Group Purchasing Code of Conduct
Mar 12, 2016
Premier’s Group Purchasing Code of Conduct sets high standards of conduct regarding appropriate business practices in group purchasing and related matters. The existence of this Code of Conduct helps to further demonstrate Premier’s commitment to ethical business practices in all that it does. The Code covers a broad range of issues, including: Conflicts of interest (corporate, director, employee, member advisory committee, subject matter expert), Communication with and between members and suppliers Contracting practices Existence of mechanisms to ensure understanding of and adherence to these standards Safety, cost containment and clinical comparability Supplier diversity Disclosures to owners, members, suppliers and the public.
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Page 2 Premier, Inc.
CONTENTS
Group Purchasing Code of Conduct Page 3
Updated February 2006
Page 4 Premier, Inc.
Group Purchasing Credo
Preface
Group Purchasing Code of Conduct Page 5
Page 6 Premier, Inc.
GENERAL ETHICS POLICIES 1.a. Commitment to its Members and to the Goals of Quality Medical Care and Cost Containment
(Hanson ref. 1)
1.b. Code of Ethics
(Hanson ref. 2)
1.c. Premier GPOs Shall Comply with Applicable Laws
(HIGPA Code ref. A)
CONFLICT OF INTEREST PROVISIONS
EMPLOYEES OF PREMIER ENTITIES 2.a. No Gifts to Employees
(Hanson ref. 3, Premier Letter ref. 11, HIGPA Code ref. B.1.a.)
Group Purchasing Code of Conduct Page 7
2.b. No Equity Ownership by Employees
(Hanson ref. 4, Premier Letter ref. 11, HIGPA Code ref. B.1.b.)
2.c. Insider Trading
(Hanson ref. 15)
DIRECTORS AND OFFICERS
3.a. No Gifts to Directors and Officers Who Can Influence Contracting
(Hanson ref. 6, HIGPA Code ref. B.2.a.)
3.b. Directors and Officers to Recuse Themselves if They Have Received Gifts
(Hanson ref. 7, HIGPA Code ref. B.2.a.)
3.c. Disclosure by Directors and Officers of Equity Interests
(Hanson ref. 8, HIGPA Code ref. B.2.b.)
3.d. Directors and Officers to Recuse Themselves if They Have Equity Interests
Page 8 Premier, Inc.
(Hanson ref. 9, HIGPA Code ref. B.2.b.)
ADVISORS ON PREMIER GPO MEMBER AND SPECIAL COMMITTEES
4.a. No Gifts to Advisors Who Can Influence Contracting
(Hanson ref. 6, HIGPA Code ref. B.2.a.)
4.b. Advisors to Recuse Themselves if They Have Received Gifts
(Hanson ref. 7, HIGPA Code ref. B.2.a.)
4.c. Disclosure by Advisors of Equity Interests
(Hanson ref. 8, HIGPA Code ref. B.2.b.)
4.d. Advisors to Recuse Themselves if They Have Equity Interests
(Hanson ref. 9, HIGPA Code ref. B.2.b.)
4.e. No Advisors with Extensive Equity Interests
Group Purchasing Code of Conduct Page 9
(Hanson ref. 10)
CORPORATE EQUITY INTERESTS
5.a. Limitation of Equity Investment by Premier GPO in Vendors
(Hanson ref. 11, Premier Letter ref. 13, HIGPA Code ref. B.3.a.)
5.b. Disclosure of Equity Investments in Vendors
(Hanson ref. 12, Premier Letter ref. 13, HIGPA Code ref. B.3.b.)
5.c. No Commitments Permitted If Premier GPO Has Equity Investment
(Hanson ref. 13, Premier Letter ref. 13, HIGPA Code ref. B.3.c.)
VENDOR EQUITY OWNERSHIP IN PREMIER GPOs
6.a. No Vendor Equity in Premier GPOs
(Hanson ref. 5, Premier Letter ref. 6)
OTHER BUSINESS RELATIONSHIPS WITH VENDORS
Page 10 Premier, Inc.
7.a. Limitation on Other Business Relationships with Vendors
(Hanson ref. 14)
(Premier Letter ref. 1)
PARENT COMPANY OF PREMIER GPOs8
8.a. Parent Company - Conflict of Interest
(Hanson ref. 46)
8.b. Parent Company – Limitation on Business Activities
(Hanson ref. 47)
PREMIER SUBSIDIARIES
9.a. Directors and Advisors to Non-GPO Subsidiaries of Premier
Group Purchasing Code of Conduct Page 11
(Hanson ref. 48)
9.b. Non-GPO Subsidiaries of Parent Company – Limitation on Equity Investments
(Hanson ref. 49)
9.c. Non-GPO Subsidiaries of Parent Company – Limitation on Business Activities
(Hanson ref. 50)
MEMBER RELATIONS, PRODUCT EVALUATION AND VENDOR GRIEVANCES
10.a. Right to Communicate Directly with Vendors
(Hanson ref 18, HIGPA Code ref. C.1.a.)
