Table 1:

Potential stakeholder actions to mitigate effects of physician-industry conflict of interest. DHHS, Department of Health and Human Services.

Strategic approach	PREVENTION	REGULATION	SANCTIONS/RESTITUTION
Timing of intervention	Stop conflicts from ever arising before they occur	Supervise conflicts during their occurrence	Penalize actors after an inappropriate conflict occurs
Examples of specific actions, and the applicable stakeholder	Industry: Self-regulation to curtail types of payments empirically demonstrated to conflict with PhRMA Code’s “independence and decision-making” language Physicians: Self-regulation to curtail the most harmful kinds of payments Lawmakers: New legislation to prospectively prohibit industry payments	Payers: Exclude payment-accepting physicians from preferred networks Payers: Apply additional prior authorization and step therapy requirements to non-generic prescriptions by payment-accepting physicians	DHHS, Office of Inspector General / Department of Justice: Prosecute a broader range of industry payments to physicians as illegal kickbacks and/or false claims DHHS, Office of Inspector General: Exclude payment-accepting physicians from reimbursement through the Federal Health Care Programs