1. V ENDOR M ANAGEMENT Troy Kyle President / CEO Vendor Credentialing Service troykyle@vcsdatabase.com

2. OBJECTIVES Government Watch List (what they are, laws, and enforcement actions) HIPAA, how it affects facilities from a vendor perspective, BAA’s, etc. Immunization testing, what is required, CDC and OSHA regulations Training requirements, Bloodborne Pathogens and OSHA rules and regulations Access Controls

4. V ENDOR C REDENTIALING ? Definitions: The process of obtaining and reviewing the documentation (licensure, certifications, insurance, etc.) of health professionals. Generally, this includes reviewing information given by the professional and verifying that the information is correct and complete. missourifamilies.org/features/healtharticles/healt h40.htm missourifamilies.org/features/healtharticles/healt h40.htm

5. R EQUIREMENTS What are Government Watch List? OIG/GSA Government Exclusions: The OIG, under this Congressional mandate, established a program to exclude individuals and entities affected by these various legal authorities, contained in sections 1128 and 1156 of the Social Security Act 11281156Social Security Act “Follow the Money” Principle Checked through the EPLS and LEIE (federal), and State OIG websites http://oig.hhs.gov/fraud/docs/alertsandbulletins/effected.htm

6. P ENALTIES CMP’s or Civil Monetary Penalties OIG's CMPs are in the Civil Monetary Penalties Law ("CMPL"), 42 U.S.C. § 1320a-7a Corporate Integrity Agreements Typical term is 5 years http://oig.hhs.gov/fraud/cia/cia_list.asp Tenet Health, Zimmer, Walgreen’s Have reimbursements withheld Become an Excluded Entity

7. O THER REQ ’ S OSHA – “Since your company maintains a continuing relationship with its employees, but another employer (your client, a healthcare facility) creates and controls the hazard, there is a shared responsibility for assuring that your employees are protected from workplace hazards.” “The client, of course, may specify what qualifications are required for supplied personnel, including vaccination status.” Bloodborne Pathogens training http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21010

8. R EQ ’ S CONTINUED CDC – Immunizations for people who work in a health-care facility include MMR, Varicella, HBV, TB (schedule of immunizations) Schedule for health care workers HHS – HIPAA regulations with considerable interest in incidental disclosure. Enforced by the OCR (Office of Civil Rights) BAA’s Social Networking / Media

9. R EQ ’ S C ONTINUED The Joint Commission (TJC) – Does not currently directly address vendors who are not contracted by a healthcare organization. Security / Patient Safety TB Test #1 check AORN - Health care industry representatives may function in any of several positions (e.g., clinical consultants, sales representatives, technicians, or repair/maintenance personnel). OR Procedure Room Protocol

10. R EQ ’ S CONTINUED ACS – The purpose of this statement is to supply guidelines to health care facilities and members of the perioperative health care team to ensure an optimal surgical outcome, as well as the patient's safety, right to privacy, and confidentiality when a HCIR is present during a surgical procedure. OR Procedure Room Protocol General Expectations and Hospital Safety Training The patient should be informed of the presence and purpose of the HCIR in the OR and give written, informed consent. This should be documented within the medical records.

11. W HAT D OES I T M EAN T O H EALTHCARE ? Vendor Management = Risk Management Managing Risk to patients healthcare-associated infections account for an estimated 1.7 million infections and 99,000 associated deaths each year 13,779 TB cases (a rate of 4.6 cases per 100,000 persons) were reported in the United States in 2006. Patient Privacy and Patient Rights Security of the hospital and hospital property Managing Conflict of Interest Cost controls with proper device and medication approval processes

12. R ISK REDUCTION Access Controls Cold Calling Appointment setting Medical mistakes due to interruptions Without Interruption With Interruption Procedural failure rate 69.6% 84.6% (with three interruptions) Clincal error (at least one) 25.3% 38.9% (with three interruptions) Estimated risk of major error 2.3% 4.7% (with four interruptions) http://confidenceconnected.com/connect/article/reducing_interruptions_and_errors/

13. C HALLENGES F ACING A F ACILITY Vendor Company Financials Bankruptcies Liens Judgments Legal Standing Involved with Anti- Kickback Legislation Liability Insurance HUB’s Conflict of Interest Vendor Representatives Immunizations MMR TB Varicella Influenza Cold Calling Background Check Conflict of Interest Contact Information Proper Trainning

14. C HOICES Cost Human capital Design the system Programming Manage the information Development time Administer the program Higher cost to vendor community Cost Normally at no or little cost to you Administer the program Lower cost to vendor community Develop your own systemUse a service

15. Q UESTIONS ?