10.b. Right to Purchase Clinical Preference Items off Contract
(Hanson ref. 19, HIGPA Code ref. C.1.a.)
Page 12 Premier, Inc.
10.c. Notice of Pending Bidding Processes
(Hanson ref. 20, HIGPA Code ref. C.1.b.)
10.d. Statement of Vendor Rights and Responsibilities
(Hanson ref. 17)
10.e. Notice to Vendors of Ethical Standards
(Hanson ref. 35)
10.f. Fair Technology Evaluation Process
(Hanson ref. 21, Premier Letter ref. 8)
10.g. Technology Breakthrough Procedures
(Hanson ref. 22, Premier Letter ref. 8, HIGPA Code ref. C.2.)
10.h. Vendor Grievance Procedures
(Hanson ref 23, HIGPA Code ref. C.3.)
USE OF CONTRACTING TOOLS
11.a. Goals of Contracting
Group Purchasing Code of Conduct Page 13
(Hanson ref. 16, HIGPA Code ref. D.)
11.b. Limitation on Sole-Source Contracts10
(Hanson ref. 24, Premier Letter ref. 9.a.)
11.c. Limitation on Commitment Levels
(Hanson ref. 25, Premier Letter ref. 9.b.)
11.d. No Bundling of Unrelated Products
(Hanson ref. 26, Premier Letter ref. 9.c.)
11.e. No Bundling of Unrelated Products Across Vendors
(Hanson ref. 27, Premier Letter ref. 7)
11.f. General Limitation of Contracts to 3 Years
(Hanson ref. 28, Premier Letter ref. 10)
11.g. Cap on Administrative Fees
(Hanson ref. 29, Premier Letter ref. 1)
Page 14 Premier, Inc.
11.h. Standardization of Administrative Fees
(Hanson ref. 30)
11.i. No Up-Front Administrative Fees
(Hanson ref. 31, Premier Letter ref. 2)
11.j. No Administrative Fees in the Form of Vendor Equity
(Hanson ref. 32, Premier Letter ref. 4)
11.k. No Marketing or Other Fees from Vendors
(Hanson ref. 33, Premier Letter ref. 3)
11.l. No Private Label Programs
(Hanson ref. 34, Premier Letter ref. 5)
COMPLIANCE, CERTIFICATION AND IMPLEMENTATION
12.a. Designated Ethics Officer
(Hanson ref. 42)
12.b. Designated Compliance Officer
14
Group Purchasing Code of Conduct Page 15
(Hanson ref. 43, Premier Letter ref. 12, HIGPA Code ref. E.1.)
12.c. Annual Report on Ethics Performance
(Hanson ref. 45, Premier Letter ref. 12, HIGPA Code ref. E.2.)
12.d. Review by Audit Committee
(Hanson ref. 44)
12.e. Implementation, Transition and Updating
(HIGPA Code ref. E.3.a.)
12.f. Respond to Changes in HIGPA Code
(HIGPA Code ref. E.3.b.)
REPORTING AND EDUCATION
13.a. Cooperation with Cost Studies
(Hanson ref. 41, HIGPA Code ref. F.1.)
Page 16 Premier, Inc.
13.b. Web-Based Vendor Directory
(HIGPA Code ref. F.2.)
13.c. Educational Programs
(HIGPA Code ref. F3)
DISCLOSURE OF VENDOR PAYMENTS
14.a. Written Agreement
(HIGPA Code ref. G.1.)
14.b. Disclosure of Acceptance of Payments
(HIGPA Code ref. G.2.)
14.c. Disclosure of Payments Related to Purchases
(Hanson ref. 37, HIGPA Code ref. G.3.)
14.d. Disclosure of Vendor Payments
(Hanson ref. 40, HIGPA Code ref. G.4.)
Group Purchasing Code of Conduct Page 17
14.e. Annual Financial Reporting
(Hanson ref. 39)
14.f. Disclosure of Contracts to Members
(Hanson ref. 37)
14.g. Disclosure of Contracts to the Public
(Hanson ref. 38)
SAFETY, COST-REDUCTION AND CLINICAL COMPARABILITY
15.a. Safety, Cost-Reduction and Clinical Comparability
(HIGPA Code ref. H)
DIVERSITY
16.a.
(Hanson ref. 36, HIGPA Code ref. I)
Page 18 Premier, Inc.
DEFINITIONS
“Clinical Preference Products or Services”
“Clinical Products or Services”
“Corporate Equity Interest”
“GPO”
“Individual Equity Interest”
“Members”
“Nominal Value”
Group Purchasing Code of Conduct Page 19
“Participating Vendor”
“Payments”
“Physician Preference Products”
“Premier”
“Premier Entity”
“Premier GPOs”
“Subject Matter Experts”
“Vendors”
Page 20 Premier, Inc.
Notes
Group Purchasing Code of Conduct Page 21
Notes
Page 22 Premier, Inc.
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