Table of Contents
Vendor Access Policy 3
Vendor Code Of Conduct 7
Vendor Access Guidelines 8
Vendor Identification Badges 12
Vendor Identification Badge Requirements 13
Vendor Procedure for Restricted Patient Care Areas 14
Obtaining a Vendor Badge 16
Vendor Representative Sign-In/Sign-Out Procedure 17
Vendor Profile Record 18
General Confidentiality Statement 20
Vendor Gift Disclosure Form 21
Vendor Access Programs FAQs 22
MedStar Health Hospitals 23
Vendor Access Policy
Purpose
To state MedStar Health’s specific rules for access and activities of all vendor representatives at MedStar Health patient care facilities.
Policy
All vendor representatives doing business at a MedStar Health patient care facility will comply with the established access requirements and policies associated with providing products, services or equipment. Any product, service or equipment brought into a MedStar Health facility not meeting these requirements will be considered a donation to MedStar Health for which there will be no remuneration. Badges are not transferable and can be used only by the representative to whom they are issued.
Scope
This policy applies to any vendor representative providing educational support, service, products, intraoperative blood salvage and/or equipment to any MedStar Health patient care facility. This policy does not apply to temporary clinical or physician staff, volunteers, construction workers.
Definitions
1. Vendor Representatives:
Vendor representatives are personnel employed by any company from whom MedStar Health purchases or will purchase services, products and/or equipment.
2. Vendor Access Program Administrator:
MedStar Health employee responsible for overall management of vendor access program.
3. Vendor Photo Identification Badge:
Photo identification badges will be issued by MedStar Health Corporate Materials Management Department to representatives having repeat business at MedStar Health facilities. Requirements for these badges are listed in the Vendor Access Program packet.
4. 24-Hour Vendor Identification Badge:
24-hour badges will be issued at individual MedStar Health facilities for representatives needing access to a MedStar Health facility two or fewer times annually. Authorization by a MedStar Health department manager is required to enter patient care areas with a 24-hour badge.
5. Vendor Access Program Packet
MedStar Health will provide online access to the requirements, forms, procedures and policies related to the vendor access program.
Responsibilities
1. Vendor Program Administrator
1.1. Manage corporate vendor database or Business Outsourcing Partner
1.2. Provide Vendor Access Program Packets to any new vendor representative.
1.3. Communicate infractions of vendor policy to representative and their employer.
1.4. Communicate any infraction involving a breach of patient confidentiality to the Corporate Privacy Officer.
2. Department Directors at MedStar Health Facility
2.1. Communicate as needed with representatives and the program administrator.
2.2. Coordinate and manage meetings with vendors.
2.3. In conjunction with the Product Standardization and Pharmacy and Therapeutics Committees manage and facilitate product or equipment trials.
2.4. Provide information regarding infractions by vendor representative(s) to Program Administrator for appropriate documentation and action.
2.5. Communicate any infraction involving a breach of patient confidentiality to the Corporate Privacy Officer.
3. Hospital Departments-All Hospital Employees
3.1. MedStar Health employees should meet with vendor representative only if they have a scheduled appointment.
3.2. All MedStar Health employees are responsible for identifying noncompliant vendor behavior and reporting this to their manager.
4. Vendor Representatives
4.1. Complete all requirements as listed in the Vendor Access Information Packet. No vendor representative badges will be issued until documentation has been completed. The Packet includes:
4.1.1. Vendor Access Policy
4.1.2. Vendor Code of Conduct
4.1.3. Vendor Access Guidelines
4.1.4. Vendor Procedure for Restricted Patient Care Areas
4.1.5. Vendor Badging Procedure
4.1.6 Vendor Sign-in/Sign-out Procedure
4.1.7 Vendor Profile Record
4.1.8 Confidentiality Statement
4.1.9. Vendor Gift Disclosure Form
4.2. Display vendor representative identification badge at all times while in any MedStar Health facility.
4.3. Comply with all MedStar Health policies regarding patient safety, confidentiality, infection control and risk management.
Exceptions
This policy does not apply to physician offices. Application to outpatient settings will be made by local administrators. Other exceptions may be made by authorized MedStar Health employees in emergent situations.
