Vendor Risk Profiles – Vendor Representatives

April 2, 2007 at 7:15 pm Leave a comment

The United States Attorney’s Office, Southern District of Florida, recently announced a medical equipment company owner was sentenced to four years in prison for defrauding Medicare of $2.2 million in payments for medical equipment that was never provided to patients.  Do you know if you are/were doing business with this company? 

Talking to one large multi-national medical device company about their processes for screening their employees against the OIG sanction list, they admitted that this is done once…. at the time of hire.  That does not cut it in OIG eyes.  These should be done at a minimum, annually.  A vendor representative may be placed on the sanction list as a result of improprieties from a business relationship (Board Membership, ownership stake, former employee) outside of their direct employment.  Without continuing these screenings, gaps in credentialing are created.    I suggest you ask yourselves the following questions when considering who you work with:  Who is roaming your halls? How many vendor representatives are in your hospital every day?Is this vendor representative still employed by the vendor they claim to be associated with? 

What has their employer screened for that covers your liability?  How often are these screens performed? 

What additional screens are required to protect your employees, patients, customers, other vendors? 

What do you know about their employer?

What is the skill / aptitude of this representative?

Has this individual signed off on all current vendor policies? 

Have all individuals requiring special certifications and immunizations been qualified? 

How often is this person in your facility? 

Who are they seeing when they come on site? 

How long are they visiting?

What is the relationship with that representative and any of your company representatives?

What tests or certifications have they acquired that give you confidence in their abilities and mitigate your risks?

Does this person have a criminal record that you should be aware of?

How often is a vendor trained on the product he is selling?  Did he pass the training?  How do you know this?

Does your representative have a criminal background? 

Has he ever filed bankruptcy?

Do vendor reps know what is required of them?   

Entry filed under: Uncategorized.

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