Vendor Policy

I. PURPOSE

To provide guidelines that give Vendor Representatives  an opportunity to conduct business in a manner that does not interfere with the normal operations of Yale New Haven Health Services Corporation and its affiliates (“YNHHS”), to enhance patient care quality and safety, respect for the confidentiality of information and to ensure a cost effective procurement system that complies with YNHHS contractual and ethical policies and standards while fostering an environment of fair competition with vendor access and control.

II. PROCEDURES

A. Policy

It is the policy of YNHHS that the conducting of business with vendor representatives be initiated and managed through the locally based facility’s Supply Chain Management personnel and YNHHS Corporate Supply Chain Management Department, with special emphasis on all HIPAA requirements to safeguard the privacy and confidentiality of patient health information.

B. Standard procedures

1. All Vendor representatives wishing to conduct business at YNNHS facilities must do so through the Supply Chain Management Department, Pharmaceutical Department, Food Services Department or Facilities/Construction Department.  Vendors who have been authorized as YNHHS business partners by one of these departments and Supply Chain Management, may conduct business, by appointment, with the respective departments, and in accordance with the policy set forth below. Representatives who attempt to conduct business directly with hospital departments or staff  without prior authorization of Supply Chain Management and an appointment will be immediately redirected to the Supply Chain Management Department by the affected department and be considered in breach of this policy.
   
   
2. Vendor Representatives are individuals who market products and services to YNHHS facilities. All Vendor representatives must be fully registered and signed in to the “Vendor Mate” vendor management system upon each visit to the hospital. Representatives are not allowed to conduct business at YNHHS without full registration in the Vendor Mate System.   When fully registered and upon signing into the system upon each visit, the Vendor representative will then be allowed to print a vendor badge with photo ID, that must be worn visibly on a part of the clothing located above the waist. Those representatives who are witnessed not wearing a badge will be questioned by hospital personnel, advised of the policy and immediately referred to the facility’s Procurement Coordinator or other Supply Chain Management personnel.
   
   
3. Vendor representatives are required to adhere to YNHHS policies including but not limited to: HIPAA Policies, The Gifts and Gratuity Policy, Gifts and Business Courtesies from Vendor Policy and the YNHHS Code of Conduct, available upon request. Pharmaceutical representatives are required to adhere to the YNHHS Pharmaceutical Vendor Policy (see below).
   
   
4. Vendor representatives will not be allowed to conduct business on YNNHS property after 5 pm. unless prior arrangements have been made for such activities such as product fairs/demonstrations, in-service programs, or service / repair work.
   
   
5. New products that are introduced will need prior approval / determination of pricing and YNHHS contractual adherence through the Supply Chain Management personnel. The Supply Chain Management Department in collaboration with the requesting department will direct new product introduction through the appropriate hospital and/or Health System committee structure/approval process.  Trials for new product will require prior authorization through the completion and approval of the “New Product Request” form. The request and the form must be generated from a Hospital or Health System employee or a physician and may not be completed by a vendor representative.  At a minimum, the request form will be signed by the user department as well as a member of the Supply Chain Management department for the respective facility or the Health System. New items introduced that would potentially be used by several departments (such as commodity type products) will require review by each facility’s Product Evaluation Committee before a trial is granted.  

C. Violation of Vendor Policy

In the event that a member of the YNHHS staff observes a Vendor or Vendor Representative in violation of policy, the staff member should immediately notify the Supply Chain Management Department.  YNHHS reserves the right to investigate any violations and based upon the severity of the violation shall determine disciplinary action and communicate such actions to the system hospitals as needed.

1. Verbal and/or written warning to the vendor representative and his/her supervisor.
   
   
2. Restriction of all activity and service calls at any YNHHS location for 3 months, 6 months, or 1 year depending on infraction.
   
   
3. Violations committed by any one representative of a given company may result in disciplinary action against any or all representatives of that company.
   
   
4. Repeated Violations by any Vendor or Representative may result in the banning of future visitations by Vendor or a particular Representative for a one year period or indefinitely if warranted.

