Disclosure of Financial Interest Policy Disclosure

Transcript:Disclosure of Financial Interest Policy Disclosure:
Disclosure of Financial Interest Policy Disclosure of Financial Interest Policy Medical Staff Policy Approved by the MEC’s Aimed at protecting the integrity of Lee Health Medical Staffs Requires disclosure of certain financial interests at the time of appointment, reappointment and throughout appointment cycle Promotes transparency, does not prohibit legally compliant payments or ownership interests Prompted by the Physician Payment Sunshine Act and/or Florida law related to Public Agency laws 1 Open Payment Program (*previously titled Physician Payment Sunshine Act) Part of the Patient Protection and Affordable Care Act Final Rule released by the Centers for Medicare & Medicaid Services in February 2013 Purpose is to prevent fraud, abuse and waste in the health care system Aims to increase transparency of financial relationships between the drug and device industries, healthcare providers, and patients *Now referred to as Open Payment Program 2 Open Payments Program Requires drug, device, biological and medical supply manufacturers and distributors to report, in significant detail, payments made to physicians and other medical institutions to the Federal Government on an annual basis Affected manufacturers and distributors (including group purchasing organizations (GPOs)) must also report certain ownership or investment interests held by physicians and their immediate family members 3 Open Payments Program List of reportable payments is very broad Includes consulting fees, honoraria, food, beverage, entertainment, travel, and education Data collection started August 2013 Must be reported to CMS by March 31 annually Data collected each calendar year is published each June of the following calendar year 4 Disclosure of Financial Interest Policy M14.01.078 5 Disclosure of Financial Interest Policy (M14.01.078) Applies to Medical Staff Members (a physician, dentist, podiatrist, or psychologist with membership on one or more Medical Staff of Lee Health and all Advance Practice Providers credentialed by any Lee Health Medical Staff) Completed Disclosure of Financial Interest Questionnaire sent to Medical Staff Services Failure to disclose/non-compliance Initially handled by Medical Staff Services 15 days to comply (optional additional 15 by MS President) Referred to MEC 6 Disclosure of Financial Interest Policy (M14.01.078) Financial Interests are defined as Payment(s) or Transfer(s) of Value from a Drug, Device, Biological or Medical Supply Vendor, Manufacturer or Supplier to the Medical Staff Member that are: $500.00 per payment/transfer or $1500/total for reporting period. Which is defined as (1) the twelve month period prior to the initial disclosure or (2) the time period between disclosures (i.e. reappointment period) Or an Ownership