Clifford E. Barnes and Megan Robertson, attorneys in the Health Care & Life Sciences practice, in the firm’s Washington, DC, office, co-authored an article in the American Health Law Association’s Practice Group Bulletin, titled “Hospitals and Hospital System Boards Should Review Sole Source Procurement Policies and Procedures.” (Read the full version – subscription required.)
Following is an excerpt (see below to download the full version in PDF format):
A hospital system’s sole source procurement of products and services provided by Board members that were not approved by the entire Board, or otherwise run through conflict of interest (COI) processes, caused the Maryland General Assembly to impose a prohibition against any sole source contracting for that state hospital system in 2019. Hospital Boards may want to review both their sole source contracting activities to ensure that they are consistent with their COI policy and the conflict policy itself to ensure that sole source agreements are required to be regularly reviewed.