VENDOR MANAGEMENT

Troy Kyle

President / CEOVendor Credentialing Servicetroykyle@vcsdatabase.com

OBJECTIVES

Government Watch List (what they are, laws, and enforcement actions)

HIPAA, how it affects facilities from a vendor perspective, BAA’s, etc.

Immunization testing, what is required, CDC and OSHA regulations

Training requirements, Bloodborne Pathogens and OSHA rules and regulations

Access Controls

VENDOR CREDENTIALING?

Definitions: The process of obtaining and reviewing the

documentation (licensure, certifications, insurance, etc.) of health professionals. Generally, this includes reviewing information given by the professional and verifying that the information is correct and complete.missourifamilies.org/features/healtharticles/health40.htm

REQUIREMENTS

What are Government Watch List? OIG/GSA Government Exclusions:

The OIG, under this Congressional mandate, established a program to exclude individuals and entities affected by these various legal authorities, contained in sections 1128  and 1156  of the Social Security Act 

“Follow the Money” Principle Checked through the EPLS and LEIE (federal),

and State OIG websites

http://oig.hhs.gov/fraud/docs/alertsandbulletins/effected.htm

PENALTIES

CMP’s or Civil Monetary Penalties OIG's CMPs are in the Civil Monetary Penalties

Law ("CMPL"), 42 U.S.C. § 1320a-7a Corporate Integrity Agreements

Typical term is 5 years http://oig.hhs.gov/fraud/cia/cia_list.asp Tenet Health, Zimmer, Walgreen’s

Have reimbursements withheld Become an Excluded Entity

OTHER REQ’S

OSHA – “Since your company maintains a continuing relationship with its employees, but another employer (your client, a healthcare facility) creates and controls the hazard, there is a shared responsibility for assuring that your employees are protected from workplace hazards.” “The client, of course, may specify what

qualifications are required for supplied personnel, including vaccination status.”

Bloodborne Pathogens training

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21010

REQ’S CONTINUED CDC – Immunizations for people who work in

a health-care facility include MMR, Varicella, HBV, TB (schedule of immunizations) Schedule for health care workers

HHS – HIPAA regulations with considerable interest in incidental disclosure. Enforced by the OCR (Office of Civil Rights) BAA’s Social Networking / Media

REQ’S CONTINUED

The Joint Commission (TJC) – Does not currently directly address vendors who are not contracted by a healthcare organization. Security / Patient SafetyTB Test #1 check

AORN - Health care industry representatives may function in any of several positions (e.g., clinical consultants, sales representatives, technicians, or repair/maintenance personnel).OR Procedure Room Protocol

REQ’S CONTINUED

ACS – The purpose of this statement is to supply guidelines to health care facilities and members of the perioperative health care team to ensure an optimal surgical outcome, as well as the patient's safety, right to privacy, and confidentiality when a HCIR is present during a surgical procedure. OR Procedure Room Protocol General Expectations and Hospital Safety Training The patient should be informed of the presence

and purpose of the HCIR in the OR and give written, informed consent. This should be documented within the medical records.

WHAT DOES IT MEAN TO HEALTHCARE?

Vendor Management = Risk Management Managing Risk to patients

healthcare-associated infections account for an estimated 1.7 million infections and 99,000 associated deaths each year

13,779 TB cases (a rate of 4.6 cases per 100,000 persons) were reported in the United States in 2006.

Patient Privacy and Patient Rights Security of the hospital and hospital property Managing Conflict of Interest Cost controls with proper device and

medication approval processes

RISK REDUCTION

Access Controls Cold Calling Appointment setting Medical mistakes due to interruptions

Without Interruption

With Interruption

Procedural failure rate

69.6%84.6% (with three interruptions)

Clincal error (at least one)

25.3%38.9% (with three interruptions)

Estimated risk of major error

2.3%4.7% (with four interruptions)

http://confidenceconnected.com/connect/article/reducing_interruptions_and_errors/

CHALLENGES FACING A FACILITY

Vendor Company Financials

Bankruptcies Liens Judgments

Legal Standing Involved with Anti-

Kickback Legislation Liability Insurance HUB’s Conflict of Interest

Vendor Representatives Immunizations

MMR TB Varicella Influenza

Cold Calling Background Check Conflict of Interest Contact Information Proper Trainning

CHOICES

Cost Human capital

Design the system Programming Manage the

information Development time Administer the

program Higher cost to

vendor community

Cost Normally at no or

little cost to you Administer the

program Lower cost to vendor

community

Develop your own system Use a service

QUESTIONS?