Archive for August, 2009
Getting the Word Out
I’ll suggest that the day-to-day reality of compliance management is more about actively communicating the sets of unacceptable behaviors rather than uncovering and punishing perpetrators. After all, the vast majority of people follow community standards of ethical behavior (except, perhaps, during rush hour). For this reason, it’s not surprising to see recommendations like this recent one from Supply Chain Management Review. An article discussing Gifts and Entertainment Policies best practices, includes this conclusion:
Finally, another best practice on this topic is to send an annual letter to suppliers, reminding them of the policy and expectations, alerting them to the consequences for failing to abide by the policy, and enclosing a summary of the policy for their guidance.
I appreciate the intention of clarity. Define your standards, and communicate them to all affected parties. But how do you do this, really? How many supply chain managers have the contact information for all the supplier reps who might be doing the entertaining? Sure you’ve got your contacts, but what about the other department heads’ contacts?
And then, what about your other policies that you want to communicate? Do you bundle this all into one extended message? Or do you piecemeal it over time? A “Message a Month”?
The recommendation also includes repetition. Not just at the start of the contract, but annually. Again, I agree. Reinforcement, reminders, and repetition are all keys to communication and learning.
Of course, I have my own point of view here. And it’s that Vendormate addresses this by having suppliers register on a buyer’s customized portal. The supplier, rather than the buyer, keeps the contact information current. This way the supplier is always informed of the buyer’s standards, just as the supplier stays current about the buyer’s product and service needs. The web-based portal provides 24/7 availability of all policies (old, new, and in-between) and serves as the central database of record for supplier and vendor contact information for email announcements of changing policies.
But not everyone is a Vendormate user, so, I’ll open this up for comment. What are your real world approaches to this communication recommendation?
1 comment August 25, 2009
States Reinforce CMS Exclusion Guidelines
In January, 2009, the Centers for Medicare & Medicate Services (CMS) released a State Medicaid Director Letter (SMDL #09-001) clarifying and reminding States of the requirements and consequences of payments to excluded individuals and entities.
Since then, states have been at work communicating the same requirements either under their own letterhead or by re-post. A quick scan of the internet shows communications from:
- Alabama
- Iowa
- Kentucky
- Louisiana
- Maryland
- Nebraska
- Nevada
- Oklahoma
- Rhode Island
- South Carolina
- Virginia
I’m sure there are more. But whether it was a reTweet from your state or you saw it directly from HHS, two key points remain:
Sets forth the Centers for Medicare & Medicaid Services’ (CMS) policy with respect to States’ responsibility to communicate to providers their obligation to screen employees and contractors for excluded individuals and entities both prior to hiring or contracting and on a periodic basis (emphasis added)
States should require providers to search the HHS-OIG website monthly (emphasis added) to capture exclusions and reinstatements that have occurred since the last search.
Add comment August 17, 2009
