1. Presented by: University Privacy & Contracting Office 1

2. Introduction Industry is defined broadly as any company selling goods or services for patient care. The industry guidelines for Tulane University are listed on the compliance website located: http://tulane.edu/compliance/upload/HCC-004-Industry-Representative- Policy.pdf http://tulane.edu/compliance/upload/HCC-004-Industry-Representative- Policy.pdf 2

3. Purpose This policy outlines a set of acceptable, ethical business practices and principles that will guide the interactions of all faculty, staff, and trainees of Tulane University. The industry registration requirement for Tulane University has been in effect since May 1, 2011. 3

4. Tulane Policy For Industry Representatives Industry representatives (IR) must register with Reptrax prior to visiting a Tulane Facility; IR must create an appointment ahead of visit; IR’s sign-in and receive a printed badge in order to enter any Tulane facility – J.B.J., Murphy, Perdido, Poydras, School of Medicine, Tidewater, etc.; The IR sign-in computer kiosk where badges are printed is located on the 1 st floor in the School of Medicine at 1430 Tulane Avenue; IR’s are not permitted to use Tulane’s phones, fax machines, computers or copiers, excluding the sign-in computer kiosk. 4

5. Tulane Policy For Industry Representatives Continued Tulane IR Requirements: TUMG Industry Policy ( HCC-004 ) Proof of Liability Insurance Proof of Background Check Product/Service Training Completion Documents HIPAA/HITECH Training Completion 5

6. Why Is This Program Important? Increasing awareness and understanding of Tulane’s industry policies by all parties. Improving patient, IR, and employee safety and health through credential verification of industry representatives. *Medicare/Medicaid monthly check. Decreasing product and service misrepresentation. Helping faculty, staff, students, and security personnel identify potentially nefarious individuals lacking credentials for access to areas. Additionally, if patterns of theft or vandalism are occurring, this program establishes where IR’s are traveling within Tulane. 6

7. Why This Program Is Important Continued Reduces time spent by Tulane employees reviewing and organizing credential documents of vendors. The Clinical Compliance Operations Committee will be reviewing reports for selective audits of IR compliance with Part II of Tulane’s Industry policy. 7

8. Here Is What You Can Do To Support The Program: If you see an industry representative without a badge, please direct them to the check-in point. The badge will have: The IR’s picture; The name of the company represented; The name of the IR; The date; The appointment time; The location of the appointment; The person the IR has the appointment with. α Note: This only applies to TU Health Sciences Center facilities. IR’s who visit TUHC must follow all TUHC policies and must use the kiosk located on the 2 nd floor of the hospital. 8

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10. Reporting The Privacy & Contracting Office is in the process of working with Tulane University Medical Group’s Compliance Officer, Dr. Dennard, to determine monitoring guidelines of industry representatives. 10

11. Feedback, Comments, or Questions? Hunter McMillan, University Compliance Coordinator (504) 988-7721 Glenda Folse, R.N., NE-BC, C.H.A. University Privacy & Contracting Officer (504) 988-7739 11