Wednesday, July 22, 2009

Conflict of Interest - the Power of External Databases

As my last post on DoD indicated, there are some real gems waiting to be mined when comparing internal data to external data for fraud and abuse. Today's Chronicle of Higher Education reports a two-month old WSJ and UPI Story about a UCLA Surgeon who received more than $450,000 in payments from Medical Device companies, but repeatedly failed to disclose that outside income on conflict of interest forms required by the University.

Representative Charles Grassley is regularly in the news for advocating a national law (i.e. Physician Payments Sunshine Act) that would require disclosure of speaking fees. Currently, state laws and specific academic institution each set their own policies and monitoring requirements.

The Chronicle opined that "Universities also need to pay more attention to whether they review research activities by their own staff that may damage their institutional reputations even though the work involves outside facilities, Ms. Chimonas said. The case of Dr. Wang may prove a strong incentive for UCLA to do so. Even within the same statewide system, she said, there are campuses such as the University of California at Davis that have taken a much more aggressive definition of how they monitor outside research by university faculty members.

Institutions such as UCLA could be realizing the danger of ignoring outside research work, Ms. Chimonas said. "This may be a wake-up call for a lot of institutions who have been thinking, 'Well, this has nothing to do with us,'" she said."

Taking information from external databases like Excluded Parties List System (the list of Federally debarred vendors), or the OFAC Watch List is a high-value audit test, especially as frequency is increased from annual to quarterly or more frequently. UCLA's situation with Dr. Wang, especially because of reputation risk, calls for better monitoring of external databases.

What external databases are your organizations monitoring? How often? What are the more interesting findings? Please comment - all input is welcomed!

Joe Oringel
Visual Risk IQ
Charlotte NC, USA

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