2024 PUBLIC ACCOUNTABILITY QUESTIONNAIRE

This Questionnaire Covers Calendar Year 2023.

Please return your response to [email protected] and
[email protected] no later than
June 3, 2024.

OWNERSHIPANDORGANIZATIONAL STRUCTURE

1. Describe the ownership structure of your GPO and/or its parent or affiliated companies,
including details regarding the following:

- Person(s) or entities that control the majority of voting interests in your GPO;
- The types of equity holders of your GPO (e.g., publicly-held company,
healthcare providers, individuals, for-profit and/or not-for-profit entities);
- The corporate form of your GPO and/or its parent or affiliated companies – such as
corporation, partnership, limited liability company, co-op;
- Whether the GPO is organized as a for-profit or not-for-profit organization; and
- Location of corporate headquarters.

TPC:
a) Member interest is equal among the Founding Members.
b) TPC membership interest is made up of healthcare providers. The current
membership interest is exclusively not-for-profit entities.
c) LLC
d) For-profit
e) 5700 Granite Parkway, Suite 900, Plano, TX 75024.

2. Describe the composition of your Board of Directors or other governing body and reflect
any changes from the previous HGPII reporting year. Include the following in your
response:

- Number of individuals serving on your Board;

- Percentage of Board representing GPO customers;
- Percentage of Board that are employees of the GPO; and
- Percentage of Board members also serving as employees, officers, or directors of a
participating vendor.

TPC:
a) There are six members of TPC’s Board of Managers. In addition, TPC has an
Advisory Board made up of nine members.
b) All Board of Managers and Advisory Board positions are held by GPO customers
(see more below).
 c) One member of the Board of Managers is a TPC employee and one member of the
Advisory Board is a TPC employee.
d) No board member is an employee, officer, or director of a participating GPO
vendor.

Note: TPC has a Board of Managers which is comprised of the owners (5 Founders) of TPC
and TPC’s President/CEO. TPC also has an Advisory Board which includes Founders, Non-
Founders, and the President/CEO of TPC. The Advisory Board is made up of nine Members
(5 Founders, 3 Non-Founders and TPC’s President/CEO). The Non-Founders are also not-
for-profit health systems and no Advisory Board Member or Board of Managers Member
is an employee, officer or director of a participating GPO vendor.

3. Indicate whether any equity holder of your GPO and/or its parent or affiliated companies is a
physician (or an immediate family member of a physician).

TPC:
There is no physician ownership of TPC. There is no equity holder of TPC that is a
physician or an immediate family member of a physician.

CONFLICTOFINTEREST

4. Describe the GPO’s policies and procedures that address conflicts of interest for:

- Employees in a position of influence with regard to contracting decisions;

- Clinical Advisory Members; and
- Members of the GPO’s Board of Directors or other governing body.

TPC:
a) All TPC employees are expected to comply with the TPC Business Ethics policy. All
employees are required to complete the Employee Compliance Certification Form
when joining the company and annually thereafter.
b) Members of Clinical Advisory Committees are required to abide by the TPC
Membership Agreement, which requires anyone on a committee to voluntarily
remove themselves from any decisions where they may have a financial or family
relationship (Conflict of Interest).
c) TPC's Board of Managers and TPC’s Advisory Board are representatives of not-for-
profit healthcare providers and as such may be obligated to comply with their
individual organization’s Business Ethics Policies and/or Conflict of Interest
Policies.
d) TPC addresses the company Conflict of Interest and Confidentiality policy at the
beginning of each Member committee meeting during which Members are asked
to disclose any actual, potential or apparent conflicts of interest and voluntarily
refrain from engaging in any action or decision in which a conflict of interest may
exist. Any participant in the meeting that discloses a conflict of interest or any
potential conflict of interest is excused from participating in discussions about a
contracting decision and will be excluded from voting on contracting decisions or
strategies.
 As part of your response, provide details about reporting requirements for conflicts and
provide a copy of written policies.

