Posts filed under ‘vendor compliance’
Compliance and credentialing requirements, such as OIG LEIE sanction checks, apply to many healthcare vendors — even those that never visit a hospital. So hospitals that focus their vendor compliance efforts on on-site vendor reps create an artificial cap to compliance. In our experience, 4 in 10 of the hospital’s vendor base is untouched when attention is paid only to the vendors that have feet in the halls.
Yet some hospitals have broken the 60% compliance rate ceiling. How?
By integrating vendor compliance and credentialing into their on-boarding, contracting, or accounts payable processes. We’ve seen hospitals take one or more of these steps to close the credential gap and minimize their risk exposure.
- Ensure vendors are credentialed and compliant when on-boarding data into the vendor master database by either synchronizing with or even importing Vendormate VISION data.
- Add standard language to new contracts and contract renewals to ensure vendors register and fulfill compliance requirements before executing a final contract.
- Some hospitals add a step into purchase order or invoice creation that calls for AP managers to check Vendormate VISION to ensure vendors are compliant.
These straightforward process changes have the profound effect of blowing right through the compliance ceiling.
Contributed by: Ed Zunzunegui, VP of Operations, Vendormate
Last May in the Swine Flu and Vendor Credentialing post, we highlighted the new reality that a number of customer hospitals were email visiting vendor representatives to new H1N1 precautions. These hospitals relied on their Vendormate registration files for current vendor contact information. Most of these notes were gentle reminders of communicable disease best practices and basically read, “if you’re sick, stay home.”
With H1N1 still with us, hospitals are again alerting visiting representatives to new precautions. Hospitals want to require seasonal flu and H1N1 vaccinations, but know that distribution issues make that impossible. Instead they are requiring the immunizations or a mask when on site.
Most of these customers have adjusted their Vendormate-based program to communicate the shot or mask requirement and to track compliance.
To reinforce the message, Vendormate badges at these hospitals now include a WARNING by the badge photo indicating that a MASK is required if the visiting representative hasn’t yet been able to complete the vaccinations. This message is critical for the hospital staff to be able enforce the requirement quickly and effectively without interfering with the vendor’s business routine.
I’ll suggest that the day-to-day reality of compliance management is more about actively communicating the sets of unacceptable behaviors rather than uncovering and punishing perpetrators. After all, the vast majority of people follow community standards of ethical behavior (except, perhaps, during rush hour). For this reason, it’s not surprising to see recommendations like this recent one from Supply Chain Management Review. An article discussing Gifts and Entertainment Policies best practices, includes this conclusion:
Finally, another best practice on this topic is to send an annual letter to suppliers, reminding them of the policy and expectations, alerting them to the consequences for failing to abide by the policy, and enclosing a summary of the policy for their guidance.
I appreciate the intention of clarity. Define your standards, and communicate them to all affected parties. But how do you do this, really? How many supply chain managers have the contact information for all the supplier reps who might be doing the entertaining? Sure you’ve got your contacts, but what about the other department heads’ contacts?
And then, what about your other policies that you want to communicate? Do you bundle this all into one extended message? Or do you piecemeal it over time? A “Message a Month”?
The recommendation also includes repetition. Not just at the start of the contract, but annually. Again, I agree. Reinforcement, reminders, and repetition are all keys to communication and learning.
Of course, I have my own point of view here. And it’s that Vendormate addresses this by having suppliers register on a buyer’s customized portal. The supplier, rather than the buyer, keeps the contact information current. This way the supplier is always informed of the buyer’s standards, just as the supplier stays current about the buyer’s product and service needs. The web-based portal provides 24/7 availability of all policies (old, new, and in-between) and serves as the central database of record for supplier and vendor contact information for email announcements of changing policies.
But not everyone is a Vendormate user, so, I’ll open this up for comment. What are your real world approaches to this communication recommendation?
John Commins over at HealthLeaders recently wrote about the ever-rising focus on fraud in the healthcare. In his article, Culture of Compliance Preempts Whistleblower Suits, he makes the point that the potential gains to the whistleblower in a difficult economy could easily increase the number of whistleblower suits. He continues that creating a culture of compliance, with appropriate reporting pathways, is the best way to prevent these suits.
The aphorism is true: Prevention is the best medicine.
Cultures are typically created informally and unintentionally. Action by action. Decision by decision. Until there is a consistency in viewpoint and behavior. I’ll build on John’s recommendation that now is the time to conciously create a culture of compliance by adding that culture has to be applied consistently across staff, contractors, and vendors.
When I introduced this series of posts about how hospitals are auditing participation in vendor programs, I used the analogy of my son’s inability to effectively use an agenda to keep up with his homework. Just to keep beating that horse, let’s compare homework to the documents that buyers want from their vendors.
It continues to amaze my son that the completed homework he left on the kitchen table or in the bottom of his locker doesn’t count to his teachers. And for vendor reps, just as with homework, having the document isn’t enough. Unfortunately, it’s not enough to say, “I did it,” or “I’ve had that training.” It actually has to be turned in for credit. And that’s one of the key drivers for vendor programs in healthcare and banking — Document Management. Collecting. Storing. Tracking expirations.
