Archive for August, 2008
“Publicly Available” Is Not the Same as “Free”
The IMDA has issued its recommendations on vendor credentialing in healthcare. There is a lot of interesting content in it that reflects the importance of this dialogue.
While we wish IMDA had responded to our contacts by both voicemail and email to participate in its June panel on credentialing that preceded these conclusions, they did not. So over the next few weeks we’ll just put a few thoughts out for consideration via the blog.
For today, let’s start with the idea that “public information” such as the OIG List of Excluded Individuals and Entities is, in fact, “free.” True, anyone with internet access can look for HHS/OIG alerts about a company or an individual.
After all it’s online, and internet bandwidth is “free” right? (Insert line item of healthcare system telecommunications data invoice here.) But for the sake of argument, we’ll ignore that expense because the healthcare provider was paying for internet access anyway, right? And once they blocked insiders from playing “Halo,” they had all the bandwidth they needed.
So where does the cost come in? I’m unaware of any healthcare materials management department that is staffed by volunteers. And if volunteers aren’t doing this, then someone must be paid to take the “free” route of doing this one-by-one using the one-entry-at-a-time search capability. How much can that cost? Say it only takes one minute to pull a vendor record from the AP system, enter it into the OIG HHS application, press search, read the output, and record the results. 2300 vendor companies @ 1 per minute equals 38.3 work hours. Nearly a full work week. Now go through the list again searching for individuals that come into patient contact.
Oh, and just because a vendor doesn’t appear in the HHS/OIG list doesn’t mean it’s clear from all of the state lists. Just last week, we highlighted the Associated Press’ research that 6 of 10 entries on state lists don’t appear on the HHS/OIG LEIE. So be prepared to do it another 50 or so times. That’s 51 weeks in labor terms. And then there is the GSA list….
Please, volunteer vendor credentialer, don’t take a vacation.
Don’t really have a volunteer headcount you can commit to this for nearly a full year? Perhaps the healthcare system could get a volunteer to program a batch processing application that can download the monthly updates and run that against its in-house vendor files. Either way, it’s going to cost — in staff hours, if not out-of-pocket dollars.
True, most, if not all, of IMDA’s members won’t appear on any of these lists just as I expect most, if not all, of the members won’t set off the alarms at airport security. But the screening needs to occur, nonetheless, and it’s not “free” no matter how you do it.
2 comments August 25, 2008
6 of 10 State Sanctions Missed in OIG LEIE
The Department of Health and Human Services Office of Inspector General (HHS OIG) List of Excluded Individuals and Entities (LEIE) is supposed to include a roll up of vendors and individuals with state level Medicaid sanctions as well as those marked by Federal sanctions. But a recent Associated Press article uncovers major gaps in reporting.
Investigators surveyed the states to find out how often their Medicaid programs sanction a provider in a way that would in the vast majority of cases merit a spot in the IG’s exclusion database. An astounding 61 percent of the 4,319 sanctions imposed by state Medicaid agencies in 2004 and 2005 could not be found in the federal database.
Hospitals, long-term care providers, any one dealing with Medicare/Medicaid reimbursement will want to verify that their current vendor credentialing processes check all states — from the state lists — as well as the OIG LEIE.
2 comments August 18, 2008
Helping Out With The Joint Commission Visit
Maine Medical Center has been live with its Vendormate-based vendor program for just 9 months. We recently received this note from its associate director of materials management.
“We had the JC here 2 weeks ago. In one of the O.R. tracers, they wanted to know about a vendor. The O.R. leader knew to call me. I went over and showed them Vendormate and what we had in the system for this vendor. We passed that with flying colors.”
Bob Barber
Associate Director, Materials Management
Maine Medical Center
It’s an example of what Laura Smith, associate project director for the Joint Commission’s division of standards and survey methods, said at an IMDA conference recently. The Joint Commission standards relating to vendors are focusing on patient safety.
After all, where do patients and vendor representatives come closer to each than the O.R.?
Add comment August 12, 2008
CMS Clarifies State Vendor Check Requirements
In case you haven’t seen it yet, The Centers for Medicare & Medicaid Services (CMS) issued a letter to state Medicaid director clarifying the requirements for vendor checks prior to receiving payments. While you may not be a state Medicaid director, if you’re planning to process payments through your state’s Medicaid office, you’ll want to know what they are looking for.
Highlights from the letter:
Frequency of Checks
States are guided to review eligibility at enrollment or re-enrollment as well as monthly. The monthly checks are to identify reinstatements as well as new exclusions.
Who to Check
States are reminded that they must look at out-of-State as well as in-State providers.
Comprehensive Disclosure of Ownership
Because payments to a provider that has an excluded individual as owner (5% or greater) or a managing executive are prohibited, States should be wary of incomplete disclosure information and should not process payments from that company without further research.
You can read the letter yourself here.
1 comment August 5, 2008
