by David Hermann

At this point in the industry, vendor representative credentialing is difficult to
define. At its most general, vendor representative credentialing is a process where sales and service representatives undergo some form of verification before they are permitted into the hospital or sensitive patient-care areas such as the operating room.

The issue gets complicated because the process of verification, as well as the information that is verified, can be quite different from hospital to hospital or from one vendor representative credentialing company to another. This verification can include criminal background checks, checks to see if the representative is among those in the Office of the Inspector General’s (OIG) List of Excluded Individuals/Entities, checks for vaccination histories and many others. It can also involve hospital-specific elements, such as infection control training, vendor orientation sessions and HIPAA policy compliance. In order to know what a hospital system needs to implement, it is important to understand why vendor rep credentialing is needed.

There are several major reasons why hospital supply chains should credential and track the vendor representatives that call on their organizations:

• Health systems are physically and operationally complex entities with multiple entry points and often off-site purchasing departments

• New products are introduced to physicians before the purchasing department knows the vendor was on-site

• Regulatory agencies are increasing their requirements for hospitals to credential their vendors

• Patient safety demands that vendors are properly vaccinated, healthy and free from a criminal background

Within the vendor representative population, the ones who require the highest levels of credentialing are physician preference item (PPI) manufacturers and resellers since they are granted the greatest levels of access to sensitive patient care areas and information. Additionally, they provide the greatest risk of introduction of new and possibly unapproved technology to the organization.

Vendor representative credentialing is increasingly an important regulatory issue. The two most significant regulators are the Center for Medicare and Medicaid Services (CMS) and The Joint Commission. Most supply chain managers know that Congress mandated CMS and the OIG to prohibit any hospital system participating in a federally-funded health program from doing business with any party listed in the OIG’s List of Excluded Individuals/Entities. This is a critical part of any vendor rep credentialing program.

The Joint Commission has regulations, both in-force and proposed, which address the need for oversight and credentialing of vendor reps in the healthcare setting. For example, The Joint Commission announced in April 2007 that an explicit standard for oversight of vendor representatives has been approved for field review and, at press time, the wording for this proposed standard would soon be released. In addition to the explicit standard, there are at least two other Joint Commission regulations that can be loosely interpreted to require credentialing and tracking of vendor reps:

• The 2009 Proposed Standard LD.3.40 requires that the hospital provides accurate and usable information related to safety and quality to those who need it, including staff, licensed independent practitioners, patients, families and external interested parties.

• The 2007 National Patient Safety Goal No. 7 is to reduce the risk of healthcare-associated infections which can imply the need for assurance around vaccinations and history of diseases communicable within the context of a sales representative’s activities.

In addition to the increase in regulation, numerous professional associations and industry organizations have begun to form positions on the subject of vendor management and representative credentials. The two most influential of these statements have come from the Association of periOperative Registered Nurses (AORN) and the American College of Surgeons (ACS).

In its statement titled "The Role of the Healthcare Industry Representative in the Perioperative Setting," AORN states that "patients have the right to be informed about the presence of a health care industry representative in the perioperative/invasive procedure setting during a surgical procedure according to local, state and federal regulations" and that "healthcare facilities should incorporate the local, state and federal regulations regarding health care industry representatives in their perioperative/invasive procedure setting."

ACS’s "Statement on Health Care Industry Representatives in the Operating Room" indicates that the hospital system should provide an authority which authorizes and oversees vendor reps. This oversight should include identification badges as well as orientation and training regarding the facility, HIPAA compliance, conduct and attire in the OR, aseptic principles, infection control, occupational safety and other applicable practices.

In the marketplace, there are many vendor representative credentialing companies that will partner with your hospital system and provide varying degrees of services and tools. Some of these companies may follow the regulations and guidelines closely and others may provide a different solution with regards to features and process.

With a bewildering amount of choices for solutions and features available, it can be challenging to determine what the best solution for your organization is. While a comprehensive set of RFP questions can easily fill dozens of pages, the following list can be a guide:

• Does the solution provide value to hospitals and IDNs? Does the solution fit the problem? Does the solution track the vendor company or the vendor reps?

• Is it just a tool, or does the service provider offer value-adds and best practices to implement the solution?

• Is the solution easy to implement and maintain?

• Does it have multiple levels of credentialing? This prevents the need to credential the photocopier service representative who only gets access to support offices as thoroughly as the [customer relationship management] CRM representative that gets direct access to the OR.

• What will the cost be to the hospital to start the program up?

• What experience does the service provider have with managing vendor reps in a hospital setting, particularly PPI representatives?

As vendor representative credentialing becomes a critical responsibility of supply chain managers, being informed is the best way to select the optimal solution for your hospital organization. This will ensure you are positioned to meet the challenges ahead.