TPC:
TPC employees are prohibited from participating in contracting decisions in which a
potential conflict exists, which is defined as an employee having an interest in, or
connection with, any company that TPC does business with or is contemplating doing
business with, if the interest is of such a nature that it might influence, or appear to
influence, the independent judgment of the employee. This may be further defined as an
individual equity interest or property or service transactions. With prior management
approval, TPC employees may serve as an officer or director of any company that does not
have a material conflict with the interests of TPC. Employees may not serve on the board
of managers or serve as an officer in a company that TPC management determines has
material conflicts of interest with TPC, including but not limited to be a competitor or
vendor of TPC. TPC’s Board of Managers and TPC’s Advisory Board of Managers are
required to follow the Ethics Policies of their employer(s). TPC’s Business Ethics Policy
addresses limitations and disclosure of gifts. Any company employee involved in the
contracting process is prohibited from accepting any gift or participating in any business
entertainment event offered by a prospective supplier/vendor if said participation would
influence the contracting decision; in certain circumstances TPC employees may provide
meals to vendors. Please see TPC’s Business Ethics Policy. If an employee reports an ethics
violation to any employee or manager, TPC’s President/CEO is notified of the alleged
activity. Depending on the circumstances, available information and perceived seriousness
of the alleged violation, the President/CEO may notify the Chairman of TPC’s Board of
Managers and initiate an internal and/or an external investigation. TPC’s Business Ethics
can be found on TPC’s website at www.tpc1.com. Scroll to the bottom of your screen and
click on “compliance” to access TPC’s written Business Ethics document.

5. Describe actions the GPO takes to avoid conflict of interest issues for members of the
Board of Directors (e.g. disclosure and/or prevention of equity investments in
participating vendor relationships and acceptance of gifts/meals/travel/entertainment paid
for by vendors).

TPC:
TPC's Board of Managers are representatives of not-for-profit healthcare providers and
are obligated to comply with their individual organization’s Business Ethics policies
and/or Conflict of Interest Policies. TPC shares the Business Ethics policy with the TPC
Board of Managers and TPC’s Advisory Board and this policy addresses limitations and
disclosure of gifts. TPC Board of Managers and TPC Advisory Board are asked to
voluntarily remove themselves from discussions or decisions if a conflict of interest exists.

6. Describe the GPO’s policies and procedures that address activities, including other lines of
business of the GPO and/or its affiliates (including non-GPO services and strategic
investments) that might constitute conflicts of interest to the independence of its purchasing
activity. [1]
 TPC:
TPC owns Southwest Insurance Services, Inc., an insurance agency licensed in several
states for the sale of insurance products such as life, disability, dental and vision, property
and casualty coverage; the business interests of TPC and Southwest Insurance Services are
complementary and aligned with no known or anticipated potential conflicts of interest.
TPC has contracts for GPO services that are specifically outlined and define TPC’s
purchasing activity. There are no conflicts of interest to the independence of its
purchasing activity. TPC’s governance structure is designed to manage the best interests
of TPC’s participating health systems.

OTHERLINES OFBUSINESS

7. Describe other lines of business or investments of the GPO and its affiliates. We are
interested in hearing about new as well as nontraditional GPO services that your company
and its affiliates are involved with.

TPC:
TPC owns Southwest Insurance Services, Inc., an insurance agency licensed in several
states for the sale of insurance products such as life, disability, dental and vision, property
and casualty coverage; the business interests of TPC and Southwest Insurance Services are
complementary and aligned with no known or anticipated potential conflicts of interest.
TPC does maintain purchasing agreements that are separate and distinct from the
agreements that are in place for traditional medical/surgical/pharmacy supply chain
purchasing (agreements with TPC’s primary GPO – currently Vizient). These TPC
purchasing agreements primarily focus on purchased services categories such as insurance
(referenced above), food services, clinical maintenance, information technology services,
temporary staffing, revenue cycle, capital, etc. TPC has also made significant investments
to support Member’s business intelligence, benchmarking and analytics needs. TPC has
stood up performance improvement capabilities that support workforce management,
quality outcomes and revenue enhancement. Service lines that are commonly referenced
at TPC include supply chain, purchased services, revenue cycle, insurance services and
performance improvement services.

8. What policies or guidelines does the GPO have to address potential conflicts of interest
with regard to other lines of business engaged in by the GPO and/or its parent or affiliated
companies?

TPC:
TPC does not have other lines of business that are outside of the purchasing function
whereby a conflict of interest exists. The lines of business that TPC engages in are focused

1 Business concerns, organizations, or individuals are affiliates of each other if, directly or indirectly, (1) either one controls or has the
power to control the other, or (2) a third party controls or has the power to control both. (See 48 CFR, Section 9.403 (2007): Securities Act,
Sec. 16, 15 USC 77p(f)).

on cost reduction specific to lowering the cost of supplies and lowering the amount of
supplies used to care for patients. TPC works collaboratively with health systems,
suppliers and consultants to aggregate volume to reduce the total cost of care and
improve the overall financial and clinical performance of its Members. In addition, TPC
 engages in performance improvement activity that pursues best practices and adopts
utilization criteria and proven benchmarks that supports quality outcomes at lower costs.
If identified, TPC’s Business Ethics policy is effective to address potential conflicts of
interest.

