The Renal Physicians Association (RPA) believes that members of its Board of Directors and others in positions of leadership (such as Committee Members) have a responsibility to carry out the Association’s business for the benefit of the Association. The RPA is a professional individual membership association, and as such recognizes that many of its members will have relationships with other entities, including pharmaceutical and device manufacturers, dialysis facility owners and other organizations. Leaders of the RPA must ensure that when they consider any specific issue on behalf of the Association, they do not have a substantial conflict of interest. RPA therefore established this policy and procedures to manage conflicts of interest.

Definition

RPA considers a serious potential conflict of interest to exist when a Board member, association leader or Committee member has a relationship with, or engages in any activity, or has a personal financial interest or consulting relationship that creates a risk such that the professional judgment or actions of a Board member, association leader or Committee member regarding the RPA’s mission and core values may be unduly and inappropriately influenced.

In a practical sense, a serious perceived conflict of interest is generally defined as that level of involvement with outside relationships or interests which may cause embarrassment or lead to questions concerning the Board member or other leader’s motives with regard to RPA business.

General Principles

1. Disclosure
1. The RPA will develop and maintain processes that document, review and track potential conflicts of interest for its Board of Directors and other leaders.
2. A Conflict of Interest Form will be executed by July 1^st each year by each member of the Board of Directors and members of Standing Committees
3. The disclosure statement will name all leadership positions in dialysis organizations, industry, value based care (VBC), sponsored research and other medical or professional organizations.
4. The disclosure will include all financial relationships with these organizations, direct or indirect for the individual or their spouse including salaries, royalties, consultancies, speaker’s bureaus, honoraria, income-generating relationships with health care facilities or other funding sources. Holdings in retirement funds or mutual funds will not be reported. The fee for Medical Directorship(s) of Dialysis Facilities is also excluded. Two categories of financial disclosure will be requested:

                                                    i.     Less than $50,000/year

                                                   ii.     Greater than or equal to $50,000/year

5. Ownership positions, stock holdings, or partnerships in organizations doing business in renal medicine will be disclosed when such positions exceed $50,000 in value.
6. Members of the RPA Board of Directors or Committees may recuse themselves from discussion and voting when conflicts of interest or the appearance of conflicts of interest are present. In cases where there is a conflict of interest, uncertainty regarding a conflict of interest, or the appearance of a conflict of interest the Board of Directors will determine the need for a member’s recusal. Minutes of all meetings will list all recusals.  

2. Transparency and Standardization
1. A uniform policy on potential bias and conflicts of interest will be reviewed biannually.
2. A Potential Conflict of Interest Form will be executed by July 1^st each year by all members of the RPA Board of Director and standing committee members.
3. All Potential Conflicts of Interest Forms will be made available to all members of the Association upon request.
   

3. Evaluation

The executive committee will act as the Conflict of Interest Committee and will regularly review the Association’s Conflict of Interest policies and procedures, and make recommendations to the Board of Directors to maximize its effectiveness.

1. This committee will review the Potential Conflict of Interest forms each year, and will make recommendations to the Board of Directors concerning any actions needed to maintain the integrity of the Association.
2. A document outlining the principles this committee will follow will be prepared and reviewed biannually.
3. Any concerns brought before the Association concerning Conflict of Interest will be considered by this committee, whose recommendations will be reported to the Board of Directors.

Guiding Examples    

The examples below illustrate potential situations that may be presented to the Conflict of Interest Committee for consideration. They are intended to help guide decisions; however, all situations cannot be predicted, and each situation will need to take into account the unique circumstances it presents. In this chart, “A” means acceptable with disclosure, “M” means may be acceptable with disclosure if committee approves. “HLS”, High Level of Scrutiny, means that there is sufficient potential conflict or perception of conflict that the committee must carefully consider the candidate and their role when making its recommendation to the Board of Directors. The RPA Board of Directors must vote on recommendations for candidates affected by the “HLS” classification.

Situation                                       Committee Chair                   Board Member            Officer

Full-time employee, officer,

Board Director Member or Medical

Director of Dialysis Company                     M                                            M                         HLS

Board member of

renal-related national organization            M                                             M                         HLS

Full-time employee, officer,

Board Director Member of Value

Based Care Organization                          M                                           M                           HLS

Committee chair of

renal-related national organization     M                                             M                     M

Full-time employee, officer or

Board of Director Member of

Pharma Company or Device

Manufacturer                                       M                                              HLS                      HLS

Investor or Participant in ACO/

Shared Savings Program                   A                                               M                     M

Consultant to Dialysis

Company                                             A                                              M                     M           

Consultant to Pharma

Company or Device Manufacturer      A                                              M                     M

Substantial Ownership

Position of a Dialysis Facility

Or Facilities                                         A                                              M                     M

To be clear, all appointments to the BOD receive a high level of scrutiny by the nature of the process and that the BOD must vote on the appointment.

CERTIFICATION OF FULL DISCLOSURE

In order for the members of the Renal Physicians Association (RPA) Board of Directors, association leaders and Committee members to be fully informed during the conduct of the Association's business, any and all actual and potential conflicts of interest are required to be disclosed by each elected and appointed member of the RPA Board of Directors and all Committee members on no less than an annual basis by July 1^st of each year.  Such conflicts of interest must be disclosed to ensure that each member of the RPA Board of Directors or standing Committee has the opportunity to formulate his/her/their individual opinions about the issues being addressed by the Board or Committee with knowledge of any Board or Committee member's involvement with the issue. Conflict of interest disclosure changes/updates should be reported within 30 days of such changes in any given year. 

You are required to sign and return this form annually during your tenure and participation
on the RPA Board of Directors or Standing Committee.