Find answers to frequently asked questions related to conflict of interest policies at Saint Louis University.
The employee is responsible for disclosing their relationships annually and within 30 days of a significant change in their relationship with industry, which could include a new role with the outside entity or a relationship with a new outside entity.
The responsibility of the supporting administrative offices will include a discrete review of the disclosure along with other pertinent information, such as the employee's roles and responsibilities on behalf of the University.
The Research Integrity and Safety Group supports employees who design, conduct or report on research while the Compliance Office supports Institutional Officials and employees who provide patient care. Finally, the corresponding committee will make a determination if a COI exists, and then resolve the matter if deemed necessary.
FAQs Related to Patient Care Conflict of Interests
The policy applies to health professions faculty and clinical, educational and research support staff (including full-time, part-time, adjunct and volunteer); as well as health professions trainees at the undergraduate, graduate and post-graduate level, (including fellows and residents); and medical center administration.
The purpose of SLU's policy on medical center conflicts of interest in patient care and service describes the necessity for reporting, tracking and monitoring relationships between medical center personnel and health care products companies in order to protect the learning environment and the patient-centeredness focus of all practitioners.
LCME accreditation standards expect a medical school to have effective policies and procedures for board members, faculty members and any other individuals who participate in decision-making affecting the medical education program to avoid the impact of conflicts of interest in the operation of the medical education program, its associated clinical facilities and any related enterprises.
The Anti-Kickback Statute prohibits offering, paying, soliciting or receiving anything of value to induce or reward referrals or generate federal health care program business.
No, the Stark Law prohibits a physician from this practice.
FAQs Related to Institutional Conflict of Interests
An institutional official (IO) is someone who can affect the strategic direction of the University through their organizational role. IOs include the president of Saint Louis University, the provost, vice presidents, associate and assistant vice presidents, deans, associate and assistant deans, academic and clinical department chairs, division directors, office directors and other institutional administrators as determined by the University's executive leadership and the ICOI Review Committee.
The disclosure requirements for immediate family members follow the Physician Payment Sunshine Act - Section 6002 of the Patient Protection and Affordable Care Act (PPACA), which also conforms with the Stark Law.
The policy monitors the following:
- A situation in which an institutional official disclosed a personal relationship with a company (such as a spouse working for a company) that also sponsors research being performed by a research team under their supervision or authority.
- A situation in which an institutional official disclosed a personal relationship with a company (such as a minimal equity ownership in a company) that also is a referral site for clinical services by a provider under their supervision or authority.
- A situation in which an institutional official disclosed a personal relationship with a company (such as serving in a non-compensated leadership role for the company) that also is a supplier of devices to the department under their authority?
The policy does not monitor the following:
- A situation in which an institutional official disclosed a personal relationship with a company (such as a spouse working for a company) that also sponsors research being performed by a research team within a different department and not under their supervision or authority.
A situation in which an institutional official disclosed a personal relationship with a company (such as a minimal equity ownership in a company) that does not have any business overlap with the institutional official or any individual under their supervision or authority.
The final rule of the Sunshine Act defines a physician's "immediate family members" in a manner similar to the Stark law regulations, specifically including a physician's spouse, parents, children, siblings, step-parents, step-siblings, in-laws, grandparents, spouses of grandparents and grandchildren, regardless of whether the person is a natural or an adopted family member.
The University opts to follow the federal guidance as far as practical. Our outside interest disclosure asks for relationships with outside entities including the individual, their spouse, dependent children, siblings, and any other person(s) residing in the individual's household.
There may be some uncertainty in disclosing the exact dollar amounts of one's immediate family member's income. If you are reticent to disclose dollar amounts, select the "value can not be determined" option on question number five which reads "select the total value of your personal financial relationship with the entity." Our objective is to identify the significance of the relationship with the outside entity. In the absence of a stated value, we will assume that the relationship is significant.