Betsy Wade (bwade@signaturehealthcarellc.com) is the Chief Compliance and Ethics Officer at Signature Healthcare in Louisville, KY.
Whether a healthcare organization is a nonprofit or for-profit, federal oversight agencies have made it clear in their respective compliance program effectiveness guidance documents that a conflicts of interest (COIs) process must be implemented, managed, and monitored.
The Office of Inspector General, in conjunction with HCCA, recognized the importance of having a COI policy in 2017 when it published Measuring Compliance Program Effectiveness: A Resource Guide.[1]