Vendor Compliance

Supplier Compliance with CMS First-Tier, Downstream, and Related entities ("FDRs")

The Centers for Medicare & Medicaid Services (CMS) has instituted compliance program requirements for First-Tier, Downstream, and Related entities ("FDRs") that provide administrative or health care services for Medical Advantage beneficiaries. UPMC providers are First Tier entities with respect to Medicare Advantage beneficiaries because they are participating providers in Medicare Advantage plan networks and directly contract with such plans.

As a First-Tier entity, UPMC is required to effectively manage and oversee the compliance of our Downstream and Related Entities. This notice provides an overview of those compliance requirements. Learn more about this policy.

Tobacco-free Policy

Effective July 1, 2014, UPMC will no longer permit employees, physicians, volunteers, contractors, students, and others acting for UPMC from smoking or using tobacco products during their work shift. This policy stance expands the already existing smoke-free campuses throughout UPMC. In conjunction with our mission of supporting healthy lifestyles, we join other like-minded health care leaders such as Baylor Health Care System, Cleveland Clinic, and Mayo Clinic in committing to a healthy environment for patients, visitors, and staff.

Why is UPMC going tobacco-free?

• Our mission as a health care organization is to support and promote healthy lifestyles throughout our communities. According to the Centers for Disease Control and Prevention, tobacco use is the single most preventable cause of disease, disability, and premature death in the United States. It's time for us to lead by example within our region.
• We are committed to maintaining a healthy environment for patients and visitors, and ensuring their experience with us is positive by reducing their exposure to tobacco products.
• We are committed to a healthier workforce. Our people are our greatest strength, and their health is important to all of us so we can continue to provide world-class care to our patients.
• We want to be good neighbors. Our campuses have been smoke-free since 2007. This is a natural evolution of that commitment.

About the policy changes

Tobacco use, including smoking, by all employees, physicians, volunteers, contractors, students, and others acting for UPMC will be prohibited during all shifts. For our staff, a work shift will be defined as the time staff members report to work until the shift is over, including paid and unpaid breaks whether taken on or off campus.

No Purchase Order No Payment Policy

UPMC Supply Chain Management is implementing a NO PO NO PAY policy. Under this policy your invoices must contain a valid UPMC purchase order number or they will not be processed for payment.

A reference guide for a valid UPMC Purchase Order number is as follows:

1. The PO Number is numeric with 10 Digits
2. The PO Number has 3 leading zeroes
   Example: 0001234567

Items not requiring a purchase order are limited items such as: books and periodicals, organ acquisition, postage, and tax/government payments.

Compliance Helpline

UPMC is committed to combating fraud, abuse, and waste in health care. Through the Compliance Helpline, employees and vendors who do business with UPMC can report potentially criminal activities or violations of UPMC policy. Calls to the Helpline are answered by independent third-party communications specialists who assign your call a private code number that you may refer to during any follow-up calls. This allows you to remain anonymous. All calls are handled in confidence and are not recorded.

The Helpline specialist will document the information reported during the call and generate a written report that will be forwarded to the compliance officer of the appropriate UPMC entity. After reviewing the report, the compliance officer will initiate an investigation to determine if corrective action is required.

The toll-free Helpline is available 24 hours a day, seven days a week, at 1-877-98ETHIC (3-8442).

Vendor Access Practices to UPMC Facilities

ProTech Compliance is a technology and services company that provides the health care industry and vendors serving the industry with simple, cost-effective, and reliable technology solutions for managing vendor-client relationships, including the credentialing and certification process, compliance standards, facility security, scheduling, tracking, and reporting. Vendor representatives can register via www.protechcompliance.com. For more details, contact ProTech Compliance Customer Service at 1-877-710-STAT (7828) or via e-mail to admin@protechcompliance.com.

Conflicts of Interest and Interactions Between Representatives

It is the policy of UPMC, jointly with the University of Pittsburgh Schools of the Health Sciences (SOHS), that clinical decision-making, education, and research activities be free from influence created by improper financial relationships with, or gifts provided by, Industry. For purposes of this policy, “Industry” is defined as all pharmaceutical manufacturers, and biotechnology, medical devices, and hospital equipment supply industry entities and their representatives. Learn more about this policy.

Vendor Responsibilities Under the Deficit Reduction and False Claims Acts

In accordance with the federal Deficit Reduction Act, UPMC is required to inform vendors about the Federal False Claims Act. UPMC encourages its vendors to read and be familiar with the federal guidelines as they pertain to this important issue. The Deficit Reduction Act also requires UPMC to provide vendors with information about whistle blowing and non-retaliation. As part of its Reporting and Non-Retaliation policy, UPMC prohibits retaliation for reporting instances of wrongdoing, made in good faith. Suspected instances of wrongdoing may be reported through the Compliance Helpline (1-877-98ETHIC). To help you understand your responsibilities as a vendor of UPMC, please review the excerpt of UPMC's False Claims policy.