Ethics and Compliance Services is excited to announce a new process for designated staff to disclose possible conflicts of interest (e.g., business ownership, gifts received, relatives employed at ANTHC, board memberships, etc.).
Who Will Have to Disclose Possible Conflicts?
At this time, only the following staff will be required to complete the disclosures:
- All Physicians and Residents
- Any direct hire, Commissioned Corps, or contracted staff member whose position is designated as a manager (i.e., has a manager code assigned).
These staff have been selected because they have either a high degree of responsibility for patient care or have decision-making authority for hiring, firing, compensation, etc. These types of positions have been identified as having the highest risk for conflicts.
How Will Possible Conflicts be Disclosed and Reviewed?
ANTHC will utilize a web-based system (NAVEX Disclosure Management Tool), which designated staff will use to disclose potential conflicts of interest. The NAVEX system will lead users through a brief questionnaire that covers all the categories of disclosures and collect the information needed to evaluate those disclosures. The questionnaire will be available for a full year, so should anything change, staff can return to their answers and update them or add new disclosures.
Disclosures will be evaluated by trained staff from Compliance, Human Resources, or Legal, as appropriate, to determine if a conflict could or does exist and document any follow-up mitigation. This system will allow ANTHC to more proactively manage the risks of conflicts of interest and create a centralized location for tracking disclosures.
When Will This New Process Start?
The link to the first questionnaire will be distributed by email to designated staff beginning Monday, February 3, 2025, and staff will have 30 days to complete it. New hires who fall into one of the prioritized categories will be automatically added to the system and receive the questionnaire link via email.
In addition, the Compliance team has developed an FAQ that will be made available to staff who have to complete the disclosure questionnaire to ensure they can navigate the system.
You can download the FAQ about this new system below.
