Conflict of Interest Resource Library
Understanding and managing conflicts of interest is important to ensuring that Carilion Clinic operates in a manner consistent with its charitable purpose and that it does not engage in activities that could jeopardize its status as an organization exempt from federal income tax.
A conflict of interest (COI) occurs when an employee’s, or their immediate family members’, personal interest interferes, or may be perceived to interfere, with their ability to make decisions that are in the best interest of the organization and our patients.
The following white papers are intended to assist employees with navigating potential areas of concern by offering guidance and examples. Please direct any additional questions related to conflict of interest to the Compliance Department at compliance@carilionclinic.org.
Advisory Boards - Participating in activities that rely on an employee’s professional competencies to provide opinions, guidance, or insight to a third party in exchange for a monetary compensation or non- monetary items of value.
Authorship - Individuals who have contributed in a meaningful and substantial way to an article or publication, including defining and ordering the authors of published work.
Board and Trustees Membership - Participating on non-Carilion Board of Directors or Trustees.
Charitable Donations - Accepting donations of cash, cash equivalents, or non-monetary items of value on behalf of Carilion Clinic.
Competing with Carilion Clinic - Participating in activities with a third party, who provides similar services that are offered by Carilion Clinic and are within Carilion Clinic’s service area.
Consulting Services - Providing professional services, including the production of documents, software, or other deliverables to a third party.
Donated Products for Teaching/Education - Donation of single-use material goods used solely for the purpose of training/educating employees.
Educational Awards and Grants - Acceptance of scholarships, fellowships, and other educational awards (including travel expenses to educational events) from non-Carilion entities.
External Legal Consulting and Expert Testimony - Provision of expert testimony, medical opinions, or medical chart and case reviews.
Fundraising - Raising funds, including but not limited to, solicitation of contributions, posting information, or distributing written material related to fundraising on Carilion Clinic property.
Gifts and Courtesies - Acceptance of gifts or business courtesies from current or proposed vendors.
Lobbying - Individuals seeking to influence the actions, policies, or decisions of public or government officials.
Marketing - Participating in activities that promote a third party’s products, items, or services while on Carilion Clinic property.
Meals, Food, and Beverages - Acceptance of meals, food, and beverages from current or potential vendors.
Medical Directorships - Provision of clinical administrative duties to outside entities, including but not limited to EMS agencies, hospital medical units, skilled nursing facilities, hospices, home health care agencies, community clinics, and health insurance plans.
Outside Employment (Under revision) - Individual is employed by or contracted to perform services for a third party; including business ownership.
Pharmacy and Therapeutics Committees - Committee that reviews and selects pharmaceuticals used withing Carilion facilities, as well making formulary decisions.
Patient Gifts - Acceptance of gifts from patients or their caregivers.
Professional Boundaries - Guidance to all Carilion Clinic staff in order to prevent and address issues where an inappropriate relationship develops between a patient and staff member.
Product Evaluation and Demonstration - Evaluation and demonstration of products necessary to carry out the business operations of Carilion Clinic.
Product Selection Committees - Committee that reviews and selects medical products used within Carilion Clinic facilities.
Related and Personally Involved Parties - Employment of relatives within the same area of the organization.
Travel Expenses - Acceptance of the direct provision of or reimbursement for travel from a current or potential vendor.
Continuing Medical Education (CME) - Participating in Continuing Medical Education (CME) events