Vendor Compliance

HITECH Increases HIPAA Risk

vendorcompliance — Fri, 30 Oct 2009 21:15:56 +0000

Risk to violators, that is. Be sure to read the new interim final rule posted today. Key to the proposed changes is that the maximum penalty increases 60-fold — to $1.5 million for violations of an idential provision. And a covered entity can no longer bar the penalty unless correction is made within 30 days [...]

Swine Flu and Vendor Credentialing: Part II

vendorcompliance — Fri, 23 Oct 2009 15:49:38 +0000

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, [...]

HHS Breach Notification Form On line

vendorcompliance — Tue, 06 Oct 2009 18:40:12 +0000

The Hunton & Williams privacy and security blog has been very active recently. It covers a wide range of issues of interest to many industries. Last Friday, they noted that the Department of Health and Human Services had added the on-line form for breach notifications. For all of you worried about the burden of reporting a breach, take [...]

HITECH & BAA & Vendor Credentialing

vendorcompliance — Fri, 11 Sep 2009 17:33:51 +0000

Several of our healthcare customers came together for a call last week to talk about the implications of the Health Information Technology for Economic and Clinical Health (HITECH) Act, particularly as it concerns vendors that meet the “Business Associate” requirement. Representing hospitals from California to Florida to Michigan and in between, these systems shared a common [...]

Getting the Word Out

vendorcompliance — Tue, 25 Aug 2009 14:44:30 +0000

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 [...]

States Reinforce CMS Exclusion Guidelines

vendorcompliance — Mon, 17 Aug 2009 16:03:14 +0000

In January, 2009, the Centers for Medicare & Medicate Services (CMS) released a State Medicaid Director Letter (SMDL #09-001) clarifying and reminding States of the requirements and consequences of payments to excluded individuals and entities. Since then, states have been at work communicating the same requirements either under their own letterhead or by re-post. A quick [...]

Healthcare Crackdown on Fraud

vendorcompliance — Thu, 30 Jul 2009 17:40:06 +0000

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 [...]

Bankruptcy, Part II

vendorcompliance — Fri, 10 Jul 2009 20:50:27 +0000

Back in October, we posted the BPM or Bankruptcy Page Metric, which was just a count of the pages of Chapter 11 filings in the US Bankruptcy Court, District of Delaware. From a base of 3 pages of filing in January, 2008, the number of pages in the filings jumped to 16 pages in August, 2008. Now, we see [...]

Vendor Program Audits: From Homeroom to First Period

vendorcompliance — Wed, 01 Jul 2009 21:12:52 +0000

Back on the topic of vendor program audits, this week is about auditing the hospital’s own participation in the vendor program. I’ve made my middle-school son the stand-in for vendor representatives, so let’s turn the table and make his teachers the analogy for hospital staff. Our school system has a set of guidelines for teachers. But not surprisingly [...]

Vendor Credentialing for Brides

vendorcompliance — Wed, 17 Jun 2009 15:09:00 +0000

I’m going to digress a bit this week to highlight the expansion of vendor verification and credentialing into other verticals beyond healthcare. Buyers have always turned to references for reassurance when they lacked personal experience in selecting a supplier. And as the internet expands a buyer’s access to potential suppliers to infinite levels, references and credentials become even more meaningful. At [...]