Chief Compliance and Ethics Officer Health Care

Policies on interactions with healthcare industry stakeholders

  • 1.  Policies on interactions with healthcare industry stakeholders

    Posted 03-18-2019 10:00 AM
    I have been reviewing the MEG and one of the measurement questions ask about" Verify appropriate policies on interactions with other healthcare industry stakeholders (e.g., hospitals/physicians, pharma/device representatives, vendors)."

    Currently we have general policies in our compliance program manual on stark/anti-kickback which states definition of the statutes, remuneration for referrals is illegal, a little bit about fair market value, all business arrangements should be reviewed by Compliance Officer, and possible risk areas. In addition, we have a section on gifts, sample medications, and conflicts of interest. Do I need more detailed policies to address this section or is what we have in our compliance manual enough? If you have examples of policies developed to address interactions with other health industry stakeholders, I would love to see these so I can compare with what we have already.

    Savannah Knuettel CHC
    Compliance Officer
    Galen Medical Group

    The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.
    2019 HCCA Compliance Institute