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.
Supplier Guide Policy
In addition to the Vendor Code of Conduct, BJC HealthCare has developed a Supplier Guide Policy to establish BJC HealthCare’s minimum guidelines, policies, requirements and expectations for suppliers, their employees, representatives or agents to comply with while engaging in business with, contacting or visiting BJC HealthCare employees, representatives or facilities.
In addition to these policies, suppliers must comply with Washington University and any other BJC HealthCare partner or affiliates’ policies related to interactions with suppliers as well as any laws, regulations or location specific policies which may be more restrictive than those in this Supplier Guide Policy.
Failure to meet these policies may result in loss of payment for supplier’s products or services as well as corrective action ranging from a warning to discontinuation of business engagements with the supplier.
The Supplier guide Policy is located here.
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.
Read the Informational Policy Concerning False Claims Laws