URMC Compliance Program Policy Manual:
Conflicts of Interest

URMC personnel should avoid all potential conflicts of interest. Adherence to this policy ensures that personnel act with total objectivity in carrying out their duties for the institution for which they work.

To this end, URMC personnel may not be employed by, act as a consultant to, or have an independent business relationship with any of an entity's service providers, competitors, or third party payers. Nor may personnel invest in any payer, provider, supplier, or competitor (other than through mutual funds or through holdings of less than 0.5 percent of the outstanding shares of publicly traded securities) unless they first obtain written permission from their Department Chair or other senior supervisor.

Personnel should not have other outside employment or business interests that place them in the position of (i) appearing to represent the system or one of its entities, (ii) providing goods or services substantially similar to those URMC provides or is considering making available, or (iii) lessening their efficiency, productivity, or dedication to their organization in performing their everyday duties.

Personnel may not use assets owned or leased by a URMC entity for personal benefit or personal business purposes. Employees may not have an interest in or speculate in products or real estate the value of which may be affected by the business of a URMC entity. Employees may not divulge or use confidential information such as financial data, payer information, computer programs, and patient information for their own personal or business purposes.

Any personal or business activities by an employee that may raise concerns along these lines must be reviewed with, and approved in advance, by a Department Chair or supervisor.

In order for the URMC entities to comply with requirements of the Medicare program, every employee must notify a human resources supervisor and the Compliance Officer if he or she was at any time during the year preceding his or her employment with a URMC entity employed by the Medicare intermediary or carrier. An employee's failure to make this disclosure at the time of employment could cause the organization to lose its right to participate in Medicare.

Because the Medical Center participates in state programs such as Medicaid, employees must inform a human resources supervisor and the Compliance Officer if they have previously been employed by the State of New York.