Corporate Responsibility G-001 Conflicts of Interest POLICY and Addendums 012721

.pdf
School
Eastern Gateway Community College **We aren't endorsed by this school
Course
NURSING RN NUR2801
Subject
Management
Date
Nov 13, 2023
Pages
25
Uploaded by HighnessTank3001 on coursehero.com
Effective Date: January 27, 2021 Page 1 of 3 Conflicts of Interest © Copyright 2019-2021 CommonSpirit Health. For Internal Use Only. COMMONSPIRIT HEALTH GOVERNANCE POLICY SUBJECT: Conflicts of Interest EFFECTIVE DATE: January 27, 2021 POLICY NUMBER: Corporate Responsibility G-001 ORIGINAL EFFECTIVE DATE: February 8, 2019 POLICY It is the policy of CommonSpirit Health to provide for the disclosure and subsequent review and management of Conflicts of Interest that may exist for Persons and to follow applicable federal and state laws relating to the disclosure and management of such conflicts. Each Person has a continuing duty to disclose actual or potential Conflicts of Interest in a manner that complies with this Policy. SCOPE All Persons are subject to this Policy and the obligations contained herein. DISCLOSURE, REVIEW, AND MANAGEMENT OF CONFLICTS OF INTEREST General Obligation . Each Person must promptly and fully disclose to their direct manager, supervisor, medical staff office, board or board committee, or other appropriate individual or body, any situation or circumstance that may create a Conflict of Interest. The Person must disclose the actual or potential conflict as soon as they become aware of it and annually thereafter in accordance with this Policy or until the conflict no longer exists. Any question as to whether a circumstance presents a Conflict of Interest should be resolved in favor of disclosure. Persons Obligated to Disclose . The following Persons shall disclose actual or potential Conflicts of Interest at least annually (via a formal, System-administered survey) if the Person's affiliation with the System continues: Members of corporate and community boards of System Entities Members of committees of corporate and community boards of System Entities Members of the Executive Leadership Team of CommonSpirit Corporate officers of System Entities Employees of System Entities at the Vice President level and above All individuals engaged in Research at institutions owned or operated by a System Entity
Effective Date: January 27, 2021 Page 2 of 3 Conflicts of Interest © Copyright 2019-2021 CommonSpirit Health. For Internal Use Only. Select Employees, as determined from time to time by leadership ( e.g., Supply Chain Employees below Vice President with contracting responsibilities, Medication Use and Management committee members, and Key Employees and highest compensated employees as specified by the Internal Revenue Service (IRS) for Form 990 purposes who are not included in the categories above) Conflict of Interest Review and Management . Disclosed Conflicts of Interest shall be reviewed by designated individuals (identified in the Addenda to this Policy). If necessary, a Conflict of Interest Management Plan shall be developed, which plan shall be subject to acceptance by the appropriate direct manager, supervisor, medical staff office, board or board committee, or other appropriate individual or body. Once accepted, the Conflict of Interest Management Plan shall be communicated to the Person with the actual or potential conflict so they may conduct themselves in conformance with the plan. CONFLICT OF INTEREST RECORD MAINTENANCE Historic Conflicts of Interest records (in the form of a central data repository or otherwise) of Conflicts of Interest disclosures, reviews, and plans shall be maintained and preserved for seven (7) years from the year of disclosure or until any related civil, criminal, or regulatory proceedings have concluded, whichever is later. OTHER APPLICABLE STANDARDS & LAWS This Policy is intended to supplement, but not replace, any federal or state laws governing conflicts of interest applicable to nonprofit corporations. This Policy also supplements, but does not replace, the CommonSpirit Health Standards of Conduct: Our Values in Action Policy and Reference Guide. FAILURE TO ADHERE TO POLICY A Person who fails to adhere to this Policy may be subject to disciplinary or corrective actions including, without limitation, employment termination or removal from board or committee service. REVIEW OF POLICY This Policy will be reviewed by the CommonSpirit Board of Stewardship Trustees no less frequently than every five (5) years from the date it becomes effective or from the date of any subsequent review or amendment.
Effective Date: January 27, 2021 Page 3 of 3 Conflicts of Interest © Copyright 2019-2021 CommonSpirit Health. For Internal Use Only. AFFECTED AREAS OR DEPARTMENTS This Policy applies to CommonSpirit and its Direct Affiliates [1] and Subsidiaries, [2] as well as any other related entity whose governing documents expressly require or provide for such entity(ies) to comply with CommonSpirit's policies and procedures (Conforming Entity). ADDENDA: A Conflicts of Interest Definitions B Conflicts of Interest Disclosure and Review Process C Board Members, Trustees, Board Committee Members, Corporate Officers, and Executive Leadership Team D Employed Physicians, Physician Administrators and Leaders, and Employed Advanced Practice Providers E Employees other than Physicians and Advanced Practice Providers F Research Conflicts of Interest APPROVED BY COMMONSPIRIT HEALTH BOARD: January 21, 2021 [1] A Direct Affiliate is any corporation of which CommonSpirit Health is the sole corporate member or sole shareholder, as well as Dignity Community Care, a Colorado nonprofit corporation. [2] A Subsidiary refers to either an organization, whether nonprofit or for-profit, in which a Direct Affiliate holds the power to appoint fifty percent (50%) or more of the voting members of the governing body of such organization or holds fifty percent (50%) or more of the voting rights in such organization (as evidenced by membership powers or securities conferring certain decision-making authority on the Direct Affiliate) or any organization in which a Subsidiary holds such power or voting rights.
Page1of 25
Uploaded by HighnessTank3001 on coursehero.com