Posts filed under ‘vendor compliance’
John Commins over at HealthLeaders recently wrote about the ever-rising focus on fraud in the healthcare. In his article, Culture of Compliance Preempts Whistleblower Suits, he makes the point that the potential gains to the whistleblower in a difficult economy could easily increase the number of whistleblower suits. He continues that creating a culture of compliance, with appropriate reporting pathways, is the best way to prevent these suits.
The aphorism is true: Prevention is the best medicine.
Cultures are typically created informally and unintentionally. Action by action. Decision by decision. Until there is a consistency in viewpoint and behavior. I’ll build on John’s recommendation that now is the time to conciously create a culture of compliance by adding that culture has to be applied consistently across staff, contractors, and vendors.
When I introduced this series of posts about how hospitals are auditing participation in vendor programs, I used the analogy of my son’s inability to effectively use an agenda to keep up with his homework. Just to keep beating that horse, let’s compare homework to the documents that buyers want from their vendors.
It continues to amaze my son that the completed homework he left on the kitchen table or in the bottom of his locker doesn’t count to his teachers. And for vendor reps, just as with homework, having the document isn’t enough. Unfortunately, it’s not enough to say, “I did it,” or “I’ve had that training.” It actually has to be turned in for credit. And that’s one of the key drivers for vendor programs in healthcare and banking — Document Management. Collecting. Storing. Tracking expirations.
I find out when my son has forgotten to turn in homework through the school’s “document audit website” — or as they call it, online student report. I log in, pull up his name, select a class, and review the assignments. At a glance, I can see any missing assignments.
Many of our customers turn to the Document Audit Report inside Vendormate VISION as the first step in their vendor program audits. The Document Audit Report allows customers to check the status of all their registered companies and registered reps against any or all the required documents. The status identifies completed, alert (about to expire) or missing/expired documents.
One of our customers recently changed its product trial program to protect itself from unexpected expenses. Any product brought in for trial now needs a no-charge purchase order. If not, the trial product is considered a donation.
Vendormate sent an alert out to all registered reps who might be affected by this type of policy. Homework analogy — everyone received the handout.
Three weeks later, a document audit report across all these same reps showed that 9 of 10 had acknowledged the new policy. Homework analogy — 9 of 10 in the class completed the assignment and turned it in.
For the remaining 1 in 10, I guess it’s detention. Not really, but reporting like this makes it easy for the hospital to identify and manage the remaining reps as exceptions. And for any of these people with a pattern of non-compliance, the consequences could be significant.
The point is vendor compliance is not once and done. Situations change. Staff changes. And your program has to adapt. Program audit techniques like this help you determine whether or not your program is achieving your goals
Last week, I promised that the next few posts would look at how hospitals are auditing the participation in vendor programs. We’ll kick off the review with this Best Practice example from WellStar’s Coding Assurance/Compliance Department.
WellStar is a five-hospital system in the rapidly growing northern suburbs of Atlanta, Georgia area. Like most healthcare systems, one of the goals of its program is to manage the access of vendor representatives to support patient safety and to minimize staff interruptions. Three months after implementing sign in and badging guidelines, WellStar wanted to assess the impact of the effort. A straightforward field review of its vendor program identified opportunities to clarify the program practices and improve participation.
By observing 10 representatives as they came into a WellStar facility and conducting informal intercept interviews, WellStar gained valuable insight that improved its program. What they learned:
- More vendors are using the appropriate entrance point than previously
- Some departments actively send unregistered reps to the sign in station; others do not. Some are denying red flagged vendors access; others do not.
- Reality in the field identified gaps between system requirements and department requirements
- Questions that define risk tiers and credential requirements cause confusion for some and lead to mis-classification.
- Some reps sign in under false or shared names to game the system.
With learning like this, WellStar is already improving its program with a few tweaks to its program. We’re finding other customers making similar changes, such as.
- Requiring badge photos to eliminate registration sharing.
- Simplifying questions about business relationship that define credential tier at registration to improve consistency and rep participation.
- Further refining department level requirements and integrate those within the vendor program.
- Holding departments, as well as vendors, responsible for accurate participation.
Consider taking a couple of hours to watch what happens in your facilities. Simple adjustments might make your program more successful for all.
(Vendors: Update your WellStar registration.)
As healthcare systems roll out vendor credentialing programs, it’s important to understand what is and is not within the individual rep’s authority to agree to.
Vendor credentialing in healthcare mixes the credentials of individuals with their employers, but the average employee cannot enter into agreements on behalf of the employer.