What Constitutes Noncompliance
Noncompliance includes but is not limited to violation of any of the requirements cited in the MedStar Health Vendor Access Information Packet:
· Vendor Code of Conduct
· Vendor Access Guidelines
· Vendor Badge Procedure
· Vendor Sign-in/Sign-Out Procedure
· Confidentiality Statement
· Vendor Gift Disclosure Form
Any violation of federal, state or other regulatory laws may lead to the termination of the contract or business relationship. MedStar Health may report these violations to the appropriate agency, which could lead to consequences under the appropriate law.
Explanations and Details/Examples
Badges are valid for as long as services are authorized and requirements are met. The representative must submit documentation of compliance or surrender their badge to MedStar Health Corporate Materials Management. If an event occurs that is in violation of the badge requirements, it is the responsibility of the representative’s employer to notify Corporate Materials Management in writing. The badge must be surrendered. The company is required to surrender the badge on the transfer or termination of a representative.
1. Vendor Identification Badge
Photo identification badge will be issued by the MedStar Health Corporate Materials Management Department to representatives having business at MedStar Health patient care facilities. The badge color will denote the level of access allowed to the representative. The badge contains: the company name, vendor representative’s name, vendor representative identification number and picture. Badge colors reflect the following access levels:
1.1. Green Vendor Badge – Level I:
Allows access to non-patient care areas only, i.e. Lab area, offices, etc
1.2. Blue Vendor Badge – Level II:
Allows access to limited patient care areas, i.e. patient care units, Pharmacy
1.3. Red Vendor Badge – Level III:
Allows access to restricted patient care areas, i.e. Inpatient and Outpatient Perioperative units, Imaging Departments, Emergency Department, etc.
All access is limited to an appointment confirmed by an authorized MedStar Health Representative.
2. 24-Hour Vendor Identification Badge
Badge issued at individual MedStar Health patient care facilities for representatives who occasionally need access to a MedStar Health facility.
If a Representative needs access more than two times annually, they need to meet all of the requirements for a Vendor Representative Identification Badge.
24-hour badges can be obtained from the facility’s security department or desk.
Requirements and Guidelines for Implementing the Policy
Corporate Materials Management and Hospital Department Directors will be responsible for managing and enforcing the Vendor Representative Access Policy.
Guidelines for Vendor Representatives
No product, service, equipment, drug or information will be introduced to a MedStar Health facility until it has met all of the approval criteria from MedStar Health or other applicable government agencies.
No drug samples will be distributed in any MedStar Health facility without the approval of that facility's Director of Pharmacy.
Representatives will abide by all HIPAA regulations and restrictions regarding patient confidentiality.
In case of a lost badge, Corporate Materials Management must be notified by the representative within 24 hours. During non-business hours, hospital security may be notified.
Reference to Laws or Regulations of Outside Bodies
HIPAA
Right to Change or Terminate Policy
Proposed changes to this policy will be discussed with all affected parties at both MedStar Health entities and corporate levels of the organization.
The corporation’s policies are the purview of the Chief Executive Officer (CEO) and the CEO’s management team.
The CEO has the final sign-off authority on all corporate policies.
Vendor Code Of Conduct
MedStar Health requires all vendors to adhere to the MedStar Health Code of Conduct (see attachment) and related policies and procedures.
MedStar Health strives to exercise the highest standards of conduct in working with vendors. We expect that our vendors will also use these same high standards when conducting business with MedStar Health.
· Vendors will keep patient and business information confidential.
· No vendor will seek the attention or time of MedStar personnel without an appointment.
· Vendors will not request anyone other than a designated member of Materials Management, Perioperative Services, Facilities or Pharmacy Departments to sign any type of purchasing agreement or contract. Agreements or contracts signed by a non-authorized MedStar agent will be considered non-binding. No agreement will be deemed valid until all MedStar Health contract conditions are met.
· All contract negotiations and interactions between MedStar Health and vendors/suppliers shall be conducted in a manner that avoids the violation of any law or regulation and the appearance of impropriety.
· Vendors will observe the general hours of operation of each facility. Access shall be limited to 9:00 AM to 5:00 PM unless other arrangements have been made through Materials Management, Perioperative Services, Pharmacy or other involved department.
· Vendors will not demonstrate any supplies, equipment or pharmaceuticals to staff on site without approval by that department manager.
· On each visit, vendors will be required to register upon arrival and sign out upon departure at a designated site(s) in each facility. (See Vendor Representative Sign-in/Sign-out Procedure in Vendor Information Packet.) During the visit, representatives will be required to display the appropriate MedStar Health-issued photo ID or 24-hour badge.