Guidelines for Pharmaceutical Company Representatives

Definition: Pharmaceutical Company Representative
A Pharmaceutical Company Representative (PCR) shall be defined as a representative of a pharmaceutical company who enters Yale New Haven Health System (YNHHS) to promote the use of products/services which are evaluated and/or purchased by the Department of Pharmacy Services.   

General Code of Conduct for Pharmaceutical Company Representatives

• Any PCR who wishes to access YNHHS facilities and be eligible for business with YNHHS must register in our vendor credentialing and compliance monitoring system (Vendormate). 
  
  
• Upon Vendormate registration, PCR must read and acknowledge acceptance of the YNHHS PCR guidelines as well as any site specific procedures annually.
  
  
• All PCRs visiting YNHHS must sign in and out at one of the Vendormate Kiosk locations.
  
  
• PCRs shall display Vendormate-generated identification badges at all times.
  
  
• The PCR must make an appointment with the secretary or designee of the hospital employee with whom they wish to speak PRIOR to conducting business with that individual.  
  
  
• PCRs may not be present in patient care areas at any time.  Approved appointments must be held in a location that does not require travel through a patient care area.
  
  
• PCRs may not use inter-hospital phones, paging system or inter-hospital mail systems.
  
  
• P&T and its sub-committee members shall not be specifically targeted by PCRs regarding product information or Committee business items.

Disbursement of Drug Information

• PCRs shall first inform the Department of Pharmacy Services of new drugs they wish to discuss at YNHHS.
  
  
• Information changes pertaining to medications on formulary (i.e. indications, dosage, routes of administration, formulations, etc.) shall be provided to the Department of Pharmacy Services prior to discussion with other YNHHS personnel. 
  
  
• All pharmaceutical detailing shall be within the context of P&T approved criteria for restricted drugs, as it relates to the specific hospital.   
  
  
• PCRs shall limit discussions of restricted drugs with those authorized to prescriber as noted in the P&T approved criteria and designated pharmacy staff.  
   
• At no time shall PCRs detail non-formulary drugs or indications not included in the YNHHS criteria or specific hospital criteria without approval from the Director of Pharmacy Services or his/her designee.
  
  
• Non-formulary categories include the following: drugs not yet reviewed by the P&T Committee, drugs reviewed and denied addition, and off-criteria indications of restricted formulary drugs.
  
  
• All information and materials distributed at YNHHS must be approved by the Director of Pharmacy Services or his/her designee prior to distribution.
  
  
• Product package inserts and peer-reviewed journal articles that are not company labeled may be distributed only when attached to the YNHHS Criteria for Use to highlight differences between FDA approved indications and YNHHS approved indications.

Educational Activities 

PCRs are not permitted to attend or provide educational in-services at YNHHS unless prior approval is obtained by the Director of Pharmacy Services or his/her designee.

• PCRs may not post and YNHHS will not advertise industry-sponsored events that are not CME/CE accredited or fail to comply with the Yale School of Medicine Conflict of Interest Policy, Accreditation Council for Continuing Medical Education (ACCME), or Accreditation Council for Pharmacy Education (ACPE) standards.    

Violation of Guidelines

• Violations of PCR guidelines shall be reported to the respective Director of Pharmacy Services.
  
  
• Based on the severity of the violation, the Director of Pharmacy Services or his/her designee shall determine disciplinary action and communicate to the system hospitals as needed.
  
  
• The Director of Pharmacy Services shall impose one or more of the following restrictions on an PCR found to be in violation of the guidelines:
  
  
  • Verbal and/or written warning to the PCR and his/her supervisor.
    
    
  • Restriction of all activity and service calls at any YNHHS location for 3 months, 6 months, or 1 year depending on infraction.
    
    
  • Letters to the PCR, his/her supervisor, and to the Vendor Director of the pharmaceutical company stating that the PCR is no longer permitted on the hospital and/or YNHHS premises for a specified time frame.
    
    
• Violations committed by any one representative of a given company may result in disciplinary action against any or all representatives of that company.