Consultant Physician

BOX 3-1 Model of Steps Used to Identify and
Respond to a Conflict of Interest
Step 1 Obtain the disclosure of information about financial and other relationships that
could constitute a conflict of interest.
No relationships reported: stop. Relationships disclosed: go to Step 2.
Step 2 Evaluate the disclosures—in light of the individual’s responsibilities or specific
activities (e.g., research, teaching, and patient care)—to determine whether a conflict of
interest exists. If necessary, collect additional information to assess the likelihood of
undue influence and the seriousness of possible harms.
No conflict exists: stop. Conflict exists: go to Step 3.
Step 3 Determine whether the relationship is one prohibited under institutional or other
policies or whether the risks of the relationship are so serious that the individual
should either eliminate it or forgo participation in the activity put at risk by the
relationship.
Conflict elimination necessary: go to Step 5. Elimination not necessary: go to Step 4.
Step 4 If management is appropriate, devise and implement a plan to manage the
conflict. Go to Step 5.
Step 5 Monitor conflict elimination or management plan and assess adherence.
Plan followed. Plan not followed: go to Step 6.
Step 6 Determine the nature of the noncompliance and the appropriate response (e.g.,
education, penalty, or revision of the plan) and implement the response.