Vendor Ethics and Compliance
We live and work in a highly regulated environment. Federal and state privacy laws protect the privacy of identifiable student, consumer, and health care information. Intellectual property laws protect the contributions we make to science and learning. Research laws and related accreditation standards impose a broad range of requirements for protecting individuals who volunteer to participate in clinical trials and other studies. Occupational health and safety laws are designed to protect workers from on-the-job hazards. And federal fraud and abuse laws seek to promote efficiency and avoid waste in federally funded programs, such as health care programs like Medicare and Medicaid, and research programs supported by the U.S. Public Health Service.
The University of Michigan Health System and other University health care delivery units have implemented various compliance programs that help ensure that our facilities meet federal safety regulations, our health care providers are properly trained, patients participating in research are protected, and our vendors do not improperly influence our purchasing decisions.
Code of Conduct. To assure vendor compliance with the UMHS policies, vendor representatives who work on site with University health care providers or who have access to sensitive information created or maintained by those providers are required to follow the UMHS Code of Conduct and Compliance Program and execute our Code of Conduct Attestation. Vendors furnishing goods and services to University health care providers are required to comply with University policies designed to promote ethical conduct and facilitate regulatory compliance. Some of those policies are available through the policy link on the left-hand toolbar. Other policies are highlighted below:
Conflict of Interest. The University’s Conflict of Interest and Conflict of Commitment policies were implemented to maintain public trust, promote integrity and honest in all areas of decision-making as well as to ensure appropriate use of University and UMHS facilities and resources. By entering into an arrangement with the University, each Vendor represents and warrants that to the best of Vendor’s knowledge, information and belief, there exists no actual or potential conflict of interest between Vendor (or any of its affiliates) and the University (or any of its employees or contractors, or their respective family or household members). In the event of a change, each Vendor must promptly inform the University Director of Purchasing or Purchasing Services designee of any potential conflict of interest that may arise.
Fraud and Abuse Prevention and Detection. Detailed information about the federal and state fraud and abuse laws, as well as information about whistleblower protection, is available here (PDF). Any Vendor with concerns about University or its employees’ compliance with any applicable laws or policies must promptly contact the University of Michigan Compliance Hotline at 866-990-0111 (or such other numbers as may be provided by the University through this website) and provide details concerning the suspected wrongdoing sufficient to facilitate an investigation by the University.
Vendor Visitation and Interaction Policies. Vendors that conduct business at or with the University of Michigan Health System (UMHS) must do so in a way that protects patient confidentiality and does not interfere with the process of patient care. Vendors agree as a condition of their engagement to adhere to the Vendor Visitation Policy when conducting business with any UMHS unit or representative.