Vendor Compliance

I saw this on Social Customer Manifesto and thought it should be read and digested by more people.  I feel this way when buying things and I am sure that I am not alone.  

• I want to have a say.
• I don’t want to do business with idiots.
• I want to know when something is wrong, and what you’re going to do to fix it.
• I want to help shape things that I’ll find useful.
• I want to connect with others who are working on similar problems.
• I don’t want to be called by another salesperson. Ever. (Unless they have something useful. Then I want it yesterday.)
• I want to buy things on my schedule, not yours. I don’t care if it’s the end of your quarter.
• I want to know your selling process.
• I want to tell you when you’re screwing up. Conversely, I’m happy to tell you the things that you are doing well. I may even tell you what your competitors are doing.
• I want to do business with companies that act in a transparent and ethical manner.
• I want to know what’s next. We’re in partnership…where should we go?

- Andy Monin

There is a lot of great information and mis-information floating around the blogosphere.  I want to point out a few valuable resources that I read almost daily….especially if you are in the Procurement / Materials Management / Sourcing profession. 

For those of you that have not visited Michael Lamoureux’s blog, Sourcing Innovation,  I highly encourage you to bookmark this site and visit often.   The topics range from spend visibility, risk mitigation, and best practices.  I spoke with him a couple of weeks ago and he posted a summary of our conversation, Vendormate-great-fit-less-fraud, in his blog this week.  He recognizes Vendor Compliance as a viable risk component of the supply chain that must be dealt with.  I enjoyed our conversation and will continue to read his posts.

In addition, I have spoken with Jason Busch in the past and continue to read his blog, Spend Matters .  He and Tim Minihans’, Supply Excellence , have a healthy, ongoing philosophical debate which has been fun to watch.   They all have incredible experience and insight into this space.   These 3 blogs all have a large readership and they post frequently on a wide array of topics and issues.   I hope this is helpful and  I look forward to jumping into the mix with these guys as we continue to carry the flag for Vendor Compliance.

-Andy Monin

NO POSITION IS ABOVE REPROACH

Trust comes from experience and demonstrating character over time.  As a society we are easily duped by those who carry titles of high position and esteem.  We are shocked with headlines of crooked cops, pedophiles priests, and unethical CEO’s that steal from their company. 

Compliance Officer Accused of Vendor Fraud

As reported by Debra Barayuga at the Star Bulletin, a former Queen’s Medical Center administrator responsible for ensuring compliance with the law is accused of steering more than $300,000 in hospital money to companies she owned for consulting work that was never performed.

According to an FBI affidavit, Patricia M. Syling worked as Queen’s corporate compliance administrator from January 2001 to October 2004. Her duties included overseeing collection activities by Queen’s from various private health-care insurers and government agencies.

She also had authority to “solicit and negotiate” vendor and service contracts that were then executed by the hospital’s chief operating officer, the complaint said.
Syling allegedly failed to disclose to her employer before the contracts were executed that the companies that received the consulting contracts — HealthCare Financial & Compliance Management and HealthCare Financial Group — were owned and operated by her from her residence.

It is not enough to hire someone as a Compliance Officer, write a Business Code of Conduct policy and call it a day.  To truly mitigate risk you need an objective, sustainable vendor program that requires all vendors to disclose and report all critical information like conflicts of interest, financials, licenses, certificates, and insurance.  By capturing standard business information, several red flags would have been raised in this case.  But even if this fraud was more sophisticated, credentialing of self-reported vendor data would have also uncovered issues.

Andy Monin

Have you ever noticed how many movies use the “vendor imposter” shtick as the “bad guys” default means of getting unfettered access to a facility with the intent of committing a crime?  They dress up as member of the cleaning crew, a delivery man, a door to door salesman, a waiter, a telephone, TV, or air conditioning repairman.  

Here are a few examples:  In Ocean’s Eleven, Matt Damon imposes as a Nevada Gaming Commissioner to distract Andy Garcia while Damon’s partners in crime shake down the Bellagio.  In Wallstreet, Charlie Sheen buys an ownership stake in a cleaning company to get late night access to files and sensitive information to help influence stock trades.  In Catch Me if You Can, Leo Dicaprio walked off with more than $2.5 million dollars impersonating a doctor, an airline pilot, and a prosecuting attorney.  I think IMdB’s movie description of the 1960’s comedy, The Great Impostor, starring Tony Curtis sums it up best….
“a bright young man who hasn’t the patience for the normal way of advancement finds that people rarely question you if your papers are in order. He becomes a marine, a monk, a surgeon onboard a Canadian Warship, and a prison warden.” 

I imagine that it would be pretty difficult to get counterfeit credentials that would allow you to board a Canadian Warship these days?  However, what is known about the hundreds of vendors, suppliers and contractors that are roaming our hospital halls every day?  Have these individuals presented their credentials?  Has their employer done background checks on them?  It is dangerous to assume anything these days.    How many of these vendors, suppliers and contractors have been screened against terrorist and sexual predator watch lists?  Are there former, banned/disgruntled employees that wish to cause harm to the hospital or staff members? 

In Fletch, Chevy Chase dressed as a doctor to get all of Alan Stanwyck’s home address and contact information from his patient records in a file drawer.   I wonder if the hospital’s security breach would be considered to be a HIPAA violation?

- Andy Monin

Today’s post will be a quick hitter.   

The State of Illinois passed the Gift Ban Act in 2003. This legislation prohibits state of Illinois employees from receiving gifts from vendors, lobbyists, service providers etc.

I recently came across an interesting article from the American Medical News, More states considering gift disclosure legislation.  More than 15 gift disclosure bills were filed in 2006!  Some were more strict than others. In Massachusetts, the bill would ban all gifts to physicians. 

In my opinion, this flood of legislative activity clearly indicates a public outcry for greater transparency and “above board” business dealings in the healthcare system.

-Andy Monin