All in all, suppliers want to provide the information their buyers need, but there are a few items occasionally requested in vendor credentialing programs that give supplier management pause:
Anything that Affects Contract Terms –The account representative doesn’t have the authority to sign off on anything that modifies contract terms. Healthcare buyers sometimes take the launch of a vendor credentialing program as the chance to slip in termination clauses, but that’s not appropriate. If it’s important enough to modify a contract, it should be included in the contract proper.
Penalties – Penalty clauses for violating a hospital policy that state the contract could be terminated or require termination of the employee. Again, if it’s that important, it should be negotiated as part of the contract.
Business Associate Agreements – Account representatives are not in the position to accept a Business Associate Agreement. This is even more significant now with the expansion of HIPAA requirements in relation to business associates in relation to the Stimulus Plan. (In brief by February 2010, business associates must meet the same security and privacy standards as the healthcare provider.)
Indemnity – Account representatives typically are not directors of their employers so they have no authority to approve indemnification or liability agreements.
An inherent value of vendor credentialing programs is a central view of the status of all the desired characteristics of the supplier company as well as account rep. So if you can’t ask for these essential agreements, what can you do?
Store the Document – Your vendor credentialing program is a great tool for information management. Leverage the tool to store the document and automate expiration alerts. Healthcare systems can certainly ask the representative to add the current attestation of the already-negotiated-indemnity coverage to the system. Just don’t ask them to personally sign off on the agreement.
Add Vendor Credentialing to Your On-boarding Process – The line between what the rep can agree to and what the company can agree to is crisper during the contract negotiation phase. Articulate your vendor credentialing program participation requirements as you are negotiating the contract. That way each side walks into the relationship with a clear understanding of expectations. Appropriate supplier management can sign off on entity-to-entity level requirements, and the account representative can focus on what they do best – serving the customer.
In a step to rationalize healthcare representative credential requirements, a joint best practices team across Advamed, AACN, AHRMM, AORN, HIRA, HMMC, IMDA, IPPS, IHAC and MDMA have released their recommendations on appropriate credentials for Health Care Industry Representatives in Clinical Areas.
The document reflects what Vendormate health care clients typically require for reps in patient care or clinical areas:
1. Immunization Records – the commonly requested MMR, HepB, and TB test
2. Training — product competency, HIPAA policies, Code of conduct/ethics, OSHA/Bloodborne pathogens
3. Hospital/Department Orientation
4. Background verification — drug screen (as applicable), criminal background check, sexual offender registry, and sanction screens
5. Statement of Insurance Liability letter
The standards emphasize the importance of the representative’s privacy and generally state that the healthcare system should accept attestations of the representative’s employer that these standards have been met.
Combining privacy with relevancy, the standards also counsel against collecting SSNs, drivers license information, personal credit checks, and resumes.
In general, most of our customers’ programs already meet these recommendations. None collect the personal information of SSNs, drivers licenses, credit checks, and resumes.
A few nuances we would recommend:
Record the expirations of immunizations. The status of “current” is what is essential here. A document that is collected one time at the start of a relationship does not reflect changes that occur over time. A simple notation of “expiration date” can help both the health system and the representative stay on top of this potential exposure.
Sanction checks need to be done more frequently. CMS has pushed state level bodies to check at least monthly, and the rate of recidivism is relatively high. Of all checks, this should certainly be done by someone other than the rep or the employer. However, privacy can be protected even here. Basic information such as name, county, and state of residence is generally enough to clear any sanction list match question. Vendormate counsels its customers that any additional information is required to reconcile a potential match be collected only on an as needed basis and with the full awareness of the potentially matching person.
The recommendations clearly reflect that these are for reps in “clinical areas.” Clinical reps are only one part of the supply chain approach to vendor credentialing. In addition to the clinical rep, the healthcare system will still want to define standards for its vendor companies — the company’s financial strength, the company’s sanction list standing, etc.
There was a time when clothing colors made statements. Good guys wore white hats. Bad guys wore black. Serious business men wore white shirts. No one attending the wedding would wear black because black was the color of mourning, and only the bride wore white. (In the U.S. at least. Of course in Asia, white is commonly a mourning color.) In some hospitals, vendor reps are required to wear black scrubs.
But color alone isn’t enough to tell who’s who. Oh, remnants of these practices still hold. And color-coded scrubs give an at-a-glance clue as to which group an individual belongs to, but that’s not enough for the healthcare compliance directors quoted in this great article, Pressure Mounts to Manage Medical Device Vendor Reps in Operating Room.
This article on AIS’s Health Business Daily on March 5 2009 reports the issues these healthcare compliance directors face on the front line in managing medical device vendors in the hospital.
Here are a few requirements cited by these leaders:
Keeping reps focused on an identified business purpose. Assisting or selling, not milling around
Patient privacy. Even if the patient gives consent to a vendor rep attending a procedure, hospitals may have additional privacy practices that the rep should follow.
