Conflict of Interest Policy
Conflict of Interest
The UnityPoint Health Board of Directors adopted an enterprise-wide Conflict of Interest Policy to set forth organizational beliefs and policies regarding:
- Conflicts of interest
- Identifying corporate entities and individuals (“covered person”) subject to certain requirements under the policy
- Explaining the requirements and activities associated with identifying and ethically resolving conflicts of interest on the part of individuals affiliated with the UnityPoint Health
Identification and resolution of conflicts of interest which may exist on the part of directors, officers, key employees and certain members of the medical staff is required by standards promulgated by accrediting organizations, the Internal Revenue Code and Treasury Regulations governing tax-exempt organizations, and by requirements placed upon providers by Medicare and Medicaid program regulations.
UnityPoint Health has adopted this policy not only to meet the above-stated requirements, but as a matter of ethics, corporate responsibility, sound management practice, and to afford protection, where available, where some duality of interest exists. In such situations, full and timely disclosure of the individual's interests in connection with transactions - which are otherwise proper and fair to the organization - provides protection against individual liability.
The enterprise-wide approach to identification and resolution of conflicts of interest includes the following elements: Resolution of the UnityPoint Health Board of Directors in regard to conflicts of interest; Article V, Section 6, Paragraph b of the UnityPoint Health Corporate Bylaws assigning conflicts of interest responsibilities to the Board Development Committee; annual distribution of this policy and disclosure questionnaires to be completed by individuals subject to disclosure requirements under this policy, the Internal Revenue Code or Medicare/Medicaid program regulations.
A single, enterprise-wide committee consisting of the Executive Director of Internal Audit, UnityPoint Health Compliance Director and the General Counsel review all annual disclosure questionnaires and interim supplemental disclosures from designated categories of persons within UnityPoint Health who are subject to this policy.
Definition of Conflict of Interest
A conflict of interest may occur if a UnityPoint Health covered person's outside activities, personal financial interests or other personal interests influence, or appear to influence, their ability to make objective and unbiased decisions about their job responsibilities. A conflict of interest may also exist if the demands of any outside activities hinder or distract a covered person from the performance of their job or cause the individual to use UnityPoint Health resources or confidential information for anything other than UnityPoint Health purposes. UnityPoint Health covered persons are obligated to ensure they remain free of conflicts of interest in the performance of their responsibilities at UnityPoint Health.
Outside Business Activities
A conflict of interest may exist where a covered person, or their family member, engages in outside business activities that conflict with the best interests of UnityPoint Health, resulting in a financial or non-financial gain to the covered person or their family member engaging in such conduct. "Outside business activity" means services as a director, trustee, officer, owner, committee member, employee, independent contractor, consultant, advisor, agent or similar position with another organization (regardless of whether the organization is charitable or for-profit in nature).
Corporate Opportunity
A conflict of interest may exist when a covered person or their family member seeks to take advantage of a corporate opportunity, or enables another interested person or other organization to take advantage of a corporate opportunity, that they have reason to believe would be of interest to UnityPoint Health. For purposes of this policy, “corporate opportunity” means a business opportunity presented to an officer, director, key employee or reporting physician that UnityPoint Health:
- Is financially able to undertake
- Is in UnityPoint Health's line of business and would be of practical value to UnityPoint Health
- Has an interest in or reasonable expectation of the opportunity, and the officer, director, key employee or reporting physician, by taking the opportunity, will create a conflict with UnityPoint Health; and
- The opportunity, in fairness, should belong to UnityPoint Health