MONIES FROM VENDORS

9. Describe the GPO’s policy with respect to the receipt of sponsorship funds, grants for
research or other educational programs, or any other source of non-administrative fee
revenue from vendors. What policies does the GPO have to guard against any potential
conflict of interest relating to such payments?

TPC:
TPC does not accept receipt of sponsorship funds, grants for research or other educational
programs or any other source of non-administrative fee revenue from vendors.

10. Does the GPO and/or its parent of affiliated companies accept vendor fees relating to
conference sponsorship or exhibit booth space? What policies does the GPO have to guard
against a potential conflict of interest relating to vendor participation in industry trade
shows, and donations in general?

TPC:
TPC does not accept vendor fees relating to conference sponsorship or exhibit booth
space.

11. Describe any services or products the GPO or its affiliates provide to vendors on a fee-for-
service basis (e.g. data, claims processing, etc.).

TPC:
No services are sold to vendors.

12. Does the GPO make annual disclosures of administrative fees received from vendors for
contracting activities with respect to the member’s purchase of products and services (e.g.
safe harbor reports)? If this document is publicly available, provide an electronic link to this
information.

TPC:
TPC makes annual disclosures of administrative fees received from vendors for contracting
activities with respect TPC Members’ purchases of products and services. Moreover, in
accordance with GPO Safe Harbor regulations, TPC discloses the terms and conditions
(including administrative fees) of each new contract in writing to all Member CEOs and
CFOs upon contract execution and upon request from TPC Members. This information is
available upon request.
13. Does the GPO disclose to members all payments other than administrative fees the GPO
receives from any vendor in the course of the GPO’s group purchasing activities (e.g. booth
space, educational grants, marketing fees, honoraria, etc.) whether from the purchasing
activity of those members or not? Describe your disclosure practices.

TPC:
Fees other than administrative fees (if any) are disclosed through TPC’s financial reporting system
and governance process. TPC’s financials are disclosed to the Board of Managers quarterly and
TPC’s audited financials by a third party financial accounting firm are disclosed to the Board of
Managers annually. TPC’s Members receive statements at least quarterly detailing purchasing
activity. TPC’s Board of Managers review TPC’s financial statements at each Board meeting and
may also request to inspect the financial records of TPC at any time.

14. Describe the GPO’s policy with respect to returning administrative fees to an
ineligible vendor.

TPC:
TPC will comply with contract terms and member agreements and promptly notify the
vendor of the ineligible Member’s administrative fee payment received and make every
reasonable effort to refund the payment.

MEMBERFEES

15. Does the GPO pay fees or offer equity to members upon the signing or re-signing of a
participation agreement with the GPO or the joining or renewal of membership in the GPO
program?

TPC:
TPC does not pay fees or offer equity to Members upon joining or renewing their
commitment to a GPO or joining or renewing their Membership Agreement with TPC.
New Members interested in becoming an owner of TPC or an equity partner of TPC has not
been considered in the past several years.

BID AND AWARD/CONTRACTING ISSUES

16. Does the GPO have a publicly-available description of its bid and award process? If so,
provide a link and written description of your bid and award process. If not, describe how
it may be obtained.

TPC:
TPC has a publicly available description of its bid and award process available on TPC’s
website; www.tpc1.com. Scroll to the bottom of your screen and click on “compliance” to
access TPC’s Bid and Award Contract Process document.
17. Describe the GPO’s requirements for how products or services are published so they are
accessible to potential vendors. If a bidder is not awarded a contract, is that bidder able to
review the decision criteria used to evaluate the bid? Include in your response a general
description of the GPO’s criteria for vendor selection.

TPC:
TPC does not publish its decision criteria used to award potential contracts; however, the
TPC contracting team, as part of its due diligence, will openly share with each vendor,
upon request, the anticipated decision criteria and timelines that will drive the contract
award process. Information is equally available to participating vendors. Upon request,
TPC’s contracting team will communicate to those bidders that do not receive an award
the criteria used in reaching the decision. TPC data, Member data or other
market/competitive information will not be disclosed. Requirements are developed for
each unique contracting opportunity and are communicated by the TPC contracting
process to each interested vendor. TPC does follow a best practice list of criteria when
undergoing a vendor analysis and awarding a contract.

