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
Healthcare Crackdown on Fraud
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.
Add comment July 30, 2009
Bankruptcy, Part II
Back in October, we posted the BPM or Bankruptcy Page Metric, which was just a count of the pages of Chapter 11 filings in the US Bankruptcy Court, District of Delaware. From a base of 3 pages of filing in January, 2008, the number of pages in the filings jumped to 16 pages in August, 2008.
Now, we see this statistic from the Washington Business Journal
More than 14,000 businesses filed for bankruptcy protection in the first quarter of 2009, a 64 percent increase over the same period a year earlier.
Nearly 10,000 of the business filings in the first quarter were Chapter 7 liquidations. Chapter 11 reorganizations accounted for 3,421 filings.
Chapter 7, as you know, means the doors are closed. No continuing operations ala Chrysler, GM, etc.
Every buyer and materials manager needs to have contingency plans in place to respond to a bankruptcy. Start with monitoring the credit scores and status of your vendors through your vendor program. Then have direct and frank conversations with your suppliers to understand their current situation and how you can work with them to keep the worst from happening.
Add comment July 10, 2009
Vendor Program Audits: From Homeroom to First Period
Back on the topic of vendor program audits, this week is about auditing the hospital’s own participation in the vendor program. I’ve made my middle-school son the stand-in for vendor representatives, so let’s turn the table and make his teachers the analogy for hospital staff.
Our school system has a set of guidelines for teachers. But not surprisingly each teacher approaches the task at hand differently. And that’s good. The teachers’ training and experience should be respected.
But at the same time, that variety can make it difficult for the administration to manage the less glamorous parts of running a school and for the students to figure out what to do.
It’s the same with hospitals. Each department wants to do what it believes is best and with its own style. But that grass-roots level initiative can make it difficult for administration to be confident standards are being met across departments and for vendors to figure out what to do.
The key is balance. Standardize the routine so that flexibility is possible when needed.
From a vendor program standpoint, sign in and badge status reports by department are the teacher’s pets, telling which departments aren’t toeing the line.
Here’s what many of our customers do.
First, run a report of all vendor rep sign-ins for some period — say a week or a month. Sort it by department. Which departments have the highest visitor traffic? Is it the ones you expect? If patient care areas like the cath lab aren’t at the top of the list, you know that something is off. On the flip side, if no one is signing in for pediatrics, that’s another problem.
Now sort the list by badge status within department. Do you see a department with a lot of non-compliant vendors? Stop by and find out why that department isn’t collecting the required documents. Maybe that document isn’t really relevant and that requirement should be dropped. Maybe that department doesn’t understand that your vendor program is about getting the mundane paperwork out of the way, so that the staff can focus on care delivery, not risk management.
Add comment July 1, 2009
Vendor Credentialing for Brides
I’m going to digress a bit this week to highlight the expansion of vendor verification and credentialing into other verticals beyond healthcare.
Buyers have always turned to references for reassurance when they lacked personal experience in selecting a supplier. And as the internet expands a buyer’s access to potential suppliers to infinite levels, references and credentials become even more meaningful. At first, comments from strangers about hotels, software, etc. suffice, but reading through those comments quickly becomes numbing. Comments run the gamut from excellent to miserable.
Who can you trust? Turn to the experts to help you decide and vendor credentialing is born.
Now vendor credentialing is moving into a variety of industries, but I think the most intriguing application is the wedding industry. The average US wedding in 2008 cost $21,800 (down, by the way, from $28,700 in 2007) according to The Wedding Report.
So, when you’re spending that amount of your own money, you certainly want to be sure you’re getting what you want. No longer restricted to referrals of friends and families, the happy couple can now turn to Verified Valid to credential the potential wedding service provider.
Vendors pay from $50 to $300 for credentialing and verification based on the level required. Then brides pay an additional fee for access to the information. (Hmmm. That’s more expensive than in healthcare.)
This all makes more sense than most “Buyer’s Guides” I’ve seen which are little more than paid listings without any vendor qualfication other than the check cleared. At least here, brides save time and get trusted independent counsel. Vendors get a stamp of credibility and access to qualified buyers without having to prove themselves over and over.
As healthcare compliance becomes increasingly integrated with risk and supply chain management, it won’t be surprising to see a shift in the vendor’s view that the value of vendor credentialing is in credibility and access to buyers rather than just a hurdle to be jumped.
Add comment June 17, 2009
Vendor Program Audits: The Documents
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
Add comment June 4, 2009
Vendor Program Audits: Who’s at the Door
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.)
