Physicians familiar with financial conflict of interest reporting are often uncomfortable with the time tracking and reporting requirements of "conflict of commitment" rules set by hospitals and other institutions that limit time spent on industry collaboration and other outside professional activities.
Primacea has analyzed the outside professional activity policies of twelve leading academic medical centers. Eleven allow faculty physicians to spend up to 20% of their time on outside professional activities. At the twelfth, Johns Hopkins, the allowance is "determined by the department director after discussion with the faculty member."
So what constitutes 20% of a physician's time? The medical center policies specify one day per week (Columbia, Pennsylvania and Yale), four days per month (Duke and Michigan State), 13 days per quarter (Stanford and Washington University) or 48-52 days per year (Baylor, Harvard, UC San Francisco and Washington University in St. Louis).
To help ensure accurate tracking, time spent on outside professional activities should be recorded in your accounting system. Track your "Outside Days" as inventory items. At the beginning of each period, set the Outside Days inventory to the number of allowed days (for example, 52 days at the beginning of each year). Each time you invoice a client, subtract the number of Outside Days spent.
Charitable and non-medical outside activities should not be deemed to consume Outside Days. The same is arguably true for consulting done after hours, on weekends and during vacations (unless your institution specifically limits total consulting days).
For a truly accurate accounting, Outside Days should be calculated as hours spent divided by hours in your actual day. How many hours are in your normal day? Of the twelve institutions we analyzed, only UC San Francisco defines a workday (eight hours); the rest leave it to their physicians. If it's up to you, be conservative. A physician who works from about 7:15 am to 8:30 pm could comfortably define a 12-hour workday. Why is this definition needed? Because spending 4 hours consulting and 8 hours at the hospital should be recorded as one-third of an Outside Day.
Physicians are responsible not only for reporting their time spent on outside professional activities but also for keeping future time commitments within their institutions' allowances. The same accounting system should be used for both of these functions. Whenever you enter into a consulting contract, you should consider entering the time commitment as a sales order for Outside Days into your accounting system. For example, say you agree to participate in a three-day scientific advisory board meeting plus another 12 hours of consulting throughout the year. Record a sales order for four Outside Days.
Whenever you are asked for a "conflict of commitment" report, run an inventory analysis that shows how many Outside Days you have spent, have committed and have remaining.
Following these steps will allow you to both provide required periodic reports and show that you are proactively meeting your institution's time disclosure requirements. In this age of increasing transparency, such disclosures of time spent on outside professional activities will be required of more and more physicians.
