vendor management september 7 th 2007 james mahan, vice president yankee alliance
TRANSCRIPT
Vendor Management
September 7th 2007James Mahan, Vice PresidentYankee Alliance
ObjectivesAt the end of the program you should
Understand the basics of; • What is Vendor Compliance? • Who does it affect?• Where does it originate? • Why is it an important?• How does it affect me?
Pieces of the Program
• Credentialing ‘the administrative process for validating the qualifications of
professionals and assessing their background.
• Certification
recognize as having met special qualifications
• ComplianceAdhering to the elements of the program
Why is this so Important?
People impacted;• Patient• Board of Directors• C-Suite ( CEO, COO, CFO)• Providers, Pharmacists• Support personnel
• Business Partners
Focus AreasAreas of significant impact;
• Patient Safety • Clinical Care Quality• Accreditation • Financial• Public Relations
There is no one entity that is driving this
overall initiative. In my opinion it is a
culmination of many different oversight
efforts.
Drivers!
Highest Level:
• Federal
• State
• Accrediting Bodies
• Oversight
• Insurers
Federal
• HIPAA - Health Insurance Portability Accountability
• OIG – Office of Inspector General • MMA – Medicare Modernization Act
• DRA – Deficit Reduction Act 2005
• CMS – Medicare and Medicaid Services
– Conditions of Participation– Interpretive Guidelines
State
• Medicaid
• Homeland Security (State Preparedness)
• DPH – Department of Public Health
• General laws – Consumer Protection
Accreditation and Guidelines
• The Joint Commission ( JCAHO) • NCQA – National Commission, Quality Assurance
• OIG – Hospital Compliance
• CDC – Center for Disease Control
• AORN- Association of OR Nurses
JOINT COMMISSION The issue of vendor compliance is reflected In their Standards and Elements of Participation;
• Human Resources Stds.• Environment of Care Stds. • Leadership Stds.
To name a few areas where you will findlanguage applicable to vendor management.
JCAHO HR 1.20
Ensure qualifications are consistent with
responsibilities.
“Organizations must manage contract personnel just as they must manage services and personnel that are provided by direct employees” ( FAQ on HR Stds.)
GOVERNANCE Corporate Responsibility
The Governing Board member may be expected to exercise general supervision and oversight of quality of care and patient Safety issues.
excerpted from (AHLA Annual Meeting June 25-27, 2007 “Corporate Responsibility and Health Care Quality – A Resource for Board of Directors – A Callender et .al.
There are many reasons to have a vendor
management program from an infection control
perspective;
Pandemic Plan for Hospitals from CDC
“ A Plan has been developed for facility access during a pandemic…”
Can you tell me who is in your hospital right now?
Deficit Reduction Act of 2005
...requires any entity, such as a hospital, that receives greater than $5,000,000 per year in Medicaid funds to implement a False Claims Education Policy. The policy must include detailed information about the False Claims Act and refer to or describe the hospital’s procedures for detecting and preventing waste, fraud and abuse. The policy was required to be in effect on January 1, 2007
ApplicabilityWhat many providers may not realize is that the policy
applies not only to the provider’s employees, but also to any contractors or agents of the hospital.
A contractor or agent is any person who furnishes Medicaid health care items or services, performs billing or coding functions, or is involved in monitoring of health care provided by the hospital on behalf of the hospital. This is a broad definition and could include consultants, vendors, and other entities providing services to or for your hospital.
Health Law Alerts – August 2006(excerpted)
In certain cases, contractors, such as supply vendors, may receive hundreds of policies from various hospitals, which may pose a practical challenge for the contractors’ compliance.
In case CMS decides to verify the hospital’s compliance, we recommend documenting the hospital’s efforts to notify its contractors of its policy.
Knowledge Standard
This standard imposes on a provider to be fully aware of the status of billing, claims…..and the providers with whomthey employ contract and or affiliate.
In other words you can’t play dumb if you should or could have known.
Balancing the Forces:
Lawyers and Risk Managers –
Protect Assets!
Administration
Efficiently Utilizes Assets!
Caught in the Middle!
Document!
Document!
Document!
Thank you!
Questions?