Related Conflict of Interest Policies

Title : Secondary/Additional Professional Activities and Outside Activities of Employed Practitioners Policy and Procedure Number : 3977, Version : 1 3. If the request for reconsideration is received by the chair of SPAC in a timely manner, the chair of SPAC will notify SPAC of the request and will advise the affected Employed Practitioner of the date and time at which SPAC will meet to review the request for reconsideration. 4. Subsequent to the meeting with the affected Employed Practitioner, SPAC will determine whether the original decision to deny the requested Covered Professional Activity should be affirmed, denied, or modified. The chair of SPAC will notify the affected Employed Practitioner of SPAC’s decision in accordance with Article IV, Section E.8. The decision of SPAC will be final and not subject to further reconsideration. I. Review of Covered Professional Activities Performed by Prospective Employed Practitioners. 1. During the process of recruiting a prospective Employed Practitioner, the appropriate Practitioner Recruiter will determine if the prospective Employed Practitioner currently has any arrangements or relationships with any Medical Group, with Banner, or with any Outside Entities that will not be terminated prior to the Employed Practitioner's employment by the applicable Medical Group. If any such arrangement or relationship exists, the prospective Covered Professional Activities must be approved by PAT, UPRT, BUCS or SPAC, as applicable, in accordance with the procedures described in this Policy. 2. If the prospective Employed Practitioner begins employment with the applicable Medical Group prior to the prospective Covered Professional Activity being approved, the Employed Practitioner may not perform the prospective Covered Professional Activity until such approval is received. The management of each Medical Group will establish a process to review all approved Secondary/Additional Professional Activities for Employed Practitioners employed by such Medical Group on an annual basis. 2. The management of each Medical Group will establish a process to monitor the amount of Secondary/Additional Compensation received by each Employed Physician in connection with approved Secondary/Additional Professional Activities in order to ensure that such Secondary/Additional Compensation is commercially reasonable and complies with the Stark Statute. 3. SPAC will establish a process to review all approved Outside Activities on an annual basis or as otherwise specified in the original SPAC decision. Such annual review will include a review of the amount of Secondary/Additional Compensation received by each Employed Physician in connection with approved Outside Activities in order to ensure that such Secondary/Additional Compensation is commercially reasonable and complies with the Stark Statute. J. Ongoing Monitoring. 1.

V. Procedural Documentation: A. PAT Request Form B. UPRT Request Form C.

Covered Professional Activity Request Form

D. Request for Chair Approval of Additional Activities for Non-Banner Entities within the Scope of Employment Form

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