VENDOR
MANAGEMENT
Troy Kyle
President / CEO
Vendor Credentialing Service
troykyle@vcsdatabase.com
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

VENDOR CREDENTIALING?
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

REQUIREMENTS
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
“Follow the Money” Principle
 Checked through the EPLS and LEIE (federal),
and State OIG websites

http://oig.hhs.gov/fraud/docs/alertsandbulletins/effected.htm
PENALTIES

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

OTHER 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
REQ’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

REQ’S CONTINUED
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

REQ’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.

WHAT DOES IT MEAN TO HEALTHCARE?
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

RISK 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/
CHALLENGES FACING A FACILITY

Vendor Company

Financials
Bankruptcies
 Liens
 Judgments


Vendor
Representatives

Involved with AntiKickback Legislation
Liability Insurance
 HUB’s
 Conflict of Interest
Immunizations
MMR
 TB
 Varicella
 Influenza

Legal Standing








Cold Calling
Background Check
Conflict of Interest
Contact Information
Proper Trainning
CHOICES
Develop your own system

Cost

Human capital
Design the system
 Programming
 Manage the
information

Development time
 Administer the
program
 Higher cost to vendor
community

Use a service

Cost
Normally at no or
little cost to you
 Administer the
program
 Lower cost to vendor
community

QUESTIONS?