Vendor Management September 7 th 2007 James Mahan, Vice President Yankee Alliance

Objectives At the end of the program you should Understand the basics of; What is Vendor Compliance? Who does it affect? Where does it originate? Why is it an important? How does it affect me?

Pieces of the Program Credentialing ‘ the administrative process for validating the qualifications of professionals and assessing their background. Certification recognize as having met special qualifications Compliance Adhering to the elements of the program

Why is this so Important? People impacted; Patient Board of Directors C-Suite ( CEO, COO, CFO) Providers, Pharmacists Support personnel Business Partners

Focus Areas Areas of significant impact; Patient Safety Clinical Care Quality Accreditation Financial Public Relations

There is no one entity that is driving this overall initiative. In my opinion it is a culmination of many different oversight efforts.

Drivers! Highest Level: Federal State Accrediting Bodies Oversight Insurers

Federal HIPAA - Health Insurance Portability Accountability OIG – Office of Inspector General MMA – Medicare Modernization Act DRA – Deficit Reduction Act 2005 CMS – Medicare and Medicaid Services –Conditions of Participation –Interpretive Guidelines

State Medicaid Homeland Security (State Preparedness) DPH – Department of Public Health General laws – Consumer Protection

Accreditation and Guidelines The Joint Commission ( JCAHO) NCQA – National Commission, Quality Assurance OIG – Hospital Compliance CDC – Center for Disease Control AORN- Association of OR Nurses

JOINT COMMISSION The issue of vendor compliance is reflected In their Standards and Elements of Participation; Human Resources Stds. Environment of Care Stds. Leadership Stds. To name a few areas where you will find language applicable to vendor management.

JCAHO HR 1.20 Ensure qualifications are consistent with responsibilities. “Organizations must manage contract personnel just as they must manage services and personnel that are provided by direct employees” ( FAQ on HR Stds.)

GOVERNANCE Corporate Responsibility The Governing Board member may be expected to exercise general supervision and oversight of quality of care and patient Safety issues. excerpted from (AHLA Annual Meeting June 25-27, 2007 “Corporate Responsibility and Health Care Quality – A Resource for Board of Directors – A Callender et.al.

There are many reasons to have a vendor management program from an infection control perspective; Pandemic Plan for Hospitals from CDC “ A Plan has been developed for facility access during a pandemic…” Can you tell me who is in your hospital right now?

Deficit Reduction Act of requires any entity, such as a hospital, that receives greater than $5,000,000 per year in Medicaid funds to implement a False Claims Education Policy. The policy must include detailed information about the False Claims Act and refer to or describe the hospital’s procedures for detecting and preventing waste, fraud and abuse. The policy was required to be in effect on January 1, 2007

Applicability What many providers may not realize is that the policy applies not only to the provider’s employees, but also to any contractors or agents of the hospital. A contractor or agent is any person who furnishes Medicaid health care items or services, performs billing or coding functions, or is involved in monitoring of health care provided by the hospital on behalf of the hospital. This is a broad definition and could include consultants, vendors, and other entities providing services to or for your hospital.

Health Law Alerts – August 2006 (excerpted) In certain cases, contractors, such as supply vendors, may receive hundreds of policies from various hospitals, which may pose a practical challenge for the contractors’ compliance. In case CMS decides to verify the hospital’s compliance, we recommend documenting the hospital’s efforts to notify its contractors of its policy.

Knowledge Standard This standard imposes on a provider to be fully aware of the status of billing, claims…..and the providers with whom they employ contract and or affiliate. In other words you can’t play dumb if you should or could have known.

Balancing the Forces: Lawyers and Risk Managers – Protect Assets! Administration Efficiently Utilizes Assets!

Caught in the Middle! Document!

Thank you! Questions?