18. Describe the GPO’s policy with regard to the use of single, sole, dual, and multi-source
procurement and provide an example or two to support use of these contracting tools.

TPC:
As a member-driven organization, TPC may recommend a sourcing strategy but TPC
Members choose whether to accept the recommendation or propose an alternative
strategy. Sole or dual source procurement is only used when TPC Members determine it is
necessary to meet the objectives of the initiative being pursued for improved value,
service and/or quality. Member participation in sole or dual source procurement sourcing
contracts is voluntary in nature and the award is based on the overall value provided by
the award winner. When contracting for a category or product segment, all current
suppliers and qualified supplier candidates are considered. TPC staff prepares and
presents quality, service and cost data and other decision criteria to TPC Members and/or
member committees. TPC Members determine the appropriate direction and authorize
TPC staff to make the final award decision based upon quantitative and qualitative data.
Examples of sourcing strategies include: Medical Surgical Distribution Services (single
source) and Peripheral Vascular (dual source). TPC’s contracting tools and governance
process support the cost benefit analysis of having single, sole, dual or multi-source
agreements.

19. Does the GPO permit bundling of unrelated products or services from the same vendor or
from different vendors? If so, under what circumstances would the GPO consider bundling
to be appropriate?

TPC:
TPC provides its Members with access to TPC’s preferred GPO partner’s (Vizient)
contracting portfolio and adheres to TPC’s GPO partner’s policies regarding the use of
bundling. TPC does not permit bundling of unrelated products or services from the same
vendor, nor does TPC permit the bundling of unrelated products or services from different
vendors.
20. Describe the process for contracting for clinical preference items. Describe the GPO’s
policy guiding the appropriate length/term of contracts for clinical preference products.

TPC:
TPC provides its Members with access to TPC’s internal and preferred GPO partner’s
(Vizient) tools and consultants for many physician preference items. TPC directs its GPO
partner to provide contracting support and subject matter expertise when evaluating
opportunities and outlining decision options. In some circumstances, TPC may negotiate
directly with manufacturers of physician preference items. Physician preference items
negotiated by TPC are done so based on the best interests and needs of TPC Members.
Agreements for clinical preference products, when awarded, are typically structured with
a term of three years or less and options are always available to Members to pursue
innovative solutions that may improve the cost or quality of care delivered.

ADMINISTRATIVEFEES

21. What is the GPO’s practice regarding the amount of administrative fees accepted? If
there is a written policy, please provide an electronic link or copy of the GPO’s policy
regarding these fees.

TPC:
When a contract is awarded to a supplier, TPC discloses the administrative fee details in
writing to each TPC Member’s CEO and CFO. In addition, TPC’s administrative fees are
disclosed to Members each calendar quarter as part of the financial statement process
and upon the request of TPC Members. TPC follows the Safe Harbor rules specifically for
healthcare GPO entities.

22. Describe the conditions in which the GPO accepts administrative fees beyond 3 percent,
requiring specific (not blanket) disclosure under the Federal Regulatory Safe Harbor
provisions?

TPC:
The conditions by which TPC may consider accepting an administrative fee beyond 3
percent vary and are evaluated on a case-by-case basis; TPC makes specific disclosure
under the Federal Regulatory Safe Harbor for all contracts, regardless of whether the
administrative fee is above 3 percent or not.
23. Describe the range of administrative fees accepted and examples of the types of contracts
(without specifying specific proprietary information) that have administrative fees greater
than 3 percent.

TPC:
The range for administrative fees varies depending on contract category. For example,
administrative fees generated by supply spend may range from 0 to 3 percent; however,
categories outside of traditional supply spend, such as purchased services categories and
revenue cycle solutions, may be greater than 3 percent including but not limited to the
following categories: Revenue Cycle Support, Managed Freight Services, Temporary
Staffing Services and Bad Debt Collection Services. TPC provides services beyond
contracting services that includes the programmatic management of helping Members
optimize the value they can receive from vendors. For example, TPC supports ongoing
implementation of services and tracks benchmarks to support the sharing of best practices
to improve overall financial, clinical, and operational performance. All fees are disclosed
to Members.

