<p>COLUMBIA/HCA </p><p>DEPARTMENT: Materials Management POLICY DESCRIPTION: Prohibition Against Contracting with Sanctioned Individuals or Companies PAGE: 1 of 2 REPLACES POLICY DATED: Sept. 29, 1998 APPROVED: March 16, 1999 RETIRED: EFFECTIVE DATE: April 16, 1999 REFERENCE NUMBER: MM.001</p><p>SCOPE: All Company facilities including, but not limited to hospitals, ambulatory surgery centers, home health agencies, and physician practices, and all Corporate Departments, Groups and Divisions.</p><p>PURPOSE: To ensure that the Company does not contract with any Sanctioned Individual or Company.</p><p>POLICY: No Company facility, including hospitals, ambulatory surgery centers, home health agencies and physician practices, as well as Corporate Departments, Groups and Divisions, may contract with any individual or company who has been convicted of a criminal offense related to health care or who is listed by a Federal Agency as debarred, excluded or otherwise ineligible for participation in federally-funded health care programs. </p><p>Additionally, pending the resolution of any criminal charges or proposed debarment or exclusion, individuals and companies with whom the Company currently contracts who are charged with criminal offenses related to health care, or proposed for debarment or exclusion, must be removed from direct responsibility for or involvement in any federally-funded health care program. If resolution results in conviction, debarment or exclusion of the individual or company, the Company must immediately cease contracting with that individual or company. </p><p>PROCEDURE: </p><p>1. CEOs, Administrators, and Practice Managers shall designate an individual responsible for checking and ensuring that the Company and its facilities do not contract with any Sanctioned Individual or Company.</p><p>2. The Office of the Inspector General’s Cumulative Sanction Report (OIG Cumulative Sanction Report) is on the Internet in a searchable format on the Office of the Inspector General’s website at http://exclusions.oig.hhs.gov.</p><p>3. The designated individual must compare the name and address of each potential contractor to the OIG Cumulative Sanction Report. Should an individual or company appear on the Report, the Company may not contract with that individual or company until the charges are resolved and it is clear that the individual or company will not be excluded or debarred. </p><p>4. Should an individual or company provide satisfactory evidence that they are not the individual or company that appears on the Report, that individual or company may be </p><p>04/16/1999 COLUMBIA/HCA </p><p>DEPARTMENT: Materials Management POLICY DESCRIPTION: Prohibition Against Contracting with Sanctioned Individuals or Companies PAGE: 2 of 2 REPLACES POLICY DATED: Sept. 29, 1998 APPROVED: March 16, 1999 RETIRED: EFFECTIVE DATE: April 16, 1999 REFERENCE NUMBER: MM.001</p><p> considered eligible to do business with the Company.</p><p>5. The following language is to be included in all Requests for Information (RFIs) submitted to potential contractors:</p><p>“Columbia/HCA complies with all Federal and state laws and regulations including the requirement not to contract with sanctioned individuals or companies. Has your company or any individual employed by your company been listed by a Federal Agency as debarred, excluded or otherwise ineligible for participation in federally funded health care programs?”</p><p>An appropriate response to this question is mandatory before a supplier may be qualified to contract with the Company.</p><p>DEFINITION: For purposes of this policy, a “Sanctioned Individual” or “Sanctioned Company” is any individual or company that is listed by a Federal Agency as debarred, excluded or otherwise ineligible for participation in federally-funded health care programs. </p><p>REFERENCES: OIG Model Compliance Plan for Laboratory, 62 FR 9435-9440 OIG Model Compliance Program Guidance for Hospitals, 63 FR 8987-8998</p><p>04/16/1999</p>