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Vendor Compliance

Compliance Helpline

UPMC is committed to combating fraud, abuse, and waste in health care. 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.

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 1‑877‑983‑8442.

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 1-877-710-7828 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 conflicts of interest.

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.

Potential Vendor Responsibilities Under OFCCP Regulations

With many UPMC entities holding federal contracts, UPMC encourages its vendors to determine whether affirmative action regulations apply to them. Affirmative Action is a requirement of a federal contract or purchase order between the contracting entity and the federal government. Affirmative Action and the laws behind it, enforced by the Office of Federal Contract Compliance Programs (OFCCP), require federal contractors and subcontractors to take positive steps to recruit, hire, promote, and retain protected individuals. Depending on the dollar amount of a federal contract or subcontract, the contractor may have to make and be prepared to report on affirmative action efforts. Basic obligations require contractors to take affirmative steps to prohibit discrimination on the basis of race, color, religion, sex, sexual orientation, gender identity, and national origin, or because of a person's status as a qualified individual with a disability or a covered veteran. To help you understand your responsibilities as a vendor of UPMC, please review the many contractor assistance tools at the OFCCP’s website.

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.