Enough to discourage you from procrastination amid specter of looming rules.
By R. Dana Barlow
January 2025 – The Journal of Healthcare Contracting
COLUMBUS, OH – Imagine if government agents showed up in your office one morning accusing you and your organization of participating in human trafficking for labor purposes. All before you took a sip of your first cuppa joe.
“Wait, whaaaaa? Really? How?”
“Yes, you buy a significant number of selected products from a company that profits from ‘cheap’ labor sourced by human traffickers.”
“Wait! I didn’t know! How are you supposed to know that?”
Their reply: “You should have known.”
Chilling.
Now rub the nape of your neck to smooth down those little hairs.
This scenario isn’t real … at least not yet. But the potential, the possibility, lingers and should resonate in the back of your mind.
First, let’s dispense with the obvious. Human trafficking – whether for labor, sex or anything else – is evil and illegal. Deep down, most of us agree and acknowledge both. Further, something must be done to slow these transactions to a trickle, to strangle the pipeline to an emphatic stop and then to prevent it from ever happening again – an extinction-level event. Quickly.
Alas, it may be an ideal that likely won’t materialize. Even one victim of human trafficking now on the public speaking circuit sharing her harrowing tale of abuse here at the annual conference of the Association of Health Care Resource & Materials Management (AHRMM) acknowledges that, “I know we can’t abolish it, but we need to become more aware of it.” Still, that doesn’t dilute her point of view nor negate the emphasis and essential nature of the words in the prior paragraph.
Beyond any initial virtue signaling the questions then arise on how to determine the most effective, efficient and expedient (triple E) way(s) to accomplish this, who should do it and what happens when it doesn’t happen fast enough as determined by … someone else?
Think of it as a kerfuffle morphing into a gurgling miasma at loggerheads with reality.
You surely don’t want this to fester into an “O-Ring Committee” situation, a reference to a scathingly satirical political cartoon about the decision-making process during the ill-fated Space Shuttle Challenger mission in 1986. The cartoonist used the design of the shuttle’s O-Ring failure as the position of the decision makers – all standing in a circle, each one pointing to the person next to him or her.
During the AHRMM show in late September, the educational session/learning lab title, “Mitigating Human Trafficking in Healthcare Supply Chain” likely raised attendee eyebrows out of sheer initial curiosity, but unfortunately not enough to pack the room full of people.
AHRMM Executive Director Mike Schiller, who spearheaded the topic and session for the parent American Hospital Association (AHA) represented the small crowd in the room showing support for this simmering under the shelves issue. Schiller referred attendees to the association’s official policy on human trafficking in the healthcare supply chain, which can be found online here. The link provides samples and templates for management systems, risk assessment tools, due diligence explanations and worker engagement and training exercises. Be sure to check it out.
Amid all the increasing supply chain pressures in a post-pandemic marketplace that really involved many of the same pre-pandemic pressures not yet solved but infused with nitrous oxide, three major issues need to be addressed – specifically and realistically (maybe not in that order) – to connect the dots.
- How to expand due diligence policies and procedures with all existing and prospective vendors to identify issues.
- How to incorporate legal declarations and severe penalties for non-compliance in binding contractual language. Anyone remember when Walmart required suppliers and vendors to adopt and implement bar coding or they would not be allowed to back their semi-trailers to warehouse docking stations?
- How to convince and persuade the C-suite to take this issue seriously enough to warrant it as a high priority among competing priorities.
At first glance, human trafficking doesn’t sound like an individual or local healthcare organization supply chain issue to address. Instead, it resonates more like a federal issue to be mitigated through the Commerce, Justice and State Departments – particularly if the human trafficking victims enter the U.S. illegally at coastal shipyards or even airports. But even actual U.S. citizens can be victimized.
Still, fundamental questions linger that can and should be resolved so that no one can or should dismiss this issue as someone else’s problem.
One recommendation is for supply chain to require of its contracted suppliers, vendors and service companies some type of proof that they have not used or are aware of their downlines using trafficked humans. Yet this raises even more questions. What constitutes and qualifies as proof? Which agency is qualified to certify this process? Who generates revenue and profits from this investigative and certification process? Should they? Might this be incorporated into the vendor credentialling process? Should suspected flagrant abusers be targeted first while the rest leak and slip through the cracks? Who should be doing this? You? Your GPO? Your distributor? Your manufacturer? Then think about all the administrative and operational costs that will be incurred to carry this out and likely buried in the prices or total delivered costs of all products.
Here’s the fundamental kicker, however: How do you either discourage, if not prevent, people from lying, and short of that, how do you catch people in their prevarication?
But let’s be clear and resolute: None of these questions should nullify a response and justify looking the other way. That would be a reckless disregard of reality and the truth.
To perform due diligence and make hard decisions during any contracting efforts, you will see costs rise and therefore, prices. When you poke a balloon at one end, you’ll notice that either a bubble will protrude in the opposite hemisphere, or the balloon will pop. It’s not unlike the privacy vs. security debate. If you want more security, you may have to sacrifice some privacy and vice versa.
Yet it’s important for the healthcare provider industry to get ahead of this issue and implement diligent and legitimate safeguards proactively before the federal government is properly motivated to force a corrective solution that might be more costly than indifference and lethargy. True healthcare extends way beyond selfcare as a shared service with sacrifice, and on this wise we should be thankful.
R. Dana Barlow serves as a senior writer and columnist for The Journal of Healthcare Contracting. Barlow has nearly four decades of journalistic experience and has covered healthcare supply chain issues for more than 30 years. He can be reached at rickdanabarlow@wingfootmedia.biz.