PRIVATELABELPROGRAMS

24. Describe whether the GPO has a private label program and if so, describe the products the
private label program covers.

TPC:
TPC does not have a private label program. TPC does participate in its primary GPO’s
private label program (Vizient’s Impact Standardization Program) and certain programs
and services offered by its preferred distribution partners.

25. Describe the GPO’s practice regarding administrative fees derived from a private label
program.

TPC:
TPC does not have a private label program. TPC follows the guidelines of its primary
GPO’s (Vizient) and distribution partners private label program.

VENDORGRIEVANCEPROCESS

26. Describe the GPO’s policy and process with respect to responding to a vendor’s grievance
regarding the bid/award process.

TPC:
All Vendors have the right to register a grievance with TPC.
TPC’s vendor grievance process is:
1. Vendor notifies TPC of grievance.
2. TPC contacts supplier to discuss nature and details of grievance.
3. TPC management determines whether grievance warrants review by the
appropriate member committee(s), specific Member organization and/or TPC
President/CEO.
 4. If the grievance cannot be resolved, TPC management and vendor will work
together to determine the appropriate recourse as provided in the agreement.

TPC’s supplier grievance process is displayed on TPC’s public website located at

www.tpc1.com. Scroll to the bottom of your screen and click on “compliance”, to access
Supplier Grievance Process.

27. Did any supplier, since submission of the last GPO’s Public Accountability Questionnaire,
request an evaluation pursuant to the HGPII Independent Evaluation Process? If so, please
provide information regarding the outcome of such evaluation.

TPC:
TPC has not received any supplier requests for an evaluation pursuant to the HGPII
Independent Evaluation Process, since submission of our last Public Accountability
Questionnaire.

28. Does the GPO participate in HGPII’s Independent Evaluation Process?

TPC:
TPC has participated in HGPII’s Independent Evaluation Process since 2014.

29. Is the HGPII Independent Evaluation Process displayed on the GPO’s public website? If
so, please provide an electronic link to this information.

TPC:
Yes, the HGPII Independent Evaluation Process is displayed on TPC’s public website
located at www.tpc1.com. Scroll to the bottom of your screen and click on “compliance”,
to access HGPII’s Independent Evaluation Process.

INNOVATION

30. Describe the GPO’s policy and process to evaluate and provide opportunities to contract
for innovative products and services.

TPC:
Vendors/suppliers and Members are encouraged to introduce innovative technologies,
services and products to TPC staff and TPC’s GPO partner (Vizient). If TPC agrees that
said technology, service or product is indeed innovative and will yield a positive
quality/cost impact for TPC Members, the technology, service or product will be
presented to TPC Members and/or member committee to further evaluate its
credibility.

31. Does the GPO have the right to enter into a GPO contract for innovative technology at any
time during its bid and award cycle? Describe the process the GPO has for fostering the
development of GPO contracts for innovative products.

TPC:
 TPC maintains the appropriate latitude to enter into new contracts where new technology
differentiates a product category or segment from previous technology offerings. TPC
encourages suppliers to present new technologies that offer material advantages over
previous or current technologies; this may be presented directly to TPC or to TPC’s GPO
partner. In addition, when finalizing an award for a committed technology or product,
TPC builds contingencies into its contract commitments that carves out the testing and
potential adoption of innovative technology or products. If and when a new product or
service can definitively improve the ability to deliver quality care and/or lower the cost,
TPC will pursue adoption of such new products or services.

32. Are GPO members allowed to evaluate products and/or communicate with vendors,
regardless of whether a vendor has a contract with the GPO?

TPC:
Yes. Members are not restricted from evaluating products and/or communicating with
any vendor regardless of whether such vendor has a contract with TPC. Members are
involved in TPC’s selection process and TPC’s governance model encourages Members to
evaluate products and innovative services.

33. Are GPO members allowed to purchase non-contracted products or services directly from
non-participating vendors?

TPC:
Yes. TPC Members may purchase non-contracted products or services directly from non-
participating vendors.

VENDORDIVERSITYPROGRAMS

34. Describe the GPO’s program or activities that encourage contracting with Diverse Vendors
(small, women-owned, veteran owned, minority-owned). Explain how you promote or
market those programs to the GPO’s membership and to Diverse Vendors.

TPC:
TPC provides its Members with access to its GPO partner’s (Vizient) diversity programs and
promotes the GPO’s contracted diversity suppliers.

