Saturday, March 8, 2008

Conflicts of Interest 2008

In all of my jobs and activities I try to be very transparent about all I do, both good and bad. In the interest of full disclosure, I thought it would be useful to describe all my affiliations, my disclosures, and my attempts to avoid conflicts of interest.

Having just finished my tax returns, I can tell you that my income is just a W2 from BIDMC, which invoices Harvard for the time I spend there. I did this to avoid having two paychecks and FICA deducted twice.

Any income I receive from speaking engagements or consulting I donate to BIDMC to minimize conflict of interest.

In 1993, I created a family trust and all my savings/investments are managed in that trust by an independent third party. The trust does not invest in technology related stocked or bonds.

Harvard has very strict rules about working with for-profit companies. No Harvard logos can be used in association with a commercial product. No organizational endorsements are permitted i.e. "Harvard thinks this is the best product on the market!". Case studies are fine and objective comments about functionality are permissible i.e. "I tested 5 products and found product x met my specific functional criteria."

Anytime I do case studies, they are reviewed by Public Affairs at Harvard Medical School for appropriateness. Anytime I have a question about serving as an adviser or board member, I inform Corporate Compliance at CareGroup and seek permission. Here are the roles I serve in for-profit companies and the financial arrangements:

Google Health Advisory Council - For the past year, I have served as an unpaid advisor on the Google Health Advisory Council. Since several individuals working on the Council are from non-profits and share my feelings about objectivity, Google circulates a form among the group so we can specify our preferences about being paid for our time. I have not accepted any personal compensation for the meetings, phone calls, policy advice and standards work.

Healthline Medical Advisory Board - Healthline has a built a search engine that uses controlled vocabularies/ontologies in an attempt to deliver more specific search results to users i.e. it knows that brains contain neurons and thus a search on neurons also looks at diseases of the brain. I serve on their advisory board to offer suggestions about how to incorporate medical knowledge in the search process. I have not accepted any compensation. I was asked to serve as an adviser by one of my former professors, who leads the Medical Advisory Board.

Whole Health Advisory Board - Whole Health provides workplace based medical services and wellness management. They use electronic health records throughout their clinics to optimize quality and safety. I was asked to serve as an adviser by a colleague at Harvard Business School. I have not accepted any compensation.

SafeMed Board of Directors - I rarely serve on the Boards of companies, but I made an exception with SafeMed because I so strongly believe in their mission - to make decision support available to doctors, patients and payers using a web-services architecture. They are the decision support behind Google Health, informing patients about medication interactions. I have not received any cash compensation for my Board service and will receive stock options, as is typical for Board members. These options will be declared with Harvard and CareGroup and I will recuse myself from any decisions regarding purchasing of SafeMed products. At present, CareGroup uses SafeMed as part of our Blue Cross funded pay for performance initiatives and CareGroup did not purchase products from SafeMed as part of that effort.

ePocrates Board of Directors - ePocrates is handheld prescribing software that runs on Treos, Blackberries and the iPhone. Many attending physicians, residents, and medical students at Harvard download the free version of ePocrates. Since it is the most popular mobile software used by clinicians at BIDMC and Harvard, I agreed to serve on the Board of Directors. I have not received any cash compensation for my Board service and did receive stock options, as is typical for Board members. These options were declared on the Harvard and CareGroup conflict of interest statements. CareGroup and Harvard have not purchased any products from ePocrates and I will recuse myself from any purchase decisions if any product selection is done in the future.

Blackberry Advocate - In 2007, I flew to a New York City SOHO studio and spent a day speaking about the way mobile devices impact my life. It was unscripted and captured my honest feelings about life as a highly connected human. What did I do to keep my objectivity? If you go to the Blackberry website, you'll see that it calls me "John Halamka, CIO and Emergency Physician", specifically removing my institutional affiliations. I worked very hard with Harvard and CareGroup counsel to ensure all materials did not include organizational endorsements, logos, or sales literature. The Blackberry media campaign in magazines, videos, and elevators was very professionally done. I did my best to express my personal belief in the utility of wireless devices while minimizing conflicts. When I walked on the set, I was given union scale wages for the day ($100 plus residuals) as would be done for any TV appearance by an extra and I donated that to BIDMC as well as disclosed it to Harvard and BIDMC corporate compliance.

These are all my for-profit company activities. I hope my attempt to isolate any conflicts of interest sound reasonable to you. The only companies from this list that I have mentioned in my blog are Google and SafeMed. For my Google entry on February 28, 2008, I specifically mentioned my Advisory Council service. Regarding my SafeMed entry of November 12, 2007, I began my Board service on February 1, 2008, so this entry is my declaration.

If there is anything I can do to adhere to other best practices, ensuring my objectivity, let me know!


Jean-Baptiste said...

Wow that's an impressive list of activities. How do you find time to do that, and blog - not to mention be a CIO?

John Halamka said...

Whenever possible, I avoid travel and use collaboration software to join company events. Ideally, I can work asynchronously and review materials nights and weekends, then email responses. Later this week, a CIO magazine article will detail my experience with working virtually via a Web 2.0 technologies and I'll post the link.