Annual Disclosure Survey

Commonly Asked Questions

If you didn't find an answer to your question on this page you can contact members of the Office for Regulatory Affairs, the Joint Survey Administration Team, and other external compliance contacts on our contact us page.

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Answers

  • How do I start my online survey?
    The instructions for logging into the survey site will be distributed to all survey participants via email on February 1, 2013.
    The survey site will be activated on the same day, February 1st, and can be found by clicking on this link: http://jointsurvey.feinberg.northwestern.edu.
  • Who is required to participate in the survey?
    You are required to complete a survey if you are a member of one or more of the following entities and have a specified role:

    Northwestern University Feinberg School of Medicine (Feinberg):
    • Full-Time Faculty (Regular and Research)
    • Part-Time Faculty (Regular and Research)
    • Contributed Services, Health System Clinician, and Regular-Lecturer Faculty
    • Other Faculty (Adjunct, Emeritus, or Co-Terminus, if also a NMFF physician/consultant or NMH Medical Staff)
    Northwestern Memorial HealthCare (NMHC):
    • Board Members (current and former) - for 990-related purposes
    • Board Committee Members - for 990-related purposes
    • Corporate Officers (current and former) - for 990-related purposes
    • Highly Compensated (current and former) - for 990-related purposes
    • Senior Leadership - for 990-related purposes
    • Management
    • Other Decision Makers (Case Management/Social Work, Purchasing/Materials Management, Pharmacy staff)
    • Department Chairs, Division Chiefs, Medical Directors
    • Medical Staff (non-employees and NMPG employees)
    • Health Professional/Doctoral Level Staff
    • Mid-Level Providers (affiliated with NMHC or NMPG)
    • Purchasing-related Committee Members and Invitees (for the P&T committees and the Medical Device committees/sub-committees)
    Northwestern Medical Faculty Foundation (NMFF):
    • Board Members (Outside Directors and Inside Directors) - for 990-related purposes
    • Senior Leadership and Key Employees - for 990-related purposes
    • Management
    • Physician/Members
    • Physician/Consultants
    • Physician/Employees
    • Mid-Level Providers
    Children’s Hospital of Chicago Medical Center (Lurie Children's):
    • Board Members (current and former) - for 990-related purposes
    • Board Committee Members - for 990-related purposes
    • Corporate Officers (current and former) - for 990-related purposes
    • Highly Compensated (current and former) - for 990-related purposes
    • Senior Leadership
    • Senior Management
    • Other Management
    • Department Chairs, Division Heads, Medical Directors
    • Medical Staff (those in Practice Plans and Community Based)
    • Health Professional/Doctoral Level Staff
    • Mid-Level Providers
    • Purchasing-related Committee Members and Invitees (for the Product Valuation and P&T committees)
    The Rehabilitation Institute of Chicago (RIC):
    • Physical Medicine & Rehabilitation Department
  • Why am I being required to take this survey?
    As per the conflict of interest policy at your organization, you hold one of the roles that requires participation in this annual disclosure process. You can visit the following website to access the policy that relates to your organization(s):
    www.feinberg.northwestern.edu/compliance/links/.
  • Have any of the disclosure and Conflict of Interest Policies changed recently?
    In 2010, the Feinberg disclosure policy was extended to cover contributed services faculty. That same year, Northwestern Medical Faculty Foundation (NMFF) expanded its Conflict of Interest Policy to include Physician Consultants and Feinberg changed its policy to align more with the policies of its affiliate institutions. Additionally, Lurie Children's created their Disclosure and Management of Outside Activities Policy. In 2012, the Feinberg policy was updated to incorporate changes that Northwestern University implemented to comply with recently promulgated regulations from the Department of Health and Human Services, i.e. the Final Rule. NMHC’s Gifts and Business Courtesies Policy was also updated in 2012. Updated policies will be provided here as they are made available: www.feinberg.northwestern.edu/compliance/links/.
  • What is the difference between the Conflict of Interest and Professional Integrity Policies?
    Northwestern University Feinberg School of Medicine (Feinberg), Northwestern Memorial HealthCare (NMHC), Northwestern Medical Faculty Foundation (NMFF), and Children’s Hospital of Chicago Medical Center (Lurie Children's) have all adopted conflict of interest policies that require the disclosure of various types of relationships and provide mechanisms for managing conflicts. The conflict of interest policies are available by clicking on this link: www.feinberg.northwestern.edu/compliance/links/. Additionally, Feinberg, NMHC, and NMFF have developed policies governing what kinds of relationships are allowable and guidelines for structuring these relationships. These policies address issues such as acceptance of gifts or meals, attendance at educational programs, consulting arrangements, and vendor relationships. The professional integrity policies are available by clicking on this link: www.feinberg.northwestern.edu/compliance/links/. In 2010, a new document, the Professional Integrity Handbook ("Handbook"), was created for physicians who hold one or more role(s) at Feinberg, NMHC and NMFF. NMFF also adopted this Handbook as its new professional integrity policy, thus all physicians who are either NMFF physician members or physician consultants must comply with the Handbook. The guidelines set forth in the Handbook were developed by combining elements of Feinberg's Disclosure and Professional Integrity Policy, NMHC's Gift Policy, and NMFF's previous Business Integrity Policy, in an effort to arrive at a consistent policy across all three organizations with respect to various issues and topics. Thus, while NMFF policy, compliance with the Handbook also ensures that you will be in compliance with Feinberg and NMHC policies as well. The Handbook was updated on January 1, 2013 to ensure its alignment with the updated Feinberg disclosure policy and NMHC gift policy; its application was also extended to NMFF-employed physicians, mid-level providers, and other employees.
  • Why is Feinberg administering the survey?
    In the past, Feinberg, Northwestern Memorial HealthCare (NMHC), Northwestern Medical Faculty Foundation (NMFF), Children’s Hospital of Chicago Medical Center (Lurie Children's), and the Rehabilitation Institute of Chicago (RIC) surveyed independently and at different times of the year with different tools, questions, and timeframes for reporting. Many of our faculty also received up to five separate surveys. The result was varied completion rates, confusion, and frustration. A steering committee, comprised of individuals from the three entities was created and worked to design and implement a joint survey tool. Feinberg is the entity that administers the survey on behalf of the other entities (NMHC and NMFF). Lurie Children's joined our survey efforts in 2010 and RIC joined in 2011. Leadership from all entities reviews their corresponding survey participants' disclosures.
  • What timeframe do survey questions cover?
    Survey questions relate to activities and relationships in the prior calendar year, in this case 2012.
  • What kinds of questions are included in this survey?
    The types of questions you receive depend on your position/role within each entity. Possible question categories include:
    • Service on board of directors/other fiduciary relationships (for yourself and your immediate family members)
    • Ownership or investment interests (for yourself and your immediate family members)
    • Receipt of gifts/favors (for yourself and your immediate family members)
    • Compensated/uncompensated relationships which include:

