What's in this template?
This Conflict of Interest, Gifts and Benefits Policy gives Australian medical practices a complete governance policy aligned to AHPRA Good Medical Practice / Code of Conduct, the Medicines Australia Code of Conduct, and RACGP Standards 5th edition governance expectations. Conflicts of interest, real or perceived, can undermine the patient's trust, this policy makes sure they are recognised, declared and managed transparently.
The policy covers 16 sections plus a sign-off block:
- Purpose: patient trust and governance
- Definitions: actual, potential, perceived COI; gift; benefit; inducement
- Scope: all clinicians, staff, contractors, owners
- Common conflict situations in general practice: financial interest, family, suppliers, pharma
- The three-step principle: DISCLOSE, DOCUMENT, MANAGE
- Gifts, the rules: patients, suppliers, pharma, administrative staff
- Specific high-risk areas: prescribing, referrals, procurement
- Roles and responsibilities: staff, Declarations Officer, Clinical Lead, Practice Manager, owners
- Declaration and review cycle: initial, annual, continuous, project-specific
- Gift register fields
- Conflict of interest register fields
- Breach and consequences: investigation, AHPRA mandatory notification consideration
- Patient communication: disclosure to patient when relevant to care
- Training: induction, annual, scenario discussions
- Related documents
- Approval and review
Editable placeholder fields
{{practice_name}},{{practice_address}}{{clinical_lead}},{{practice_manager}},{{declarations_officer}}{{gift_threshold}}, set by practice owners (typical: $50 or $100; some practices set $0)- Sign-off blocks for Clinical Lead, Practice Manager and Declarations Officer
Who needs a Conflict of Interest, Gifts and Benefits Policy?
Every Australian medical and allied health practice. Governance documents are scrutinised at RACGP accreditation, and any AHPRA conduct notification will look for documented practice expectations on COI and gifts. The template is suitable for:
- General practices: solo, group, corporate
- Specialist medical practices
- Day procedure clinics
- Allied health practices
- NDIS providers: governance documentation is also required by NDIS Practice Standards
- Aboriginal Community Controlled Health Services (ACCHOs)
Why a combined COI + Gifts policy
The cannibalisation audit identified that COI and gifts/benefits address the same governance audience and the same set of risks. Splitting them into two policies created two thin overlapping documents. Combining them gives a complete governance picture in one place, disclosure, registers, gift thresholds, prescribing, referrals, breach, all consistent with each other.
The three-step principle
| Step | What it means |
|---|---|
| DISCLOSE | Declare the interest in writing to the Declarations Officer on commencement and whenever a new interest arises |
| DOCUMENT | Record in the Conflict of Interest Register |
| MANAGE | Agreed action, recuse from the decision, transparent disclosure to patient/colleague, or in some cases divest the interest |
Disclosure alone is not management. The practice decides what action is needed.
High-risk areas built in
The policy covers the specific scenarios that come up in Australian general practice:
- Financial interest in a service the practice refers to: pathology, imaging, allied health, day procedure, pharmacy
- Family members as patients: particularly Schedule 8 prescribing where State Drugs and Poisons Acts apply
- Pharma sponsorship: under the Medicines Australia Code of Conduct
- Honoraria, speaking fees, advisory boards: accepted only with declaration
- Sponsored travel: generally declined other than for limited educational purposes
- Practice procurement: software, pathology, equipment, contractor selection
- Bequests in patient wills: clinician declines if any suggestion of influence
How to customise this template
- Download the Word document and replace every
{{placeholder}}with your details - Set the gift threshold: owners decide. Template defaults to
{{gift_threshold}}. Common choices: $50, $100, or $0 (no gifts of any value) - Nominate a Declarations Officer: usually the Practice Manager or a senior clinician; maintains both registers
- Set up the registers: most practices use simple spreadsheets reviewed at the quarterly governance meeting
- Schedule induction COI declarations: for every new starter on Day 1
- Schedule the annual refresh: every financial year, every staff member updates their declaration
- Decide pharma engagement: clarify the practice position on lunch-and-learn, conference sponsorship, and honoraria
- Brief clinicians on prescribing for family and friends: AHPRA's clear position that this should be avoided except in emergencies
- Train the team in scenarios: bring realistic examples to team meetings and discuss how the policy applies
Related templates and tools
The COI and Gifts Policy is the governance umbrella for related documents:
- Privacy Policy: confidentiality framework when registering interests
- Complaints Handling Policy: complaints alleging conflict are routed here
- Open Disclosure Policy: when a conflict has caused harm
- Quality Improvement Policy and Activity Log: governance audit feeds QI
- Policy and Document Control Procedure: versioning of all governance documents
- Staff Confidentiality and Privacy Agreement: sister obligation
- Workplace Bullying and Harassment Policy: overlaps for any harassment based on declining a gift or interest
- Position Description Template: COI obligations referenced in every PD
Frequently asked questions
What is a conflict of interest?
A situation where a personal, financial, family or other interest could influence, or appear to influence, a clinical or business decision. The policy distinguishes actual, potential and perceived conflicts. All three are declared.
Can patients give gifts to clinicians?
Personal token gifts (homemade baking, flowers, a card) may be accepted with grace and recorded in the register if above the threshold. Higher-value gifts are politely declined or referred to the practice. Cash gifts from patients are not accepted in any amount. Gifts intended to influence clinical decision-making are declined.
What about bequests in patient wills?
AHPRA guidance is clear: clinicians should decline bequests where there is any suggestion of influence on care. The policy recommends seeking guidance from the medical indemnity insurer for any bequest. This is one of the highest-risk gift scenarios and is treated specifically in section 6.
Can we accept pharma sponsorship?
Within the Medicines Australia Code of Conduct. Branded merchandise of nominal value is acceptable; gifts of meaningful monetary value are not. Educational events sponsored by pharma may be attended where the content is independent and prescribing is not influenced. Honoraria, speaking fees and advisory board fees may be accepted only with disclosure in the COI register. Sponsored travel is generally declined other than for limited educational purposes.
What about prescribing for family and friends?
AHPRA notes that prescribing for family and friends is not best practice and should be avoided except in emergencies. Schedule 8 prescribing for family members and self-prescribing is governed by State Drugs and Poisons Acts, generally prohibited or tightly restricted. The policy reflects this in section 7.
When do we have to disclose a conflict to the patient?
When the conflict is relevant to the patient's care or choice, for example, referring to a service the clinician has a financial interest in. The disclosure is in plain language, alternatives are offered, and the disclosure is documented in the clinical record. The policy covers this in section 13.
What happens after a breach?
The Declarations Officer or Clinical Lead investigates. Action ranges from counselling and policy retraining, through written warning, to termination of employment depending on severity. Notifiable conduct under AHPRA National Law is reported per the Mandatory Notifications Guidelines. Significant breaches may also trigger reporting to Medicare, the ATO, or the relevant State health complaints commission. Medical indemnity may need notification, seek advice early.
Is this part of RACGP accreditation?
RACGP Standards 5th edition include governance indicators. A documented COI and Gifts policy is part of the governance evidence. Surveyors will ask about it as part of the governance and quality improvement modules.
Will accreditors and AHPRA accept this template?
Yes, when populated and active. The policy aligns with AHPRA Good Medical Practice, the Medicines Australia Code of Conduct, and RACGP governance expectations. The three-step principle, the registers, the prescribing and referral guardrails, and the breach pathway are what any reasonable reviewer expects to see.