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Home>Research>Office of Research Compliance>Conflict of Interest Office>Clinicians

Conflict of Interest Office

Institutional and Business
Clinicians
Researchers
Assessment of Disclosed Activities
How to Disclose at RUSH
What to Disclose
Education and Training
CMS Open Payments
COI Related Policies
Technical Assistance
Public Disclosure of Financial Conflict of Interest
FAQs

Clinicians

Conflict of Interest in Clinical Practice

Physician, advance practice provider (APP), and institutional conflicts of interest have become widespread news in recent years, particularly as it pertains to patient care. The most important duty of health care providers is to put the interests of those they serve ahead of their own. Conflict of Interest (COI) may occur when interests compromise or have the appearance of compromising an individual’s professional judgment.

Maintaining objectivity in all areas of scholarly activity (e.g., clinical and preclinical) can only serve to assure everyone’s full compliance with the myriad of health care laws that impact every physician and advance care provider. RUSH policies Conflict of Interest and Commitment (OP-0359 ) and Vendor Guidelines articulate our position on COI.

Managing Conflicts

To manage a COI, it must first be disclosed. The RUSH Clinical COI Committee reviews disclosures to determine the necessary action to manage an individual’s interest. A professional activity and/or an innovation, technology development may require monitoring to assure that an actual conflict does not occur. At times a conflict may be unavoidable and it is our responsibility to behave in a transparent manner by considering the following:

Avoid conflicts of interest when possible
Assess your private, personal interests
Disclose all professional external relationships and all innovations, technology development
Manage conflicts of interest that cannot be avoided
Comply with RUSH’s policies and procedures

Conflicts of interest can be reduced, managed and at times eliminated in a variety of ways. The choice of strategy depends on the assessment of the:

Nature and value of the disclosed financial interest/activity
Scope of the relationship
Complexity of the situation

For more information regarding managing conflicts, please click here.

For information regarding RUSH’s COI related policies, please click here.

Disclosure of External Interest

To promote physician and APP integrity and to ensure a transparent clinical practice, RUSH requires an annual disclosure of external interests, which in turn helps protect our patients, patients’ family members, students, and our institution. All non-RUSH activity is required to be disclosed annually, no matter the financial value, which occurred in the last fiscal year from July 1st through June 30th.

We seek to maintain the balance among competing interests, some of which involve financial relationships with pharmaceutical and biotechnology companies, including but not limited to the use of medical devices, professional affiliations and practice specialization, reimbursement incentives, and intellectual property. These relationships, although not all, can create conflicts of interest when physicians and/or APPs are paid for their services.

Disclosures of external interests can be disclosed through the RUSH Research Portal (RRP) by completing an annual COI survey at the end of the fiscal year. For more information and detailed instructions on how to complete your annual COI survey, please click here.

Frequently asked questions regarding what to disclose can also be found here.

COI Awareness and Education

The COI Office raises awareness of the requirements surrounding COI through education and training. The COI Office conducts education sessions for RUSH faculty, clinicians, researchers, and scientists. Additional information related to education can be found here.

Open Payments

Open Payments is a national disclosure program that promotes transparency by publishing the financial relationships between the medical industry and healthcare providers (physicians and hospitals) on a publicly accessible website developed by the Center for Medicare & Medicaid Services (CMS). Physicians should check data reported in the system on a routine basis to access accuracy of payments associated to them. Data is released to the public annually on or by June 30th and is refreshed at least once annually.

As of January 2021, CMS Open Payments will start posting data on the publicly accessible website for APNs, PAs, RNs.

Detailed information can be found here.

Open Payments link can be found here: https://openpaymentsdata.cms.gov.

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