When 105 medical residents were asked if gifts from a pharmaceutical company could sway their behavior or opinion of that company, 60% said no. To this same group of medical residents, a second question was asked – what about their peers? According to the study published by the American Journal of Medicine, only 16% of the residents believed their peers could remain uninfluenced. This exemplifies a gap in self-awareness which causes us to be biased toward our own actions. We condone our own behavior, while condemning others for that very same behavior, which is only deemed inappropriate when another person is doing it.
This lack of ability to notice when we are being influenced or swayed in a specific direction is the reason why conflict of interest regulation exists in the first place. Whether potential or actual, the impact of failing to disclose conflicts of interest can be substantial, and can cause companies millions of dollars in federal charges for non-compliance. In April of this year, a large investment management corporation was fined $12 million for failing to disclose potential conflicts of interest.
How is your company managing these conflict of interest regulations? Simply adopting a COI policy is not enough. Yes, it is important to ensure your organization has created an effective COI policy. A sound conflict of interest policy should clearly define what constitutes as a conflict of interest. It should also identify the individuals within the organization covered by the conflict of interest policy. Lastly, it should also layout the procedures to be followed when managing conflicts of interests as they arise.
Beyond the written COI policy itself, it is important to consider the management process after the policy’s creation. How does the organization properly monitor and enforce compliance with the conflict of interest policy? Are annual reviews conducted? In many organizations these manual reviews can take valuable time and effort. If a company relies heavily on email as part of the conflict of interest management process, tracking disclosure can be extremely difficult and unreliable. Compliance managers should consider automating processes that make COI policy monitoring and reviewing more efficient. Taking advantage of an automated process can also help organizations better compile and maintain data on potentially conflicted individuals and entities.
Lastly, it’s imperative to consider the individuals in the organization covered by the conflict of interest policy. How easy is it for an individual to certify that he or she has no actual or possible conflicts of interest? Implement a COI management process that makes it easy for persons covered by the policy to receive, read, and acknowledge the conflict of interest certification and disclosure forms. Beyond agreement, how do affected employees disclose relationships with people doing business with your organization? An effective conflict of interest program also streamlines the process of submitting potential COI information for employees.
Establishing an efficient and effective program for managing conflicts of interest is the first step in mitigating the impact around this very real threat to highly-regulated industries. The cost of implementing a streamlined and automated solution is minimal compared to the high price of federal charges for non-compliance and failure to disclose conflicts of interest.
ConvergePoint offers Conflict of Interest Software so your organization can capture, track and have a plan for each conflict. Our Conflict of Interest Software increases transparency and supports your compliance program by automating the entire process, from requesting conflict of interest disclosure forms from employees to tracking decisions and reporting on conflict of interest disclosures.
Learn more about how ConvergePoint’s Conflict of Interest Software can help your organization stay compliant, request a demo now.