Related Conflict of Interest Policies

Title : Secondary/Additional Professional Activities and Outside Activities of Employed Practitioners Policy and Procedure Number : 3977, Version : 1 disclosure requirements of the Physician Payment Sunshine Act, it may appear to the public that the Employed Physician’s engagement in such Covered Professional Activities creates a conflict of interest with respect to prescription of drugs or other medical treatments. The public also may make the erroneous assumption that, if an Employed Practitioner discusses a particular drug or medical device during a public engagement or engages in similar Outside Activities, the Employed Practitioner is doing so as a representative of the applicable Medical Group and that the applicable Medical Group and/or Banner is endorsing such drug or medical device, thereby exposing Banner’s brand to risk. 2. As a result of the unique nature of Covered Professional Activities involving pharmaceutical and medical device companies, SPAC will consider the following factors in addition to the factors outlined in Article IV, Section E.6: a. Whether the Employed Practitioner's relationship with the pharmaceutical or medical device company will lead to innovative approaches to the provision of medical care at Banner or enable the applicable Medical Group to offer new services, cutting edge technologies, or result in process improvements. Whether permitting the Employed Practitioner to provide Covered Professional Activities to a pharmaceutical or medical device company will further the missions of the applicable Medical Group or Banner or will serve a scholarly, professional development, or other beneficial purpose. c. Whether permitting the Employed Practitioner to provide Covered Professional Activities to a pharmaceutical or medical device company will affect any contractual relationships that the applicable Medical Group and/or Banner may have with any other pharmaceutical or medical device company. d. Whether the pharmaceutical or medical device company has been sanctioned by a federal or state agency for illegal or improper conduct within the past three years. 3. Covered Professional Activities involving presentations for pharmaceutical and medical device companies should be created using the subject matter expertise of the Employed Practitioner. “Canned promotional” presentations prepared by the pharmaceutical and medical device companies are to be avoided. H. Reconsideration of Certain Decisions by SPAC. 1. In the event that a requested Covered Professional Activity is denied by SPAC, or a SPAC designee, in accordance with Article IV, Section E.8, and the denial was not based upon a finding by SPAC, or a SPAC designee, that the requested Covered Professional Activity could create a risk of liability or loss to Banner or the applicable Medical Group or otherwise could present regulatory or compliance concerns for Banner or the applicable Medical Group, the affected Employed Practitioner may request reconsideration by SPAC of such denial. 2. The affected Employed Practitioner will have 30 calendar days from the date of the denial letter within which to request reconsideration by SPAC of the denial. The request for reconsideration must be submitted in writing to the chair of SPAC and must include a written statement as to why the denial of the requested Covered Professional Activity should be reconsidered. If the affected Employed Practitioner fails to request such reconsideration within the 30 calendar day period, the original decision of SPAC, or a SPAC designee, to deny the requested Covered Professional Activity will be final. b.

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