Chief Compliance and Ethics Officer Health Care

Vendor list exclusions

  • 1.  Vendor list exclusions

    Posted 03-31-2020 11:05 AM
    Can someone help with some clarity of the vendor exclusion requirements/rules. I've heard some say you do every single person who has done business with you, other say only those that involve Medicare, some say they rotate all their vendors and within a year have done all vendors. I'm trying to clean up the process and make it efficient and effective. We have a CCRC- the Health center is Medicare certified only but money flows through the independent living. If you can clarify or point me to refence material I'd appreciate it.

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    Natalie MacBrien
    Compliance Director
    Edgewood Retirement Community
    North Andover,MA
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    2020 HCCA Compliance Institute


  • 2.  RE: Vendor list exclusions

    Posted 03-31-2020 02:56 PM

    We are a hospital and we check all vendors.

    Cinda

     

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    2020 HCCA Compliance Institute


  • 3.  RE: Vendor list exclusions

    Posted 03-31-2020 04:45 PM
    ​We are the same as Cinda - we are a hospital system and we check them all.

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    Ann Dunham
    MBA, SPHR, CHC, CHRC
    Compliance Officer
    Hannibal Regional Healthcare System
    Hannibal, MO
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    2020 HCCA Compliance Institute


  • 4.  RE: Vendor list exclusions

    Posted 04-01-2020 09:19 AM
    ​We too are a health system and check all. HR does initial check, HR sends monthly new hire list to Compliance for check, once per year we have John Sterling do all.

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    Courtney Blau
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    2020 HCCA Compliance Institute


  • 5.  RE: Vendor list exclusions

    Posted 04-01-2020 10:27 AM
    Here's the reference material: https://oig.hhs.gov/exclusions/files/sab-05092013.pdf

    In summary, and barring any more inclusive contractual obligations, vendors that have no direct or indirect ties to governmental healthcare program payments don't need to be monitored for exclusion because there's no repayment or CMP liability.  However, it's often challenging to determine in what capacity each vendor is being used.  As a result, many decide it's easier to monitor all vendors, and if an issue arises, then research how the vendor is being used and whether there's a liability.

    Stay well! :)

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    Jon McCollum
    Verify Comply
    www.VerifyComply.com
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    2020 HCCA Compliance Institute