Conflict of Interests Management Program Robert Michalski Chief Compliance Officer
Robert.Michalski@baylorhealth.edu (214) 820-‐3569
Bonnie Ann Sexton
Director of Compliance, Ethics and OperaSons BonnieAnn.Sexton@baylorhealth.edu (214) 820-‐4121
October 22, 2012
What is a Conflict of Interest?
About Baylor Health Care System • • • • • •
More than 300 access points in North Texas Serves 1.4 million paSents each year 3,500+ licensed beds 4,600+ physician medical staff 19,000+ employees 5.2 billion total assets
Program Oversight Board of Trustees Audit & Compliance
Chief Execu9ve Officer Chief Compliance Officer
Corporate Compliance
En9ty Compliance
Research Compliance Physician Prac9ce Compliance
Program  FoundaSon
Key Policies • • • • • • •
Conflict of Interests Financial RelaSonships in Research Entertainment for Business Purposes Gi_s and GratuiSes Honorariums Vendor Sponsored Travel NepoSsm
OrganizaSonal Vision To be trusted as the best place to give and receive safe, quality, compassionate health care.
Program Design Elements • • • • •
Individual Duty to Disclose Independent Review Standard Management Plans Wriden Guidance (Feedback) Individual Agreement to Follow Plan
Core FuncSons
P r o g r a m F o u n d a t i o n
Annual  Program
Individual Review
Considers Context
of All Roles
Eliminate, Reduce, or Manage
Maintain  Viability
Monitor
-‐ Disclosures Not Submided
-‐ Previous vs vs Current Disclosures
-‐ Management Plan Not Accepted
-‐ Physician Industry Payments -‐ Informed Consent
Assess
Why We Care
Benefit
Shaping the Culture