Governance, Risk & Compliance: GRC
New Year, New Conflicts of Interest Strategy: January Compliance Checklist
Conflicts of interest in the workplace happen more often than you might think. A senior manager approves a vendor contract, unaware the vendor employs a family member.
An employee fails to disclose a financial interest in a competitor’s business, creating a potential bias in decision-making.
These are just two examples of how conflicts of interest can quietly develop in the workplace. All while exposing organizations to reputational damage, legal risks, and strained workplace dynamics.
For compliance teams, the challenge isn’t just identifying these issues. It’s about creating processes that encourage transparency while managing the complexities of disclosure.
Many Organizations are Heads Down This Month on Conflicts of Interest Disclosure Work. Here’s What to Know and What to Do.
January is a key time for compliance teams as they focus on managing conflict of interest disclosures. (It’s a time when many organizations have to align their disclosure campaigns with the start of the calendar year.) This process is essential for protecting organizations from reputational and regulatory risks while fostering a transparent workplace culture.
However, manual methods can be time-consuming, prone to errors, and challenging to manage effectively.
Commonly heard: “Chasing up paperwork and updating spreadsheets feels like a waste of time.”
Modern management tools can simplify this process by automating tasks like disclosure collection, review workflows, and reminder notifications. Features such as configurable questionnaires and centralized data repositories help compliance teams maintain organized records and streamline annual campaigns. Additionally, carrying forward prior disclosures and using analytics dashboards allows teams to identify potential gaps and act proactively.
Commonly heard: “While there are legitimate reasons to request disclosures, it can feel intrusive.”
In industries like healthcare, where regulatory demands are high, ensuring compliance with requirements such as the Stark Law (which prohibits physicians, with some exceptions, to refer patients to family members, financial partners, and so forth) or Open Payments is critical.
Commonly heard: “The conflicts of interest process feels like a check-the-box exercise. Therefore, not taken seriously.”
By integrating management with training and policy tracking, organizations can align their practices with both internal standards and external regulations.
Start 2025 Off Right. Here’s a Suggested Conflict of Interest Preparation Checklist:
– Update Policies: Ensure your policies reflect current regulatory requirements and internal standards
– Educate Employees: Provide training on what constitutes a conflict of interest and how to disclose it effectively
– Streamline Questionnaires: Use configurable forms with branching logic to simplify the disclosure process for employees
– Centralize Records: Maintain disclosures in a single, secure database for easier access and review
– Automate Reminders: Set up automatic notifications and escalations to ensure timely submissions
– Leverage Analytics: Use dashboards to identify trends, gaps, and risks in disclosure responses
– Plan for Ad-Hoc Disclosures: Ensure a system is in place to capture new or updated conflicts throughout the year
Also Critical? Educating Employees.
Regarding a bonus resource we’d like to share, here are sample Conflicts of Interest learning objectives from SAI360’s Learning module that are critical to teach your teams:
– Recognize decisions influenced by conflicts and take appropriate action
– Understand principles, spot conflicts, and choose the best course of action
– Identify root causes, ask key questions, and escalate concerns appropriately
– Learn best practices for disclosing outside employment to ensure transparency
How Can SAI360 Help?
SAI360’s Conflicts of Interest Disclosure software offers tools designed to simplify and enhance COI management. It’s also industry-specific, including healthcare-specific. From automated workflows and centralized records to pre-built healthcare modules, SAI360 provides a comprehensive solution to streamline disclosures and improve compliance outcomes.
SAI360’s Disclosure Management streamlines conflicts of interest programs by automating time-consuming tasks and can even generate conflict management plans from scratch. Key features include:
– Compliance risk assessments
– Reporting systems
– Training modules
– Investigation tools
– Disciplinary measures
The end goal? These capabilities support compliance teams in meeting regulatory expectations while fostering a culture of transparency and trust. It’s a win-win.
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