Vendor Compliance

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.