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Vendor Management

Vendor Management. Troy Kyle President / CEO Vendor Credentialing Service troykyle@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.

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Vendor Management

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  1. Vendor Management Troy Kyle President / CEO Vendor Credentialing Service troykyle@vcsdatabase.com

  2. 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

  3. 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

  4. 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

  5. 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

  6. 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

  7. 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

  8. Req’s Continued • The Joint Commission (TJC) – Does not currently directly address vendors who are not contracted by a healthcare organization. • Security / Patient Safety • TB 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

  9. 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.

  10. 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

  11. Risk reduction • Access Controls • Cold Calling • Appointment setting • Medical mistakes due to interruptions http://confidenceconnected.com/connect/article/reducing_interruptions_and_errors/

  12. 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

  13. Choices Develop your own system Use a service • 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

  14. Questions?

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