35. Has the GPO increased contracting with Diverse Vendors over the prior year(s)? If so,
quantify these increases within each Diverse Vendor category (SBE, WBE, VBE,
and/or MBE).

TPC:
N/A - TPC provides its Members with access to TPC’s GPO partner’s (Vizient) diversity
programs and promotes TPC’s GPO partner’s contracted diversity suppliers.
36. Does the GPO have a Vendor Diversity Committee or other program or group for
developing diversity goals and expanding opportunities? If so, describe. What are its
mission, goals, and objectives? Does it work directly with the GPO’s sourcing team in
developing its goals and expanding opportunities? What are the Committee’s significant
achievements over the GPO’s last fiscal year? If it is a Committee, who are its members
and how frequently does it meet?

TPC:
N/A - TPC provides its Members with access to TPC’s GPO partner’s (Vizient) diversity
programs and promotes the GPO’s contracted diversity suppliers.

37. Does the program described in the previous question provide education to member health
systems regarding diversity program best practices and/or how to establish a Vendor
Diversity Program within their system? Does it solicit member feedback to ensure it is
meeting member expectations?

TPC:
N/A - TPC provides its Members with access to TPC’s GPO partner’s (Vizient) diversity
programs and promotes the GPO’s contracted diversity suppliers.

38. Describe any other actions concerning Vendor Diversity you think are important that are
not covered by the preceding questions.

TPC:
N/A - TPC provides its Members with access to TPC’s GPO partner’s (Vizient) diversity
programs and promotes the GPO’s contracted diversity suppliers.

ENVIRONMENTALLY-PREFERREDPRODUCTSANDSERVICES

39. Have members of your GPO expressed a preference for environmentally-preferred

products and services?

TPC:
Yes – in certain categories and instances, TPC Members have expressed interest in
environmentally-preferred products and services.

40. Describe your GPO’s approach in identifying and satisfying the desires of your various
members for environmentally-preferred products and services. Provide examples of
environmentally-preferred products and services within your current portfolio.

TPC:
TPC works closely with its GPO partner (Vizient) and the suppliers within the portfolio to
assess the Member’s requirements specific to environmentally preferred products and
services. When RFPs are created, Members provide feedback on the questions asked of
the potential suppliers and suppliers responses are weighted in the evaluation and
selection process. Specifically, environmentally preferred attribute information is
submitted by suppliers for criteria in all GPO contract awards.
41. What challenges, if any, have you experienced in identifying or contracting for working a
variety of environmentally-preferred products and services to your members? How have
you responded to such challenges?

TPC:
TPC works closely with its GPO partner (Vizient) and strives to provide hospitals with the
environmental attributes that assist in product selections for meeting sustainability and
patient safety goals. There are no specific responses at this time.

42. Has your GPO designated someone to:

– Identify your GPO’s environmentally-preferred objectives;

– Explore environmentally-preferred products and services; and/or

– Develop initiatives to help educate your members about the value of using
environmentally-preferred products and services?

TPC:
TPC works closely with its GPO partner (Vizient) to offer an Environmentally Preferred
Sourcing Program that provides the necessary framework for health care organizations to
implement and maintain an environmentally friendly program that supports their
organization’s overall sustainability objectives. TPC and its GPO partner (Vizient) work
with our Members to better understand how to implement an Environmentally Preferred
Sourcing Program policy and program, and why it is important. Working together in a
consistent and thoughtful manner, TPC Members can better understand reasonable and
achievable targets that are financially viable, environmentally sound, health improving
and inspiring.

43. Please describe your organization’s role in educating, advising, and supporting the adoption
of Environmentally Preferred Purchasing among your members, including the availability of
websites, catalogues, toolkits, or webinars?

TPC:
TPC works closely with its GPO partner (Vizient) to educate and support hospitals’ efforts
to engage in Environmentally Preferred Purchasing including promoting several available
online resources. In addition, TPC encourages Members to share and adopt best practices
to support Environmentally Preferred Purchasing and Utilization.
CODE OF CONDUCT

44. Provide a copy of and an electronic link to your GPO’s written code of business ethics and
conduct. Describe any changes made to it from the previous HGPII reporting year.

TPC:
TPC’s written Business Ethics and conduct can be found on TPC’s website at www.tpc1.com. Scroll
to the bottom of your screen and click on “compliance”, to access TPC Business Ethics document.
The document has not materially changed from the prior year.

