Compliance introduces streamlined conflict of interest reporting system

On Oct. 28, Yale New Haven’s Office of Privacy and Corporate Compliance will introduce COI SMART – a new system designed to centralize and streamline the process of completing and submitting conflict of interest surveys. Currently, surveys are administered to designated employees and other individuals in a variety of ways and through a number of platforms. COI SMART will make the process consistent throughout YNHHS.

“Covered Individuals” will receive an email with a link to the appropriate electronic survey in COI SMART. Surveys must be completed within 30 days as part of an employee’s annual review.

Covered Individuals include: key executives, directors and above, YNHHS trustees, employed medical staff members and medical staff members with administrative roles. These Covered Individuals will also receive the survey, regardless of their roles: employees of Pharmacy, Supply Chain /Procurement, Development/Foundation Office, Legal and Risk Services, Office of Privacy and Corporate Compliance, Center for Emergency Preparedness and Healthcare Solutions and Center for Outcomes Research and Evaluation; grant-funded employees; and members of these committees: Pharmacy and Therapeutics, Clinical Governance Committee and Formulary Integration Committee.

COI SMART will feature one survey form with questions tailored to the Covered Individual’s YNHHS role; the ability to auto-populate a respondent’s previously submitted information so it does not have to be re-entered each year; security controls to maintain disclosures privately; and integration with the Centers for Medicare and Medicaid Services Open Payments database.

Annual conflict of interest surveys are key to YNHHS’ commitment to conducting its business activities free from influence. If a Covered Individual discloses any financial interests, leadership roles or secondary commitments outside of YNHHS, the Conflict of Interest Committee can assess the potential conflict and determine the best way to manage it to reduce risk to the organization and protect its employees. If a potential conflict arises or changes, Covered Individuals must promptly notify their managers and update their COI forms.

For more information about COI-SMART or the COI process, contact the Office of Privacy and Corporate Compliance, 203-688-8416 or conflictofinterest@ynhh.org.