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Reviewing and Managing COI Disclosures in the CMS Open Payments Database

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The following blog post is taken from remarks by Alan Beer, Corporate Compliance, Carolinas HealthCare System during a recent Webinar featuring Bill Sacks, Vice President, COI Management, HCCS – a HealthStream Company and Alan Beer.

Annually, every summer, CMS releases its open payments database where companies from pharma to medical device manufacturers are required to report any payments or gifts given to physicians and mid-level providers. Monitoring the database for payments made to your affiliated physicians can be daunting, especially for large organizations. The task can be cumbersome, time-consuming, and labor-intensive. Carolinas HealthCare System, headquartered in Charlotte, NC, has over 60,000 employees, including 2,500 physicians.

Smaller facilities can assign someone to type in their affiliated physicians, one at a time, to see whether they appear in the database. Given the scope of our operation, however, we recognized we could not reasonably manage disclosures this way.

Streamlining Database Management

Our solution was to create a client management system using Microsoft SQL Server and Microsoft Access. For some organizations, Access alone may be sufficient. The open payments database is extremely large, so it was important to narrow the data to the states we serve. Because we are a regional referral center, we elected to download all payment disclosures from North and South Carolina.

I’m now able to run a couple of very quick queries using SQL and can know in about five minutes whether any of our affiliated physicians appear in the open payments data. If they haven’t already disclosed payments to us, we let physicians know something is sitting out there in the open payments database and send them a link to review it.

Processing disclosure data is only a part of what your organization needs to do to manage disclosures properly. Institutional policies must also be developed.

Processes, Policies, and Procedures

We created a conflict of interest oversight council, made up of stakeholders from throughout the system—legal, clinical, and materials resource management. The council established guidelines for reviewing potential conflicts, including limits on the amount of compensation received and an acceptable amount of time physicians may commit to outside companies. We also implemented an internal survey sent to physicians and key employees, asking them to disclose any payments they received and the time they devoted as a result.

Along with another individual, I conduct our initial review of findings. Any conflicts exceeding our internal guidelines are escalated to the oversight council, and they make the decision whether to create a master plan with administrative follow-up. When a master plan is created to address the conflict, all parties can sign off electronically using DocuSign.

By using technology to streamline our analysis and an interdisciplinary council to establish guidelines, we can efficiently and effectively manage our conflict of interest review.

Learn more about HCCS COI Management Solutions.