Chief Compliance and Ethics Officer Health Care

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Vendor and Contracted Staff Compliance Requirements

  • 1.  Vendor and Contracted Staff Compliance Requirements

    Posted 9 days ago
    I am looking for actual CMS or OIG requirements that indicate our organization must provide our vendors and contracted staff with a copy of our compliance plan and code of conduct. I recently attended a webinar where several attendees shared that they require all vendors and contracted workers to sign off on both of these however, I have searched whether this is required and I can't find anything. I did find that CMS requires that agents and employees should have access to an anonymous hotline to report concerns and should receive a copy of the code of conduct but, the overall requirements are a bit unclear to me still.

    Guidance from the DOJ mentions agents as well but it is not clear what an "agent" is. Is it someone who does work on behalf of the company? e.g., a contracted physician that sees patients within our facility? Versus, our cleaning staff that work strictly at night and have no interaction with patients. We are trying to draw the line on who needs what.

    Kaitlin Ketring
    Executive Assistant & Compliance Officer
    Bone & Joint
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