Sunshine Act, Ethics and Consequences

Yesterday, I was privileged to present to 1200 sales reps of a major healthcare company, a program on the ethical implications of the Sunshine Act.
Premise:
Transparency means having a reflective process in place and providing tools that allow honest feedback on one’s decisions. Consider these four focal points to keep that reflective process ongoing.
Highlights in a nutshell are:
1.Conscience(intuition, “gut”, moral code).
– Must be well informed
– Objectively educated
-Considered a non-negotiable.
2. Choice:
-On what basis on you making this decision?
– Be aware of whom you benefit, whom you burden and how that choice was made.
– What will be the effect of that choice: pros and cons.
– Are you willing to be held accountable for your choice?

3. Culture:(beliefs and practices of a company)
-Any perception of wrongdoing can seriously harm your reputation.
– Find every opportunity to practice the virtues of integrity, trustworthiness, honesty
and compassion.
– A culture is only effective if people trust those who were instrumental in creating it.

4. Compliance: What does the law say?
– Always a key consideration of every decision made.

– When in doubt:
* Never make the decision, yet!
* Ask your compliance department for input.
* Think about the short and long term effect.
* Make the decision when you have all the information you need.

I’m reminded of the quote by Robert Louis Stevenson: “Sooner or later we all sit down to a banquet of consequences.” The choice is what kind of consequence, good or bad?