Vendor Code of Conduct
BJC HealthCare (BJC) is dedicated to maintaining excellence and integrity in all aspects of its professional and business conduct and operating in accordance with applicable laws and regulations. BJC Corporate Compliance programs support this commitment to ethical conduct by setting forth guidelines designed to prevent and detect violations of law. We expect all vendors, contractors and agents to honor this commitment and abide by the provisions of this Vendor Code of Conduct as a condition of doing business with BJC.
Privacy, Confidentiality, & Information Security
Wireless technologies, including cell phones, computers, PDAs, tablets, pagers and other devices that may emit electromagnetic interference are prohibited in patient care areas. Supplier representatives are strictly prohibited from taking photographs of patients or confidential information. Computer use is restricted to official business and must be related to the reason for the visit in permitted areas.
All suppliers with access to BJC files, whether physical or electronic, must first obtain the appropriate approvals by strategic sourcing and, if applicable, by BJC Information Technology.
Suppliers with access or exposure to any proprietary or confidential BJC information including patient information, product information, pricing, costs and business plans must execute an appropriate confidentiality agreement and BAA, if applicable. Any violation of privacy or confidentiality by suppliers will be considered a material breach of conduct and contract.
Confidential or patient information must not be discussed at any time within or outside BJC facilities.
Official business matters including pricing and contracts are considered confidential information.
Suppliers are required to conduct their business activities in compliance with all applicable laws and regulations, including laws that are applicable to individuals and entities receiving Medicare, Medicaid and other federal funds.
To ensure compliance, coordination of pricing, distribution and consistency with best practice exchange team decisions, suppliers are prohibited from negotiating pricing or terms and conditions for any supplies, services or equipment with departments other than strategic sourcing. Only those quotations or bids sent or copied to strategic sourcing will be assured of consideration.
Exclusion from Participation in Federal HealthCare Programs
The Office of Inspector General (OIG) was established in the U.S. Department of Health and Human Services to identify and eliminate fraud, waste, and abuse in the Department's programs. The OIG has been given the authority to exclude from participation in Medicare, Medicaid and other Federal health care programs individuals and entities who have engaged in fraud or abuse, and to impose civil money penalties (CMPs) for certain misconduct related to Federal health care programs.
If a health care provider arranges or contracts (by employment or otherwise) with an individual or entity who is excluded by the OIG from program participation for the provision of items or services reimbursable under such a Federal program, the provider may be subject to CMP liability if they render services reimbursed, directly or indirectly, by such a program.
To conduct business with BJC HealthCare, a vendor must agree that: it has not been convicted of a criminal offense related to health care, it is not currently listed by a federal or state agency as excluded or otherwise ineligible for employment by an entity that receives federal health care funding, it is not currently listed on the General Service Administration (GSA) List of Parties Excluded from the Federal Procurement and Non-Procurement Programs or the Office of Inspector General (OIG) List of Excluded Individuals/Entities (LEIE), and in the event vendor becomes excluded by the GSA or OIG from participating with a federal healthcare program or providing services to an entity that receives federal health care funds, it shall notify BJC as soon as possible thereafter.
Deficit Reduction Act of 2005 ("DRA") Requirements
The DRA requires us to provide information to our contractors and agents regarding the Federal False Claims Act, administrative remedies for false claims and statements, applicable state false claims provisions, and whistleblower protections under these laws.
Vendor agrees that:
- It will review the Informational Policy Concerning False Claims Laws ("Policy") that addresses our role in preventing and detecting health care fraud, waste and abuse. The Policy is available online or contact us to email a copy. (The Policy is in PDF format and requires Adobe Acrobat Reader. If you don't have this software, go to Adobe for a free download.)
- It will provide this information to all of its employees and agents who have contact with our facilities related to the delivery or monitoring of Medicare and Medicaid health care items and services, billing or coding functions.
- It is the responsibility of all individuals who work with or provide services to or on behalf of BJC to comply with all federal and state laws and applicable BJC policies and procedures.
Vendor further understands that participation in conduct or practices that violate the terms or spirit of this Code of Conduct may result in termination of its business relationships with BJC.
INFORMATIONAL POLICY CONCERNING FALSE CLAIMS LAWS