Immunization status. To limit susceptible patients’ exposure to communicable diseases.
Training and competency. A difficult area still being defined. What are the standards? Who provides the measurement?
Financial relationships. The most prominent involves relationships between consulting surgeons and vendor companies, such as training vendor reps for pay – As one compliance officer stated in the article, “‘If they stopped buying products from the vendor, their teaching money would evaporate,’ he says.”
Imagine trying to convey an individual’s status on all these metrics through scrubs? Black scrubs with yellow stripes signify current immunizations. Red dots mean you’re fully trained. It’s not really viable.
It’s this complexity that is driving more and more healthcare systems to vendor badging integrated with their compliance programs. Beyond the color of the scrubs, healthcare systems need unique single-use badges that reflect today’s status of vendor reps and their companies.
Otherwise, you’re still left wondering – Is that a good guy in the black hat?
Business policies, like New Year resolutions, are written with the best intentions. With a new policy in place, operations will be more efficient. Universal understanding will be achieved. Expenses will be reduced and profits will soar.
These policies, like resolutions, are enthusiastically followed the first few months. Then they are forgotten. Keeping a policy “live” over time takes effort. Requires changes in core behaviors.
A recent article in Health-System Pharmacy News, quoted Dave Hicks, the University of Chicago Medical Center’s chief pharmacy officer, talking about their Vendormate-based vendor management application.
Hicks said the medical center already had a vendor-management policy in place, but compliance was inadequate.
“The vendor would make an appointment with somebody at the hospital, and that would get them through security,” Hicks explained. “And then they’d spend the day in the hospital trolling the hallways, essentially, and looking for people to have ad hoc conversations with.”
Hicks said the Vendormate system helped put teeth into the existing policy (emphasis added). The program rollout also included education for staff about permitted vendor activities and the medical center’s expectations for vendor behavior.
I’ll wager that the success University of Chicago and Hicks now are experiencing in policy compliance is based on the behaviors driven by educating the staff and the appointments and sign in process, rather than any new policy.
It’s not that the intent to comply wasn’t there before. Just like every night that I went to bed, intending to get up early and exercise. But come morning, the existing behavior of hitting the snooze bar was already there. Changing that behavior didn’t require a new, “don’t hit the snooze bar” policy, but it did require moving the alarm clock out of arm’s reach.
An article this past weekend in the Detroit Free Press highlighted the leading edge activities of hospitals and healthcare systems in Detroit and throughout Michigan in balancing vendor access and influence with fiscal responsibility and patient safety.
Vendor management touches many facets of healthcare operations, and the quotes in the reflect much of this. Tiffin Kaczkowski, DMM of Oakwood, comments on insuring patient safety by managing training and immunizations of visiting HCIRs. Ed Grima, corporate compliance at Beaumont, focused on eliminating inappropriate influence in the buy decision.
These two health systems are just some of the 29 hospitals across five health systems in Michigan that have turned to Vendormate to manage their vendor compliance and credentialing programs. We’re proud to be part of this state’s leading efforts.
Need to Register with a Vendormate vendor program in Michigan?
It’s no secret that vendor credentialing requirements and registrations aren’t popular in the vendor community. But C. R. Bard has flipped new registration program announcements from a perceived bar across the door to a door opener.
One enterprising Regional VP took Vendormate’s recent announcement of Detroit Medical Center’s decision to use Vendormate VISION as a customer touchpoint. A quick email to the supply chain director reinforced that C. R. Bard is keeping up with DMC and ready to get to work.
I hope you are well these days! I wanted to let you know that I received an e-mail from Vendormate regarding the effective date of DMC’s agreement with them.
I have sent out a message to all C. R. Bard reps and managers who cover DMC facilities, requesting they sign up immediately.
They’re all pretty familiar with this process, so I am certain they will get it taken care of soon, but wanted to let you know that the word has gone out.
Her payoff? A simple touch to the director has been forwarded to three other contacts at DMC, including a corporate VP. A sales professional’s dream. Visibility up the ladder.
Sidebar: Do you work with Detroit Medical Center? Register here.
Happy New Year? I always like to start a new year optimistically. But it’s a little more difficult this year, now that I read this report.
Just out from the Health Care Compliance Association (HCCA) and the Society of Corporate Compliance and Ethics (SCCE) are the discouraging results of a survey of health care compliance professionals. In the survey, more than 8 of 10 compliance professionals believe “the current economy greatly or somewhat increases the risk of compliance and ethics failure.”
If you have policies in place, now is the time to reinforce them with your vendors and your staff. If you don’t, now is the time to put them in place — before temptation pulls someone off course.