Add comment May 28, 2009
Vendor Program Audit
Our school system gives each student an agenda at the start of the school year. It’s a basic utilitarian calendar — columns for each day of the week, rows for each class, and a resulting grid where they can write daily assignments and tests. My middle-schooler has had one of these for seven years now. Using an agenda should be second nature by now.
It’s not.
That’s why when we started noticing an increasing number of forgotten assignments, my wife and I instituted the Agenda Audit. Each night when he announces he’s finished his homework, one of us asks to see his agenda. The resulting conversations go something like this:
Me: Why aren’t there any assignments written down for Spanish this week?
Him: I wrote down the test. Was I supposed to write homework assignments, too?
or
Me: Have you finished all your homework for tomorrow?
Him (with exasperated voice and rolling eyes): Yes
Me (opening agenda): Where’s this math assignment? Let me see that one.
Him (bewildered): Math? Oh I forgot about that.
I’ll give him the benefit of the doubt. I don’t think that he’s intentionally forgetting assignments. But to a 13-year-old, homework only gets in the way of what’s really important — video games and sports.
Several of our customers have noted the same thing with their vendor programs. Initial enthusiasm and participation dies down. Staff and reps start forgetting the procedure.
Maybe you need a Vendor Program Audit. Over the next couple of posts, we’ll give you tips from hospitals who have conducted their own Vendor Program Audits to give you some ideas.
Add comment May 18, 2009
Swine Flu and Vendor Credentialing
Tracking the immunization status of healthcare industry reps (HCIR) in clinical areas is one of the main drivers of many hospital vendor credentialing programs. But Vendormate has always recommended that health care systems think of the application as a vendor management solution, not just a clinical rep database tool.
Now concerns about H1N1 (swine flu) virus have prompted a number of hospitals to leverage the unique communication capabilities of Vendormate VISION to alert all vendor reps to new temporary procedures.
Messages range from the gentle reminder to stay away if you don’t feel well to access lock downs. Here’s one example:
To all vendors visiting UMass Memorial Medical Center:
The Centers for Disease Control has confirmed cases of 2009 H1N1 “Swine” Influenza in Massachusetts. We are therefore asking all vendors to limit their visits to the medical center to those that cannot be reasonably postponed. Also, if you or your staff are experiencing any of the typical symptoms of flu (fever, muscle aches, headache, cough, sore throat), please reschedule your visit or send someone else in your place. This is especially important for all vendors who have staff routinely on site to deliver supplies and equipment or to service medical center programs.
I appreciate your cooperation. Please let me know if you have any questions or concerns.
Thank you.
And one more:
If you have symptoms of a respiratory illness please do not visit our facilities. If you have had the flu please postpone your visit until you have no more symptoms and it has been at least 7 days since the onset of your symptoms. Sales related business may be carried out by phone or e-mail. Your cooperation is greatly appreciated.
Thank you,
Self Regional Management
This use of the vendor database and communication capability of the Vendormate VISION tool may not have been the intended application, but may turn out to be one of the most powerful.
1 comment May 1, 2009
Documentation and Relationship / Process Optimization — That’s What We Do
Jason Busch, over at SpendMatters, just took a stab at Segmenting the Supplier Information and Relatonship Management Market. He defined three approaches: analytics and predictive forecasting; data centric and data management; and documentation and relationship/process management optimization.
The first group of providers fall into what I’ll term the documentation and relationship / process optimization bucket. These are providers that fundamentally approach the supplier information and relationship management challenge from the vantage point of documenting supplier credentials, certifications, relationships and other requirements. They also aim to optimize the overall supplier relationship and streamline internal processes for managing suppliers. In some cases, organizations might use these providers to manage only a subset of their supply base for certain programs (e.g., performance, environmental compliance, supplier enablement, etc.) But in others, these programs will focus on getting 100% — or close to 100% — of a supply base on-boarded or into a centralized system. In the later scenario, companies might opt to manage basic information for the broader group (e.g., certifications, risk) while taking a highly focused, deeper relationship and information management approach with a select sub-set of suppliers for specific programs (e.g., performance) or based on the value of that sub-group to the business. What providers fall into this bucket? Hiperos, Aravo, Browz, Vendormate are four that come to mind immediately, but I’m sure there are more.
It’s an interesting taxonomy. And from our perspective a strong description of what we aim to deliver. In healthcare in particular, the relationship between the purchasing hospital and the vendor company, as well as the between the medical staff and the vendor representative, is complex, overlapping, disjointed, and misunderstood. And yes, Vendormate tries to provide the central view of the relationship that allows for strategic supplier management.
If you’re interested in keeping up with the wide world of spend management, Jason’s blog is one you should keep an eye on.
Add comment April 17, 2009
