Recording and written materials of AIS's Webinar on March 10, 2010

Vendor Gifts and Relations: Strategies for Reducing Your Compliance Risks

With both the federal and state governments cracking down on vendor gifts and relations, hospitals and other providers must have clear policies and procedures in place and make sure employees are following them. Some vendor gift conflicts are illegal — they may implicate the Stark physician self-referral and anti-kickback laws — and they create an appearance of impropriety. They also could have an unfortunate influence on patient care decision making. Learn how to identify and manage vendor gifts and relationships, and what successful strategies should be incorporated into your policies and procedures.

Sponsored by Atlantic Information Services, Inc., publisher of Report on Medicare Compliance and A Guide to Complying With Stark Physician Self-Referral Rules

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While some companies claim that it’s impossible that something as small as a doughnut could impact physician decisions, evidence shows otherwise. The HHS Office of Inspector General and Department of Justice are focusing on both physicians and vendors for violations of the Stark physician self-referral and anti-kickback laws. And more states are enacting legislation that requires pharmaceutical and device manufacturers to report gifts and other economic benefits given to physicians and other health care entities.

Hospitals and other providers need a process to identify and manage potential vendor gift conflicts, to help avoid possible compliance minefields and to make sure patient care decisions are not influenced by vendor gift-giving.

• Applicable federal laws and regulations and the government’s heightened enforcement interest in vendor relations.
• Related challenges for hospitals and providers, including challenges to supply-chain process integrity and vendor financial relations.
• Practical strategies hospitals and providers can use and incorporate into their policies and procedures.
• Common challenges your organization may encounter, plus tips on how you can deal with them.

 

Speakers

RICHARD KUSSEROW is CEO of Strategic Management Systems, Inc., a firm that specializes in problem solving and corporate support through fact gathering, analyses and report presentation in the health care industry. Expertise includes fraud-and-abuse abatement strategies, corporate compliance programs, review of arrangements agreements, vulnerability assessments, due diligence reviews, ethics programs and training. The firm also contracts with CMS in providing program integrity expertise for regulatory oversight. Mr. Kusserow served 11 years as the Inspector General for HHS, where he was responsible for all audits and investigations, as well as sanction authority for Medicare, Medicaid and maternal/child health programs. He was a member of the President's Council on Integrity and Efficiency, President's Council for Management Improvement, Chief Financial Officer's Council and Attorney General's Economic Crime Council. He was appointed by the president as a Commissioner on the National Advisory Commission on Law Enforcement. He is a past member of the Attorney General’s Economic Crime Council. He previously was a Special Agent/Supervisor with the FBI for eleven years that included coordinating and supervising the seven squads constituting the Organized Crime Program in Chicago. Mr. Kusserow has published dozens of journal articles and is a frequent speaker at conferences and events.

JULIE CHICOINE is compliance director for the Ohio State University Medical Center, where her responsibilities include oversight of the medical center's integrity and compliance program, and directing system-wide operations and activities relating to compliance with federal health care program requirements. She is an attorney at law and a registered nurse with several years of health care experience. Ms. Chicoine has served both as in-house and external legal counsel for hospitals, providing guidance on coding, billing and reimbursement issues as well as compliance with federal and state regulatory laws for a wide range of hospital services. She has a particular expertise in CPT(r), HCPCS and ICD-9-CM coding practices for diagnosis, procedures and services performed by physicians and other providers. Ms. Chicoine earned her Juris Doctor degree from the University of Houston Law Center. She also holds a Bachelor of Science and nursing degree from the University of Texas Health Sciences Center at Houston. She has written and spoken widely on health care issues, with special attention to regulatory and reimbursement issues.

Moderator: Nina Youngstrom, managing editor of AIS’s Report on Medicare Compliance.

 

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