1099s Required for $600 Business Purchases
Inside the healthcare reform legislation is a small drop of language that is causing a big storm. The language — Section 9006 — requires reporting to the IRS via 1099s any transaction valued at $600 or more. Previously, the only requirement was to report wages, not goods.
Excerpt from Patient Protection Affordable Care Act
This change has the potential to be a documentation nightmare. The cumulative value of just about any good a business procures is typically over $600. Because of this, there is already a growing grass-roots movement to modify, if not repeal, this provision.
Businesses know how difficult it is to the get the right information for creating 1099s — legal business names and addresses, tax id numbers, etc. If this rule applies to you, now is the time to start collecting the W9s that you need to meet the requirement. Make it part of your contract renewal process this year, and you’ll be in good shape for next year. Your vendor management system is a good place to house this information.
And, for the silver lining perspective, you might enjoy what Marianne Couch, a principal with the Cokala Tax Group in Michigan, had to say in a CNN Money article. That this might actually make some record keeping easier. ”The new rule is simpler: If it crosses the $600 threshold, it’s in.”
Add comment August 30, 2010
Joint Commission Lists Most Challenging Standards of 2010
The August Joint Commission Newsletter online presents the 5 Most Non-compliant Standards from the first half of 2010.
For Hospitals it was:
62% — RC.01.01.01 — Maintains complete and accurate medical records for each patient
50% — LS.02.01.20 — Maintains the integrity of the means of egress
44% — LS.02.01.10 — Building and fire protection features are designed and maintained to minimize the effects of fire, smoke, and heat.
38% — ED.02.03.05 — Maintains fire safety equipment and fire safety building features
37% — LS.02.01.20 — Provides and maintains building features to protect individuals from the hazards of fire and smoke.
It’s interesting that fire and physical safety issues outpace any direct care concerns. Do you read this to say that US hospitals generally meet their primary goal — patient care? And with that in place, they can also address the less-likely risks to patients?
Add comment August 19, 2010
It’s Not the Economy, It’s the Relationship
Jason Busch, over at Spend Matters, covers a lot ground in discussing spend management, but he consistently comes back to one theme.
Behind all the processes, data, software, analysis, there is a relationship that needs to be actively nurtured. Nurturing that relationship is never more important than during economic turmoil. He’s starting a series of posts about managing the supplier relationship to reduce risk, drive quality, and decrease total cost that I’m sure will be interesting.
Certainly in healthcare, requirements for vendor credentialing and for access management can be implemented in a punitive way, as a check box formality, or as part of a healthy relationship. In Dr. Phil terms, healthy relationships have clear communication about boundaries and expectations so that neither partner is surprised. Vendor credential programs work best as just one piece of clear communication in a collaborative relationship.
Add comment July 28, 2010
Medicare Scam Prosecutions Stepped Up
By now you’ve seen the headline, 36 Arrested in Medicare Scams Totaling $251 Million. With 94 suspects indicted and 36 arrested, the perpetrators include clinic owners, medical staff, patients, and more.
Whether or not something occurred at a hospital, the prospect of dealing with an investigation is enough to spur action. The Affordable Care Act gives federal officials to authority to stop paying a provider suspected of fraud, a significant change from the pay first, investigate later position of the past.
The vast majority of vendors and hospitals behave responsibly. But in a stepped up enforcement environment like this, neither side wants to be caught in the middle. A solid vendor compliance program integrates internal and external requirements — from managing the CMS’ monthly sanction list checks to conflict of interest disclosures to linking the individual serving the account to the employer — and protects both the buyer and seller.
Add comment July 19, 2010
Monthly Screening Requirement Alert
Vendormate account managers are often asked about how frequently sanction checks need to be performed. Our response of “monthly” is based on the frequency with which the lists are updated and statements from CMS.
A recent legal alert from Garfunkel Wild, P.C. highlighted a reminder from the New York State Office of the Medicaid Inspector General “that all employees, vendors and referral sources should be checked upon hire (if applicable) and then on a monthly basis, at a minimum…” against state and federal disqualification or exclusion lists.
You can also read it directly in the New York State Medicaid Update April 2010, Vol. 26 # 6.
This requirement isn’t new, but the momentum continues. We first noted this in August, 2008. One year later, we posted a list of states that had reinforced the same message. Apparently, the list continues to grow.
Add comment June 11, 2010
There’s Nothing Accidental About Data Security
You’ve probably heard about Google’s accidental data harvesting issue. Apparently, the special cars it uses to collect online mapping information were also getting data from unsecured WiFi networks. I’ll say Google seems to be making all the right responses. Alerting government agencies. Cooperating with investigators.
Still an event like this makes you want to review data privacy practices at even the most mundane sites. Tim Paulus, a director of development here at Vendormate, recently recapped the safeguards in place at Vendormate.
Here’s what Tim had to say:
Vendormate partners with SunGard Availability Services for datacenter space, disaster recovery services and managed IT services. SunGard facilities have 24/7 on-site, dedicated security. They employ four layers of physical security including biometric controls that withstand the stringent HIPPA, ISO and SAS-70 Type II audits.
Each Vendormate user is assigned a unique user name and password that must be entered at each login. Passwords are stored in an encrypted form and cannot be retrieved by anyone, including Vendormate staff! That’s right, while we can reset a password to a new value, we cannot retrieve an existing one. After authenticating, the user identity accompanies each and every request to strictly enforce segregation of customer data.
