CDC Non-Compliance with VFC Program Requirements Algorithm
Key Instructions
(Use in Collaboration with VFC Operations Guide Module 10 and Grantee’s Fraud & Abuse policy)

•	The Algorithm was developed to provide a detailed framework for field staff and Fraud & Abuse Coordinators to address providers who are non-compliant with VFC program requirements.  If the non-compliant behaviors are not corrected, it may lead to referrals for investigation of fraud and abuse of the VFC program.

•	The algorithm must be used in conjunction with other policy requirements outlined in the VFC Operations Guide (August 2007), Module 10.

•	The Algorithm is not intended to be used to address provider non-compliance with recommended best practices.

•	In general, if any or all of the following high-priority questions are answered incorrectly in CDC’s 2009 VFC Site Visit Questionnaire can be addressed and corrected during site visit   the provider is not required to be entered into a follow-up educational process (secondary or tertiary):  questions: #4, #10, #21, #22, #23, #24, #25, & #26.  The actions taken must be documented in question #32b, and the answer selected for question #33 must be “Provided technical assistance at time of site visit, no further follow-up is need.” 

•	In general, providers who incorrectly answered other high-priority question from CDC’s VFC Site Visit Questionnaire should be entered into a follow-up educational process (secondary or tertiary).   These questions are: pre-visit assessment of provider profile, #1, #6, #7, #8, #9, #11, #12, #13b, #14, #15, #16, #17, #18, #20, #27 and #28.  

•	On occasion, there may be situations of non-compliance related to VFC program requirements that in judgment of the grantee are not significant enough to enroll a provider into the educational process but requires follow-up to assure that the non-compliant behavior is corrected. In these situations, the follow-up plan must be   documented in the VFC Site Visit Questionnaire in questions # 32 & #33.  The follow-up activities must be documented as “VFC Site Visit Follow-up Contact” and in the appropriate table of the 2009 VFC Management Survey (due March 2010).

•	To determine which educational process (secondary or tertiary) to enroll the non-compliant provider in, the following questions must be answered: 1) Is the non-compliant behavior causing or has it caused loss of VFC vaccine? 2) Is the behavior placing the VFC program in danger if the behavior is not stopped immediately?  3) Has the provider received unintentional financial gain because of the behavior?  If the answer is “yes” to any of the questions, then the provider must be enrolled in the tertiary educational process.  If the answer to all questions is “no”, the provider should be enrolled in the secondary educational process.

•	At a minimum, grantees must comply with the follow-up schedule outlined for the appropriate educational process level (secondary or tertiary).  Grantees can do more, but not less, follow-up.

•	If a grantee identifies a situation in which fraud and abuse is strongly suspected, then the process to refer to an external agency for further investigation must begin immediately regardless of educational process being implemented.

•	For an extenuating circumstance to influence how the non-compliance situation is handled, it must be a rare or unusual occurrence.

•	If a provider is discovered to be administering vaccines outside of acceptable medical practices appropriate action must be taken based on the immunization program’s assessment of the situation.  

•	If a grantee wants to customize the non-compliance algorithm any changes must be submitted to CDC for review and approval. Please contact the VFC Coordinator at CDC to discuss before starting the customization process.

This document can be found on the CDC website at:
http://www.cdc.gov/vaccines/programs/vfc/downloads/vfc-op-guide/nc-vfc-algorithm-instruc-508.rtf