Approval/Effective Date: 07/9/2008
Last Reviewed: 04/27/2015
Policy: The UW School of Dentistry shall not contract with any individual or entity excluded from participation or otherwise ineligible to participate in federal health care programs. Additionally, if an individual or entity with whom the School currently contracts becomes excluded from participation in federal health care programs, the School shall immediately cease contracting with that excluded individual or entity.
Purpose: The purpose of this policy is to ensure that the School does not receive supplies or services from an individual or entity that has a history of engaging in illegal or improper activities. This policy also seeks to ensure the School does not enter into illegal or improper contract agreements.
1. This policy applies to the following categories of vendors:
- Independent contractors
- Agency contract staff
2. The School’s Department Administrators and Program Directors or their designees are responsible for ensuring that the non-excluded status of prospective vendors and contractors is determined through accessing the Department of Health and Human Services Office of Inspector General (OIG) List of Excluded Individuals/Entities on the OIG website (http://oig.hhs.gov/exclusions/index.asp) and the Federal Government’s System for Award Management (SAM) website (https://www.sam.gov/portal/public/SAM/) when making purchases using their procurement Visa card (Procard) or under the direct buy limit of $10,000. The UW Procurement Department will be responsible for checking the non-excluded status of vendors on all requisitions.
3. Should a vendor or contractor appear on the OIG List of Excluded Individuals/Entities or the SAM website, the School shall not contract with that individual or entity until the issues are resolved and it is clear that the individual or entity is not excluded from participation in federal health care programs.
4. The School’s contracts with vendors and contractors will include language that obligates vendors and contractors to conform to the principles and standards of its compliance program. The following language is to be included in all contracts with individuals or entities:
Federal Exclusion Clause
Vendor represents and warrants that it is not excluded from participation, and is not otherwise ineligible to participate, in a “federal health care program” as defined in 42 U.S.C. § 1320a-7b(f) or in any other government payment program. In the event Vendor is excluded from participation, or becomes otherwise ineligible to participate in any such program during the Term, Vendor will notify the School of Dentistry in writing within three (3) days after such event, and upon the occurrence of such event, whether or not such notice is given to the School of Dentistry, the School of Dentistry reserves the right to immediately cease contracting with that excluded individual or entity.
If Vendor is an Employment Agency, Vendor represents and warrants that its employees are not excluded from participation in a “federal health care program” as defined in 42 U.S.C. § 1320a-7b(f).
Corporate Compliance Plan Clause
The University of Washington, School of Dentistry’s Compliance Program is designed to ensure that the School of Dentistry complies with federal, state, and local laws and regulations. It focuses on the promotion of good corporate citizenship, including a commitment to uphold the highest standard of professional and legal business practices and the prevention of misconduct. Vendor agrees to conduct all business transactions that occur pursuant to this Agreement in accordance with all applicable laws, regulations, and the School of Dentistry compliance policies, and ensure that Vendor officers, employees and agents do the same. Any major compliance violations would be considered a material breach of this contract.