Examples of Potential Conflicts of Interest

7202.2.2 - Examples of Potential Conflicts of Interest (Rev. 63, Issued: 09-10-10, Effective: 09-10-10, Implementation: 09-10-10) CMS and the States must consider all relevant circumstances that may exist beyond the benchmarks given in §7202 to ensure that the integrity of the survey process is preserved. For example, a surveyor may not have worked for the facility to be surveyed for more than 2 years, but may have left the facility under unpleasant circumstances, or, may not currently have an immediate family member who resides there, but may have recently had one residing there who the surveyor considers to have received inadequate care. The following are typical of situations that may raise a question of possible conflicts of interest for Federal or State employees of an agency representing the Medicare/Medicaid survey and certification program. However, they do not necessarily constitute conflicts of interest. a. Participation in ownership of a health facility located within the employing State; b. Service as a director or trustee of a health facility; c. Service on a utilization review committee; d. Private acceptance of fees or payments from a health facility or group of health facilities or association of health facility officers for personal appearances, personal services, consultant services, contract services, referral services, or for furnishing supplies to a health facility; e. Participation in a news service disseminating trade information to a segment of the health industry; and f. Having members of one’s immediate family engaged in any of the above activities.