W-9 Requirement when submitting in PEER
A recent policy issued by the VUMC Office of Healthcare compliance requires that all parties VUMC does business with are checked for exclusions at the Federal and State level. This is done via an external vendor that checks federal tax ID numbers (aka EIN) of all entities with which we have a business relationship. This is checked against a large database. The Compliance Office interpretation of the policy is that it covers all entities with which we do business, regardless of whether they are paying us, we are paying them, or there are no payments made at all.
For new entities (i.e. we have never had a contract with this entity before), PEER will require the department upload the W-9. The W-9 will only be required the first time we do a contract with a new entity. Agreements with sponsors we already have Tax IDs for will not trigger the W-9 requirement.