Policy: 1-03-Conflicts of Interest

Approved By: MMS	Date: 12/08/2009	Implementation Date: 12/08/2009
Revision/Reviewed By:	Date: 07/25/2011	Implementation Date:

Standards: New (DRX 1-3A, 1-3B)
Revision: Version 1.4
Title: Conflicts of Interest
Process
MSI BOD will implement a written conflict-of-interest policy that includes guidelines for the disclosure of any existing or potential conflict of interest

Outcome

1. Define and guard against any foreseeable activities that constitute a conflict of interest among individuals or groups directly involved with MSI from a financial or operational perspective.
2. Conflict of interest is minimized or prevented within MSI.

Procedure

1. The following is defined as a conflict-of-interest:
   1. An operational or financial association of a member of the BOD with any group or organization regarded as competitor to MSI.
   2. Participation, directly or indirectly, with a source of patient referrals, in a captive referral arrangement wherein patients are directed to utilize MSI without regard for the patient’s right to select their supplier.
2. MSI governing body, staff members, and organization representatives are informed of the existing conflict-of-interest policy and are charged with implementing said policy.
3. Any administrative, management or staff personnel, BOD member, and/or organization representative encountering an existing or potential conflict-of-interest adhere to the following procedure:
   1. The Ethical Resolution Checklist may be used to assist MSI in documenting and resolving ethical issues.
   2. The BOD will review the information, with the PRESIDENT, and direct investigations, as necessary, designating those individuals responsible for carrying out said investigation .
   3. The individual(s) responsible for the investigation will report back to the BOD with details and/or recommendations within a 30-day time period.
   4. If a conflict of interest is ascertained, the BOD takes the appropriate actions necessary to resolve the conflict.
4. MSI reviews its relationship and its staff’s relationship with other care providers, educational institutions, and payers to ensure that those relationships are with law and regulations and determine if conflicts of interest exist.
5. MSI will not permit an employee to provide in-home a service a patient if that patient is a parent, spouse, stepparent, legal guardian, power of attorney or authorized representative.

MSI CONFLICT OF INTEREST NOTIFICATION