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It is difficult for large, complex organizations to change a corporate culture that has existed for generations. But after years of vendor generosity — from pharmaceutical and device company-sponsored trips for physicians to questionable vendor activity with board members and materials management — health care systems are now saying “enough.”

Some companies claim that a thing as small as a doughnut can’t possibly sway a physician’s decisions, but mounting evidence shows a connection between vendor gifts and physician choices. DOJ has begun focusing on both physicians and vendors for violations of the Stark physician self-referral and anti-kickback laws. And hospitals may also find their tax-exempt status threatened by such conflicts of interest, which are under greater scrutiny in Washington.

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

Health systems have implemented a wide variety of policies, programs and strategies for addressing these problems. Learn before it is too late which are likely to work effectively for your organization.

• Applicable federal laws/regulations, including the anti-kickback statute and the False Claims Act, and the government’s enforcement interest in vendor relations.
• Other related challenges for hospitals, including IRS tax-exempt status, challenges to supply-chain process integrity, and vendor financial relations.
• Strategies you can incorporate into your policy to effectively manage vendor relations.
• How to avoid the pitfalls you might encounter when implementing new vendor gift and vendor relations policies.

Speakers

DONALD E. KOENIG, JR. is vice president and assistant general counsel of corporate responsibility and enterprise risk management for Catholic Healthcare Partners (CHP) in Cincinnati. Ohio’s largest integrated health care system, CHP is the nation’s seventh largest tax-exempt health system, with 36 hospitals, 16 long-term care facilities and 50 additional health entities in five states. Mr. Koenig oversaw the creation of the corporate responsibility program for CHP, and he has led that effort since 1998. He is a lead partner in the consortium that developed Internet-based compliance education courses in use at more than 500 hospitals nationwide. Mr. Koenig is a frequent author and speaker on topics such as measuring the effectiveness of compliance programs and the Sarbanes-Oxley Act impact on tax-exempt health care. A former Navy Judge Advocate before joining CHP, he also served as a special assistant U.S. attorney in Mississippi and Maryland. Mr. Koenig received his B.A. from George Washington University and his J.D. from the George Washington University Law School.  
 
NICKIE BRAXTON is corporate compliance officer for Hartford Hospital/Hartford Health Care Corp. Located in Hartford, Conn., Hartford Health Care Corp. provides a variety of health services through a network of hospitals, behavioral health centers, nursing facilities and numerous community health and wellness programs for the residents of Hartford and surrounding communities in northern Connecticut. Ms. Braxton is responsible for oversight and development of Hartford Health Care Corp.’s multi-facility compliance program and for daily operations of the compliance program at Hartford Hospital, a not-for-profit 860-bed multi-site acute-care facility. She has also served as deputy chief compliance officer for North Shore L.I.J. Health System and as corporate compliance officer and vice president for legal services for Masonicare. Ms. Braxton received her B.A. from Wesleyan University and her M.A. from the University of Massachusetts, Amherst.

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

Designed Especially 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

Written Materials