Conflict of Interest Form Automation

Problem

Every year, the employee experience team had to process approximately 5,000 conflict of interest disclosure forms. Each form required manual review—reading the submission, cross-referencing it against policy criteria, determining whether it needed further investigation, and routing it appropriately. The process consumed months of the team's capacity annually, pulling them away from higher-value work. Most of the forms followed predictable patterns and could be resolved with consistent logic, but the manual process treated every submission identically regardless of complexity.

Constraints

• Conflict of interest reviews are a legal and compliance requirement—automation could not compromise the integrity of the review
• The business needed a full audit trail showing how every form was dispositioned
• Edge cases and genuinely complex disclosures still required human judgment
• The existing process was deeply ingrained; the team needed to trust the automated logic before relying on it
• Integration with existing HR systems was required to pull employee context (role, department, prior disclosures)

Approach

1. Analyzed historical submissions — Reviewed several years of COI forms to identify patterns, categorize the types of disclosures, and determine which categories could be safely auto-resolved based on consistent criteria
2. Defined the rules engine — Working with legal and compliance, codified the decision logic for auto-resolution: which disclosure types, combined with which employee attributes, could be approved without human review
3. Built the automated workflow — Implemented the rules engine in ServiceNow, pulling employee context from Workday to enrich each submission. Forms matching auto-resolution criteria were processed immediately with a documented rationale; everything else was routed to a human reviewer with relevant context pre-loaded
4. Created the exception queue — Designed a streamlined review interface for the forms that did require human judgment, pre-populating relevant employee history, prior disclosures, and the specific policy provisions at issue
5. Implemented audit logging — Every form—whether auto-resolved or manually reviewed—generated a complete audit record: the decision, the rationale, the criteria applied, and the timestamp
6. Piloted with parallel processing — Ran the automated system alongside the manual process for one cycle to validate that auto-resolution decisions matched what human reviewers would have decided

Outcome

• Volume reduction: 5,000 annual forms requiring manual review reduced to approximately 400 that genuinely needed human judgment
• Time savings: A process that consumed months of team capacity now completes in hours for the automated portion
• Consistency: Auto-resolved forms are dispositioned with consistent logic rather than varying reviewer interpretation
• Audit confidence: Every form has a complete, documented decision trail regardless of how it was processed
• Team impact: The employee experience team reclaimed the vast majority of their time previously spent on COI processing

What I'd Do Next

• Extend the rules engine to other annual compliance processes that follow similar patterns
• Add a self-service portal where employees can check the status of their disclosure in real time
• Build analytics to identify trends in disclosure types that could inform policy updates