Important Notice Regarding COVID-19
Effective March 16, 2020, and until further notice, vendors' access to all of our hospitals, clinics and extended campuses, including non-patient care and administrative sites, is restricted. Maintenance and support services requiring a presence on campus in support of direct patient care are permitted; however, in these cases, coordination with the relevant department leader prior to entering any Froedtert Health location is required.
Supplier Compliance Standards and Expectations
As a valued vendor, supplier, partner or contractor with Froedtert Health, it is important that you have an understanding of our standards and expectations as we conduct business together. In addition to the information provided here, you should also communicate with the Froedtert business leader that you are working with to identify any other relevant standards or policies that may be applicable in your unique area of responsibility.
It is important that each member of your team that is working with, at and/or on behalf of Froedtert is committed to upholding our strong reputation, as well as committing to conduct business in an ethical and compliant manner.
We are committed to upholding the high ethical standards by which we do business. We expect our vendors, contractors and agents to read the information below and practice under these general principles. If you or your company have questions that this guide cannot answer or if you have a concern you want to raise, please call the Froedtert Health Corporate Compliance Department at 414-259-0220.
- Code of Business Conduct
- Code of Corporate Ethics [FH-COM.032]
- Compliance Reporting, Hotline and Non-Retaliation Policy [FH-COM.025]
- Cyber-Security Baseline Policy [FH-IT.100]
- Confidentiality Policy [FH-COM.0062]
- Gifts/Business Courtesies To and From External Organizations/Individuals Policy [FH-COM.022]
- Billing Compliance Policy [FH-COM.95] and Whistleblower Protections
Supplier Access and Privileges
Froedtert Health has established requirements for Supplier/Sales Representatives at all Froedtert Health sites relating to access, interaction and business transactions. The intent of these requirements is not to interfere or create a barrier to the collaborative relationships that have been developed over the years with suppliers. Such relationships have been and continue to be important to the advancement of clinical practice, education and research.
Included in the requirements are stipulations regarding the RepTrax supplier management system. All sales representatives are required to check-in, obtain a sales pass, adhere the sales pass to their attire (below the shoulders and above the waist), and check-out of RepTrax upon conclusion of each and every visit.
Proper Billing to Prevent Fraud, Waste, and Abuse
As a healthcare provider, we have requirements and obligations that must be met to bill payers for health-related services. These requirements promote high quality and safe patient care, and help to make sure that providers are not inappropriately or incorrectly billing for services. Billing for services and supplies is a form of attestation that charges are appropriate and medically necessary and must have supporting documentation that accurately reflects that care and services provided.
Centers for Medicare and Medicaid Services (CMS) defines fraud and abuse in the following manner:
“Fraud” is a willful or intentional act. Examples of fraud in healthcare are:
- Billing for services and/or supplies that are not provided
- Duplicating billings that includes billing the Medicare program and the beneficiary or Medicaid, or some other insurer in an effort to receive payment greater than the amount allowed
- Knowingly submitting false claims
“Abuse” describes practices that, either directly or indirectly, result in unnecessary cost to the Medicare or Medicaid program. Abuse appears quite similar to fraud except it may not be willful or intentional. Some examples of abuse are:
- Charging in excess for services or supplies
- Providing medically unnecessary services or services that do not meet professionally recognized standards
- Billing Medicare based on a higher fee schedule than for non-Medicare patients
- Submitting bills to Medicare that are the responsibility of other insurers under the Medicare secondary payer (MSP) regulation
We require our vendors, contractors and agents to review the Billing Compliance policy that address their role in preventing, detecting and reporting healthcare fraud, waste and abuse. Attached to the policy are documents that outline the False Claims Laws as well as the Whistleblower Protections for individuals who report fraud and abuse to the government after exhausting internal reporting requirements. Our vendors, contractors and agents must provide this information to all of their employees and agents who have contact with our facility related to the delivery or monitoring of healthcare items and services. It is the responsibility of all individuals who work with or provide services to or on behalf of Froedtert to comply with all federal and state laws and applicable Froedtert Hospital policies and procedures.
Confidential Information, Including Protected Health Information ("PHI")
Protecting our confidential business information and our patients’ private health information is of the utmost importance. It is the responsibility of all individuals who work with or provide services to or on behalf of Froedtert Health to comply with all federal and state laws and applicable Froedtert Health policies and procedures regarding proper use, disclosure and protection of confidential information.
Learn More About HIPAA Compliance (includes link to Business Associate Agreement).