      • Academic/other professional relationships
      • Industry relationships (for yourself and your immediate family members)
      • Expert witness testimony/legal consulting
      • Royalty payments and inventor share
    • Time commitment
    • Research-related questions
    • Others
    Click here to see a list of all possible questions, along with corresponding definitions, that may appear on your survey, depending on your entity and role assignment:
    Sample Questions  Sample Definitions
  • Will I need to disclose the amounts that I earned from my external relationships?
    Yes, you will need to disclose amounts that you earned from each compensated relationship. Please note, no reporting threshold exists; all compensation-however small or large-must be reported.
  • What information or documents will I need to complete the survey?
    You tax records or other documentation of compensation may be helpful, as you will need to disclose amounts earned from compensated activities.
  • What are key dates for the survey?
    The survey will be distributed via email on February 1, 2013; the survey deadline is February 28, 2013.
  • What happens if I don't complete the survey by February 28, 2013?
    Failure to complete the survey by the deadline may result in your name being given to the Feinberg Vice Dean for Regulatory Affairs, the NMHC Chief Integrity Executive, the NMFF Chief Compliance Officer, the Lurie Children's Director of Compliance, and/or the RIC Director of Compliance. Specific steps for non-compliant physicians are outlined in the Joint Affiliate Annual Disclosure Survey - Submission Process Flows, which can be accessed here: http://www.feinberg.northwestern.edu/compliance/links/.
  • Will the information I submit appear online? Where will it be displayed?
    Yes. If you hold a full-time, part-time, or contributed services appointment at Feinberg, much of the information gathered in the survey will be posted on the Feinberg website for viewing by patients and the public in general. This information will be displayed under the "External Professional Relationships" section of your faculty profile. Click here to search faculty profiles: http://fsmweb.northwestern.edu/faculty/. NMHC and NMFF also include links to these profiles on their respective physician finder websites.
  • What information will be shown online?
    We will list the following information (if applicable to you): (i) your academic/other professional relationships, (ii) your industry relationships (which include consulting and related activities, ownership or investment interests, and royalty payments and inventor share); and, (iii) your service on boards of directors. We will only list the names of the entities with which you have relationships, not the compensation you have received from them. We will, however, note if the relationship was “voluntary/non-compensated.”
  • When will the information I submit appear online?
    Summer 2013 for the 2013 Joint Annual Disclosure Survey.
  • Who will review the information that I provide?
    For Feinberg faculty who have multiple roles, a joint review process has been implemented, whereby disclosures are examined at three levels - by your division chief (when applicable), by your department chair, and by joint entity leadership. Disclosures related to research are also forwarded to the Feinberg Conflict of Interest Committee for further review and consideration.
  • I received the survey at more than one email address. Do I have to take it multiple times?
    No. You may receive the survey announcement on various email addresses, but you only need to complete the survey once. If you wish to only receive survey-related communications at a single address, please contact our office to let us know your preference and we will remove any other email addresses we may have on file.
  • Who can I contact for technical assistance or survey support?
    You may Contact the Joint Annual Disclosure Survey Administrators:
            Bridget Chamberlain, Director of Compliance, Feinberg
            Email:  bridget-chamberlain@northwestern.edu
            Phone:  (312) 503-2855
                
            Caitlin Wilkes, Compliance Consultant, Joint Annual Disclosure Survey Team
            Email:  caitlin-wilkes@northwestern.edu
            Phone:  (312) 503-2941       

            AnnaLisa Daniele, Compliance Analyst, Joint Annual Disclosure Survey Team
            Email:  a-daniele@northwestern.edu
            Phone:  (312) 503-2966

    For general survey questions/concerns:
            Email:  disclosure@northwestern.edu
            Phone:  (312) 503-SURV (503-7878) 

This page last updated Feb 22, 2013

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