Disclosure of Financial Interest Policy

Medical Staff Policy Approved by the MEC’s Aimed at protecting the integrity of the LMHS 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

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

Physician Payment Sunshine Act 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

Physician Payment Sunshine Act List of reportable payments is very broad – Includes consulting fees, honoraria, food, beverage, entertainment, travel, and education Data collection will start August 2013 Must be reported to CMS by March 31, 2014 and annually thereafter The reported information will be posted on a public website starting in September 2014

Disclosure of Financial Interest Policy Applies to Medical Staff Members & Allied Health Practitioners-applicants & current 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

Disclosure of Financial Interest Policy 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: – $ 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 or Investment interest held by the Medical Staff Member or Immediate Family Member in such a Vendor, Manufacturer or Supplier Limited exceptions to disclosure for post-purchase training programs approved on a case-by-case basis by the Medical Staff Office and Compliance Department

Disclosure of Financial Interest Policy Medical Staff Members that have a Financial Interest may provide input into Purchasing Decisions, but may not make Purchasing Decisions that may be influenced by their Financial Interest(s) A Purchasing Decision is the decision as to which Vendors, Manufacturers, or Suppliers are chosen for the purchase, lease, use, or acquisition of Drugs, Devices, Biologicals, or Medical Supplies for LMHS, made in accordance with LMHS policies and procedures

Disclosure of Financial Interest Policy The Questionnaire includes the following mitigation plan options to address potential conflicts: – divestiture of ownership/investment interests; – declination of future payments or transfers for value; or – declination of future purchasing decisions connected to ownership/investment interests or payments or transfers of value.