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
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