Vendor Gifts and Relations: Effective Strategies for Health Systems and Hospitals

Table of Contents

• CMS Floats Exception to Stand-in-the Shoes Provision in Stark, Revives Entity Version
• Contractor Scheme With Hospital Official Bilked Millions From NYPH
• Communications With Agents, Vendors and Contractors
• General Contract Provisions Checklist
• Vendor Gifts & Relations: Hospital Strategies in a New Era of Government Scrutiny (Presentation from AIS Audioconference)
• OIG Says It Needs Industry’s Aid On Device Firms’ Links With Docs
• As Payment Recipient, Hospitals Are Seen as Next Target in Device Enforcement
• Recent Cases Show Perils of Improper Inducements
• Physician Financial Relationships Top List of ’08 Enforcement Areas
• Hartford Hospital, Others Adopt Strict Policy on Vendor Gifts
• Gifts, Gratuities and Business Courtesies Policy
• With Phase III of Stark II Self-Referral Law, CMS Opens Some Doors, Closes Others
• Radical Changes Take Hold in Vendor Gift Policies, Access to Health Care Systems
• Example of Policy on Vendor Gifts, Access
• Henry Ford Policy Requires Vendor Training, Limits Access
• Contract Problems Pose Risk as Feds Push Stark Enforcement
• Preventing Charity Events From Turning Into Enforcement Actions
• Lincare to Pay $10M to Settle Kickback Case; OIG Cracks Down on Kickback Givers, Takers
• Centralize Tracking of Gifts to Comply With Stark Exception
• Conflict of Interest Disclosure Statement
• Hospitals Ask Physicians, Officers for More Details on Conflicts
• With NIH as Model, Organizations Crack Down on Conflicts, Demand Transparency
• Dual Reasons to Conduct Contract Compliance Reviews: HIPAA Business Associates Requirement, Anti-Kickback and Stark Laws
• Guidelines on Drugmaker Gifts to MDs: If It Distracts, It’s No Good
• From Zero Tolerance to Formal Reviews, Organizations Crack Down on Conflicts

Written By

This book was written by the editorial staff of AIS. The audioconference presentation was written by Donald E. Koenig, Jr., vice president and assistant general counsel of corporate responsibility and enterprise risk management for Catholic Healthcare Partners (CHP) in Cincinnati, and Nickie Braxton, corporate compliance officer for Hartford (Conn.) Hospital/Hartford Health Care Corp.

Written For

Compliance officers; attorneys; and financial and operations executives at:

• Hospitals
• Health systems
• Integrated delivery systems
• Medical group practices
• Pharmaceutical companies
• Surgical and medical suppliers
• Consulting firms

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