Corporate Compliance at Lahey Hospital & Medical Center

Lahey Hospital & Medical Center has a long tradition of integrity in medical practice and a code of values that guides our work and collaborations. Our Corporate Compliance Program calls on all of our employees to adhere to our policies and procedures as well as the state and federal laws that govern our mission of patient care.

Health Care and Corporate Compliance Plan

Lahey Hospital & Medical Center’s Health Care and Corporate Compliance Plan was developed to foster an environment where all staff recognize their responsibility to act in accordance with the highest ethical standards of business and the community as well as in compliance with federal, state, and local laws, rules and regulations. This plan is the foundation for other policies and guidelines.

By conducting business with integrity and mutual respect, Lahey’s physicians and employees ensure that we comply with the law, while also better serving our patients and partners.

Conflict of Interest  

Any situation where a Lahey employee may benefit financially, directly or indirectly, as a result of his or her position is a potential conflict of interest. Lahey Hospital & Medical Center expects that all physicians and staff will avoid any actual or perceived conflicts of interest so as not to affect patient safety, quality of care, treatment, research or payment for services, or interfere with Lahey’s responsibility to the community it serves.

The Conflict of Interest Policy guides Lahey’s employees in structuring appropriate relationships with providers, payors, educational institutions, manufacturers and other vendors.

Additionally, the Financial Conflict of Interest Policy for U.S. Public Health Service Funded Research assures that the design, conduct, and reporting of research funded by a Public Health Service (PHS) grant, cooperative agreement, or contract will not be biased by any conflicting financial interest of an Investigator or Research Pernonnel.

Consulting Policy

Lahey employees may provide consulting services to outside entities or individuals (for example, manufacturers or attorneys), give talks or participate in other activities for which they would be paid, including honoraria. Before providing any such consultative services, staff must disclose their intention and receive approval in advance of consulting. Compensation must be fair market value, documented in a written agreement and submitted for review with Corporate Compliance.

Specifically, Lahey forbids staff from participating in industry-sponsored speakers bureaus or engaging in purely marketing activities for a company’s products.

Solicitation and Acceptance of Gifts

Lahey Hospital & Medical Center believes that its hospital and physicians should avoid even the appearance of impropriety in all financial relationships with vendors or others who sell or otherwise supply items or services to our organization. This policy establishes procedures to ensure that all donations from any source are accepted only if they are bona fide charitable donations. This policy specifically prohibits Lahey physicians or employees from accepting personal gifts or quid pro quo arrangements.

Vendor Relationships

Like most health care organizations, Lahey Hospital & Medical Center has agreements with vendors such as pharmaceutical manufacturers, medical device companies or firms that make and sell diagnostic equipment. We expect anyone doing business with us—or seeking to do business with us--remains aware that the focus of our mission is patient care.

The goal of our Vendor Interactions Policy is to ensure that our vendor representatives conduct themselves properly and legally in any interactions with our staff. Furthermore we expect vendor representatives to comply with all Lahey policies, especially those relating to patient confidentiality and marketing and sales conduct.

Privacy and Security of Personal Information

Personal health information (PHI) includes any portion of a patient's health information that identifies a patient or can be used to identify a patient. Lahey Hospital & Medical Center is committed to protecting both the PHI of our patients and the personal information (PI) of patients and staff.

Lahey’s Identity Theft Prevention and Security Breach Notification Policy addresses ways to prevent, detect and mitigate identify theft. This policy also details the processes for investigating allegations of identity theft and notifying the affected individuals should a breach ever occur.