Advisory: Buying Groups, Trips, Cash Rebates & Conflicts of Interest
The American Academy of Audiology Board of Directors published "Ethical Practice Guidelines on Financial Incentives from Hearing Instrument Manufacturers" (PDF) (Audiology Today, 15:3, pg 19–20, 2003). The guidelines outline various practices that create potential conflicts of interest and therefore should be avoided. For example:
- Audiologists should not accept incentives such as trips, cash, merchandise, and gifts that are based upon products purchased.
- No "strings" should be attached to any gift from a manufacturer; for example, anything of value given to the audiologist for personal use or profit by an industry representative (see guideline and FAQs referenced in the last paragraph below).
- Trips sponsored by a manufacturer are not acceptable if they are a reward to the audiologist for past sales or if acceptance of the trip commits the audiologist to future purchases (see guideline and FAQs referenced in the last paragraph below for specific examples).
The Academy Ethical Practice Committee (EPC) was asked to consider whether the above guidelines are applicable if the financial incentives originate from a "buying group." In other words, if the audiologist is obtaining hearing aids from a number of different manufacturers and receives incentives such as trips or cash from the buying group, would a conflict of interest still be present? Proponents of an exemption argue that the audiologist is removed from any conflict of interest because the incentive comes from an outside management group that is not associated with one specific manufacturer.
The opinion of the EPC is that such incentives as trips, cash rebates or other financial inducements based upon number of purchases within the buying group do constitute non-compliance with the conflict of interest guidelines and are to be avoided. The EPC's opinion is that the arrangement, as described above, still places the audiologist in the position of a conflict of interest, as the trips, cash rebates, etc., would be obtained based upon a certain volume of hearing aids purchased. A patient could question whether hearing aids were recommended based on an actual hearing health care need or on a "reward" offered by the buying group. An incentive program that reduces the cost of hearing aids based on the number purchased, or "volume discounts," is acceptable as the patient may benefit from lowered costs.
Audiologists should be aware that accepting incentives, which in effect creates billing statements that do not reflect the true cost of the instruments, may be illegal if reimbursement is based on that invoice. Further, accepting gifts or incentives associated with dispensing any instrument paid for by a government program is illegal, even if the audiologist is only billing the government for diagnostic services.
In as much as the Academy published the comprehensive guideline, American Academy of Audiology Ethical Practice Guideline for Relationships with Industry for Audiologists Providing Clinical Care, which was first written July 28, 2011, revised in 2013, and approved by the Board of Directors January 14, 2014, along with accompanying FAQs, and in as much as buying groups are deemed a part of industry, questions regarding relationships with buying groups are also referred to the 2014 Board-approved guideline and FAQs.