Payment details have additional safeguards. All credit card data are protected via Secure Socket Layer (256 bit SSL) encryption. Payment details are transferred to our payment provider using the same SSL encryption technique immediately upon receipt. Credit card numbers are NEVER stored in the Vendormate database.
So Vendormate users can be confident that state-of-the-art data measures are in place to keep their data safe and secure.
Add comment June 4, 2010
Survey: Healthcare Compliance and the Board Level
The Society of Corporate Compliance and Ethics and the Health Care Compliance Association recently released the results of a survey of compliance and ethics professionals in their database.
Their conclusions:
Despite all the efforts to promote better governance, it does not appear that there is yet a fully developed connection between governance and compliance.
A stint in survey research early in my career makes me question the representativeness of their sample, so let’s think of this as qualitative research that indicates themes and directions and go from there. (And more importantly, ethical behavior isn’t based on percentages. It’s based on a value judgement.) Still their conclusion is meaningful.
Regardless of the organizational behaviors of others, the question to ask yourself is, “How does my organization address its compliance and ethics management? Does my compliance function actually affect the governance decisions?”
Too often compliance is seen in the organization as something to be endured. For example, I worked for the company that went bankrupt from what was (at the time) the world’s largest corporate fraud. In the aftermath, the bankruptcy court decided every employee needed to take ethics training. “Why us?” my colleagues and I grumbled, “We didn’t lie about anything.” The training focused on legal standards and definitions. But it left a gap. The gap was that it didn’t tell us what to do when we found something irregular and how the company would respond.
Take a look at the survey (a free registration is required to see the full results), and think how your organization would answer the questions. In the end, don’t assess yourself by whether you’re company is doing what everyone else is. Whether you’re “average” or “above average.”
Regardless of your organizational structure. Regardless of who reports to whom. Do you have a compliance function that can actually affect behavior? Do your employees know the route to resolution? If you don’t, then you know what you need to work on.
Add comment May 21, 2010
Repertoire Magazine: Suppliers Using Vendor Data Constructively
An interesting feature from Repertoire magazine about how healthcare suppliers are using the vendor credential suppliers’ data to gain insight into their own reps behavior.
Vendormate’s “Administrator dashboard,” for example, allows the administrator to quickly see which of the company’s reps have met all their customers’ credentialing requirements, and which have not. Regarding the latter, the dashboard shows the administrator what actions need to be taken to ensure that they fall into compliance with all their customers’ requirements. What’s more, the dashboard includes a “robust directory,” which allows administrators to review each of their customers’ policies, says Hayes. … “That’s definitely a section of great interest.”
We talked about this phenomenon earlier this year in the post, 2010 Predictions: From Vendor Acceptance to Vendor Advantage. But that is still secondary to meeting their customers’ requirements.
“Vendors’ first concern is, ‘Are we compliant?’” adds John Harper, Vendormate’s vice president of marketing. “Using this as a sales management or performance management tool is down the list. It’s not necessarily the No. 1 question we’re getting, but one we’re expecting will start coming up.”
If this is an area of interest to you, Vendormate’s Vendor Services team can describe the options in more detail — vendorservices@vendormate.com. (If you’ve got a technical question, go to our Support Center.)
Add comment May 12, 2010
Three Things Every Hospital Vendor Badge Should Have
Vendormate has been printing badges for sales representatives for several years now. In fact, we recently printed our 1,000,000th badge. One million badges and 850 customers later, we heard pretty consistently what a hospital wants from a badge.
Easier-to-read Vendormate Badge
1. Show Where the Wearer Is Going and Why (Don’t Make Me Ask) — Hospital staff are busy. Stopping to ask every person “do you belong here?” just isn’t feasible. The badge should make it clear where the wearer belongs.
Some hospitals do this by the color of the badge. But our hospital customers have been clear that where they want a vendor representative to have access depends on the nature of that day’s business. If it’s a sales call, then there is no need for the vendor to be cleared for clinical areas. If it’s a consult, then by all means give the rep access. The badge should show the purpose of the visit and where the meeting is occurring.
2. Let Me Know When (And What) Exceptions Are Made — Sometimes the hospital staff needs flexibility. Maybe today is the day that a sales manager is making a one-time visit and all her paperwork isn’t on file. In this case, the risk management value of thoroughness doesn’t necessarily outweigh the timeliness of this visit. So an authorized person at the hospital makes an exception. But it should be clearly noted on the badge so that the rest of the staff is aware.
3. Be Current — Things change. Documents expire. New policies are implemented. One of the best ways to be confident that visiting reps are current is when the badge has today’s date.
Vendormate has taken all this feedback from hospitals and introduced a new badge design. The Vendormate badge meets these requirements with larger font for day and date, more room to display specific departments, facilities, and reasons for a visit, plus a bold header highlighting any compliance issues.
Add comment May 6, 2010
Vendormate In Top 20 Fastest Growing Atlanta Companies
Atlanta Business Chronicle announced the 50 fastest growing companies in the Atlanta metro region this morning at its 2010 Pacesetters event. We’re excited to announce that Vendormate is in the top 20 again.
Thanks to all the hospitals, vendors, and banks we serve for helping us achieve this. We’re committed to continuing to grow by developing more services to support you.
Add comment April 23, 2010
