Core Systems Clinical Consultingā„¢
Conflict of Interest & Professional Independence Policy
Effective Date: October 17, 2026
Applies To: Company leadership, employees, independent consultants, and subcontractors.
Purpose and Commitment
Core Systems Clinical Consulting LLC is committed to maintaining professional integrity, objectivity, confidentiality, and independence in all healthcare consulting services. We identify, disclose, evaluate, and appropriately manage actual, potential, and perceived conflicts of interest to protect the integrity of our work and the trust of our clients.
Identification of Conflicts
A conflict of interest may arise when a financial, professional, personal, contractual, or organizational relationship could influenceā€”or reasonably appear to influenceā€”an individual's independent judgment.
Examples include prior or current employment at a facility, previous consulting relationships, financial interests, personal relationships with facility leadership, or prior involvement in clinical decisions or records being independently reviewed.
Disclosure and Review
All employees, consultants, and subcontractors must disclose potential conflicts before accepting assignments and promptly report new conflicts that arise during an engagement.
Core evaluates each situation individually, considering the nature of the relationship, the services requested, and applicable contractual and regulatory requirements.
Consultant Reassignment and Conflict Resolution
When a consultant has previously worked at or provided services to a facility, Core evaluates whether that relationship could compromise the independence of the proposed review.
If a conflict is identified, Core may reassign the work to another qualified consultant who does not have the identified conflict.
When reassignment is insufficient, Core may implement additional safeguards, obtain required approvals, or decline the engagement.
Organizational conflicts involving Core itself are evaluated separately and cannot necessarily be resolved through consultant reassignment alone.
Independent Professional Judgment
All clinical reviews, regulatory assessments, audit findings, and recommendations must be based on objective evidence, applicable regulations, professional standards, and sound clinical judgment.
Consultants may not alter findings, suppress deficiencies, or permit financial or professional relationships to improperly influence their conclusions.
Confidentiality and Information Protection
All personnel must safeguard confidential facility, resident, patient, and business information. Information may only be accessed, used, or disclosed for authorized purposes in accordance with applicable laws, professional obligations, and contractual requirements.
Government Contracts and Medicare-Related Services
For government contracts and Medicare-related independent review services, Core will evaluate and comply with applicable organizational and personal conflict-of-interest requirements, including additional disclosure, screening, recusal, mitigation, and approval procedures where required.
Accountability and Oversight
Core documents material conflict disclosures, assessments, reassignment decisions, and corrective actions in its internal compliance records.
Employees and subcontractors are expected to comply with this policy. The policy is reviewed at least annually and updated when regulatory, contractual, or operational changes warrant revision.
Our Commitment
Core Systems Clinical Consultingā„¢ is dedicated to delivering ethical, independent, evidence-based healthcare consulting services while maintaining accountability, transparency, and the highest standards of professional conduct.
Core Systems Clinical Consulting LLC
Clinical Excellence ā€¢ Regulatory Compliance ā€¢ Quality Improvement
Policy Notice: Specific legal, regulatory, and contractual conflict-of-interest requirements take precedence when more restrictive than this general policy.