· Gifts or inducements of any kind are subject to the limitations of the MedStar Health Code of Conduct. Any violation could negatively impact future business. Violation of federal or state laws or other regulator agencies may result in MedStar Health reporting these violations to the appropriate agency.
· Vendors not compliant with MedStar Health Corporate and Hospital policies, procedures, including, Department Dress Code, Fire and Safety, etc. and Code of Business Conduct will lose their opportunity to access MedStar Health facilities.
Date
Print Name
Vendor Access Guidelines
MedStar Health views vendor representatives as partners in support of our mission to provide the highest quality patient care in the safest environment. Our staff recognizes vendor representatives as a key resource in supporting high quality, cost-effective solutions and technologies.
Supply Chain Strategy
In support of the MedStar Health’s “patient first” core philosophy, the supply chain strategy is to create an effective supply chain operating model that will produce sustainable cost reductions, support high customer service standards, consolidate the supply chain infrastructure and standardize business practices. Vendors are expected to be in compliance with all applicable laws and regulations.
Materials Management Goals of Service
1. Provide optimum support to our caregivers by providing them with timely accessibility of appropriate, clean, safe, user-friendly products, equipment, and services.
2. Have a clear understanding of and maximum influence over all elements of supply chain cost.
3. Maximize understanding of and support for current and emerging technology.
4. Work with trading partners to enhance each other’s quality of service and cost profile.
Participation in the Vendor Program
MedStar Health will institute specific vendor requirements to participate in MedStar Health’s Vendor Representative Program. Areas of access levels are:
Level I Access – Green Badge
· All non-patient care areas, i.e., Laboratory, offices, etc.
Level II Access – Blue Badge
· Inpatient and Outpatient Nursing units
Level III Access – Red Badge
· Inpatient and Outpatient Perioperative areas
· Labor and Delivery departments
· GI Endoscopy areas
· Cardiac Catheterization and EP labs
· All Imaging areas to include Interventional, Diagnostic and Nuclear Medicine
· Emergency departments
No vendor may access a patient care facility without making prior arrangements per MedStar Health’s Vendor Access Policy.
Visitation Rules
Authorized MedStar Health employees in emergent situations may grant exceptions.
Visitation to a MedStar Health facility is by invitation only and will require a scheduled appointment. Under no circumstances will a vendor representative be permitted to visit MedStar Health staff without a scheduled appointment.
All vendor representatives are required to register at the Security Department or desk prior to conducting business at MedStar Health. All vendor representatives are required to check out of the site on completion of business. See Sign-in/Sign-out Procedure.
After checking in, vendor representatives are authorized to visit only the areas designated by their badge for their scheduled appointment. Vendor representatives may be present in common areas of the facilities; however, initiating unsolicited contact with clinicians or other employees is prohibited. At the completion of the scheduled appointment, vendor representatives are expected to leave the facility.
Vendor Identification Badges are not transferable. At no time may a representative allow the use of his/her badge by another individual. To do so will result in the loss of access to any MedStar Health facility.
Vendor representatives are prohibited from access to confidential patient or product information unless it has been authorized as part of the information needed to complete their project. Only vendor representatives with appropriate clearance (Red or Blue Badge) may visit patient care areas and only when an appointment has been scheduled.
Vendor representatives are required to wear a MedStar Health-issued Vendor Identification Badge at all times while in a MedStar Health facility.
Vendor Identification Badges do not grant permission to provide direct patient care or indicate that MedStar Health or its facilities have approved the representative to provide such care. Only individuals who have met all applicable MedStar Health/facility requirements regarding credentialing, clinical privileges and/or other qualifications are permitted to provide direct patient care. Vendor representatives who are present while patient care is being rendered must always follow the direction, when given, of the attending physician or other MedStar Health/facility clinician involved in the procedure.
Vendor representatives are prohibited from displaying company information or advertisements without prior permission from the appropriate facility leadership, i.e., the Director of Materials Management or Pharmacy.
Vendor representatives are not permitted to park in areas designated for patients. Representatives must park in designated visitor parking areas and pay the appropriate parking fees. Some facilities may have additional parking restrictions, which the representative should observe. Vehicles parked in unauthorized areas will be towed at the driver’s expense.
Product Standardization/Utilization