Chief Compliance and Ethics Officer Health Care

Vendor Exclusions

  • 1.  Vendor Exclusions

    Posted 03-20-2019 12:36 PM
    Does anyone have a somewhat easy, tried and true way to check the vendor list against the OIG exclusions list.

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    Gayla Smith
    HIM Manager/Compliance
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    2019 HCCA Compliance Institute


  • 2.  RE: Vendor Exclusions

    Posted 03-20-2019 12:50 PM
    Gayla,
    ​I believe Frank has a system/formula that he uses internally.

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    David Rothery, CHC
    Compliance Officer
    Marin County, CA


    These are my personal opinions and not those of the County of Marin
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    2019 HCCA Compliance Institute


  • 3.  RE: Vendor Exclusions

    Posted 03-20-2019 07:51 PM
    As for (relatively) easy, I have an Excel workbook with vendor company names, vendor key personnel, and my employees listed on one tab and a download of the latest OIG Exclusions list on another. On the OIG list tab, I've inserted a few columns to the left to do a vlookup. Just keep your tab 1 vendor list current as you go and update your tab 2 with the most current OIG list monthly when you're ready to do the check, and in seconds where there is a match, you have an exclusion. While I've been fortunate to not have an exclusion show up, in theory checking both by org name and by key personnel name will flag an area of concern.

    Hardest part is getting through to the HHS website - the site frequently times out for me.

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    Chris Johnson MBA,CHC
    Compliance Officer
    SyMed Corporation
    NAPA,CA
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    2019 HCCA Compliance Institute


  • 4.  RE: Vendor Exclusions

    Posted 03-20-2019 07:54 PM
    Sounds like a workable process you have there!  Well done.

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    ► Study Session Link for CI ◄
    https://www.surveymonkey.com/r/GJSW959
    ►Study Session: April 7th - 8 PM...stay tuned...◄
    --------Frank Ruelas---------
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    2019 HCCA Compliance Institute


  • 5.  RE: Vendor Exclusions

    Posted 03-21-2019 07:59 AM
    ​What type of system does your purchasing or contracting department use? what about your A/P? Depending on the system and its capabilities, you may be able to set something up whereby there is an automated query to compare the vendors in your system with the OIG, SAM, and any other list you may want to look at.

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    Nancy O'Neill, RN, CHC, CHPC
    Director, Corporate Compliance/Privacy Officer
    Tampa General Hospital
    Tampa, FL
    noneill@tgh.org
    Responses are my own and not the view of my organization.
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    2019 HCCA Compliance Institute


  • 6.  RE: Vendor Exclusions

    Posted 03-22-2019 09:50 AM
    Hi Gayla,

    Almost 3,000 organizations use our web app for employee/vendor monitoring.  You can watch vids on our website about how it works, just to get an idea.  Depending on your needs, other service levels & plugins are also available.  If we aren't the best fit, I'd be happy to help point you in the right direction.  Feel free to reach out if you'd like to discuss in more detail.

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    Jon McCollum
    Verify Comply
    www.VerifyComply.com
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    2019 HCCA Compliance Institute


  • 7.  RE: Vendor Exclusions

    Posted 03-22-2019 10:00 AM
    For what it's worth...and Jon can call me out...as I get $0 for making the following statement....

    If given a choice of vendors for the vendor exclusion look up service and I saw Jon's company on the list...I'd start there in getting more info which I would then use to either make my decision or to shop around and compare with other vendors.

    NOTE...I am going to use a vlookup example where the context I will use is looking up names in the LEIE for possible matches as part of Rachel and my session on Tuesday at the CI (#604 on Tuesday).

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    ► Study Session Link for CI ◄
    https://www.surveymonkey.com/r/GJSW959
    ►Study Session: April 7th - 8 PM...stay tuned...◄
    --------Frank Ruelas---------
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    2019 HCCA Compliance Institute


  • 8.  RE: Vendor Exclusions

    Posted 03-22-2019 10:32 AM
    What Frank says is true - no conflicts of interest exist.  As a former compliance officer, kickbacks/referral schemes are at top of mind.

    Gayla - It could be that using a spreadsheet would be a reasonable solution for your needs, and if so I certainly wouldn't discourage it.  But whether it's a good fit depends on your technical aptitude, agencies needed, along with other factors - an assessment best discussed.  You know where to find me if you'd like to chat.  :)

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    Jon McCollum
    Verify Comply
    www.VerifyComply.com
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    2019 HCCA Compliance Institute