I find out when my son has forgotten to turn in homework through the school’s “document audit website” — or as they call it, online student report. I log in, pull up his name, select a class, and review the assignments. At a glance, I can see any missing assignments.
Many of our customers turn to the Document Audit Report inside Vendormate VISION as the first step in their vendor program audits. The Document Audit Report allows customers to check the status of all their registered companies and registered reps against any or all the required documents. The status identifies completed, alert (about to expire) or missing/expired documents.
One of our customers recently changed its product trial program to protect itself from unexpected expenses. Any product brought in for trial now needs a no-charge purchase order. If not, the trial product is considered a donation.
Vendormate sent an alert out to all registered reps who might be affected by this type of policy. Homework analogy — everyone received the handout.
Three weeks later, a document audit report across all these same reps showed that 9 of 10 had acknowledged the new policy. Homework analogy — 9 of 10 in the class completed the assignment and turned it in.
For the remaining 1 in 10, I guess it’s detention. Not really, but reporting like this makes it easy for the hospital to identify and manage the remaining reps as exceptions. And for any of these people with a pattern of non-compliance, the consequences could be significant.
The point is vendor compliance is not once and done. Situations change. Staff changes. And your program has to adapt. Program audit techniques like this help you determine whether or not your program is achieving your goals
Last week, I promised that the next few posts would look at how hospitals are auditing the participation in vendor programs. We’ll kick off the review with this Best Practice example from WellStar’s Coding Assurance/Compliance Department.
WellStar is a five-hospital system in the rapidly growing northern suburbs of Atlanta, Georgia area. Like most healthcare systems, one of the goals of its program is to manage the access of vendor representatives to support patient safety and to minimize staff interruptions. Three months after implementing sign in and badging guidelines, WellStar wanted to assess the impact of the effort. A straightforward field review of its vendor program identified opportunities to clarify the program practices and improve participation.
By observing 10 representatives as they came into a WellStar facility and conducting informal intercept interviews, WellStar gained valuable insight that improved its program. What they learned:
- More vendors are using the appropriate entrance point than previously
- Some departments actively send unregistered reps to the sign in station; others do not. Some are denying red flagged vendors access; others do not.
- Reality in the field identified gaps between system requirements and department requirements
- Questions that define risk tiers and credential requirements cause confusion for some and lead to mis-classification.
- Some reps sign in under false or shared names to game the system.
With learning like this, WellStar is already improving its program with a few tweaks to its program. We’re finding other customers making similar changes, such as.
- Requiring badge photos to eliminate registration sharing.
- Simplifying questions about business relationship that define credential tier at registration to improve consistency and rep participation.
- Further refining department level requirements and integrate those within the vendor program.
- Holding departments, as well as vendors, responsible for accurate participation.
Consider taking a couple of hours to watch what happens in your facilities. Simple adjustments might make your program more successful for all.
(Vendors: Update your WellStar registration.)
As healthcare systems roll out vendor credentialing programs, it’s important to understand what is and is not within the individual rep’s authority to agree to.
Vendor credentialing in healthcare mixes the credentials of individuals with their employers, but the average employee cannot enter into agreements on behalf of the employer.
All in all, suppliers want to provide the information their buyers need, but there are a few items occasionally requested in vendor credentialing programs that give supplier management pause:
Anything that Affects Contract Terms –The account representative doesn’t have the authority to sign off on anything that modifies contract terms. Healthcare buyers sometimes take the launch of a vendor credentialing program as the chance to slip in termination clauses, but that’s not appropriate. If it’s important enough to modify a contract, it should be included in the contract proper.
Penalties – Penalty clauses for violating a hospital policy that state the contract could be terminated or require termination of the employee. Again, if it’s that important, it should be negotiated as part of the contract.
Business Associate Agreements – Account representatives are not in the position to accept a Business Associate Agreement. This is even more significant now with the expansion of HIPAA requirements in relation to business associates in relation to the Stimulus Plan. (In brief by February 2010, business associates must meet the same security and privacy standards as the healthcare provider.)
Indemnity — Account representatives typically are not directors of their employers so they have no authority to approve indemnification or liability agreements.
An inherent value of vendor credentialing programs is a central view of the status of all the desired characteristics of the supplier company as well as account rep. So if you can’t ask for these essential agreements, what can you do?
Store the Document – Your vendor credentialing program is a great tool for information management. Leverage the tool to store the document and automate expiration alerts. Healthcare systems can certainly ask the representative to add the current attestation of the already-negotiated-indemnity coverage to the system. Just don’t ask them to personally sign off on the agreement.
Add Vendor Credentialing to Your On-boarding Process – The line between what the rep can agree to and what the company can agree to is crisper during the contract negotiation phase. Articulate your vendor credentialing program participation requirements as you are negotiating the contract. That way each side walks into the relationship with a clear understanding of expectations. Appropriate supplier management can sign off on entity-to-entity level requirements, and the account representative can focus on what they do best – serving the customer.