45. Describe whether and in what manner the GPO distributes its written code of business
ethics and conduct to all applicable employees, agents, contractors, clinical advisory
committees, and others involved in group purchasing activity. How often is the code of
conduct provided to employees? Do employees receive annual refresher training on the
GPO’s ethics and the code of conduct? Describe the content of the training and the
method of delivery.

TPC:
TPC’s Business Ethics policy, which includes a written code of conduct, is distributed
annually to TPC’s Advisory Board (inclusive of TPC’s Board of Managers). Additionally,
the summary principles of TPC’s Business Ethics policy are shared with all member
committees (including Clinical and Administrative Advisory committees) prior to each
member meeting via the written Conflict of Interest and Confidentiality statement. TPC
employees receive a copy of the Business Ethics policy at the time of hire and annually
thereafter. All employees are required to review and acknowledge their review of the
policy in writing by signing a written compliance certification form at their time of hire
and annually thereafter. Contracting employees adhere to a standardized contracting
process that requires the appropriate documentation to support TPC’s contracting and
business decisions. Agents, contractors and others involved in group purchasing
activity may also request a copy or go to TPC’s website at www.tpc1.com. Scroll to the
bottom of your screen and click on “compliance” to access TPC’s Business Ethics
document.

46. Describe the mechanism (e.g., a corporate review board, ombudsman, corporate
compliance or ethics officer) for employees to report possible violations of the written
code of business ethics and conduct to someone other than one’s direct supervisor, if
necessary.

TPC:
Employees may report possible violations directly to the President/CEO, Human Resources
or Chair of the Board of Managers. Reports may be made via email, telephone or
anonymously in writing to the President/CEO, Human Resources or the Chair of the Board
of Managers. Any report of an infraction, of any kind, is investigated promptly, discreetly,
professionally and may involve external counsel to provide protection against retaliation.
COVID-19 Response

47. With the onset of the COVID-19 pandemic many healthcare providers experienced
shortages of critical supplies and equipment due to disruptions in the supply chain. In
response, how did your organization assist its members in assessing the quality and
reliability of supplies? Specifically, what role did your organization play in vetting new
and previously unknown supply chain sources, especially within the so-called Grey
Market?

TPC:
Throughout the pandemic, TPC provided extensive support to our Member hospitals in
identifying, evaluating, and recommending new suppliers for products of high need and
innovative solutions to best serve their respective patient populations.
To help streamline and match Member demand with potential supply, TPC established
supplier vetting processes. In the early stages, TPC was approached by well over 300
various suppliers proposing a business relationship with TPC Members to meet the
immediate need of PPE. Of those, TPC vetted over 160 suppliers based upon key
qualification criteria. Based on the volume of supplier inquires to TPC and Members, TPC
established a select team of staff members in a “war room” type of environment that was
dedicated to supplier development. Suppliers interested in selling products to Members
were asked to complete a 14-question survey that included inquiries regarding product
origin, production capacity, distribution channels, FDA approval, market presence prior to
COVID-19, delivery timeline, purchasing process, and references. TPC also required the
supplier’s W-9.
Suppliers that met the qualifications were then presented to the membership for
purchasing consideration. TPC provided Members with a direct contact at the supplier to
purchase product (as opposed to the supplier contacting the Member). Members that
purchased products from recommended suppliers then shared product review and
experience with other Members. When directed by the Members, TPC would step in to
create direct contracts with specified suppliers to support the aggregate purchasing of
needed PPE. For example, under the direction of the Members, TPC contracted for masks
to quickly meet the PPE of its Members.

Throughout the pandemic and beyond, TPC has monitored supply accessibility and has
worked closely with Members, Vizient and vendors to address shortages, mitigate
escalation of cost and develop resiliency planning. TPC has consistently served as a
channel for the Members to share their challenges and outline best practice solutions
to resolve them as quickly as possible.

48. Please describe your organization 's role in advising and supporting federal and state
policy makers in managing the healthcare supply chain during the pandemic, including
cooperation with federal and state stockpiles?

TPC:
During the pandemic, TPC worked directly with Members to discuss and identify best
practices in accessing and acquiring supplies via federal and state stockpiles to help
supplement their critical supply needs. In addition, TPC shared best practice strategies to
 access federal and state funding to help off-set the cost of delivery care during the
pandemic and the impact the pandemic had on the health system’s operations.
49. As a response to pandemic related challenges and supply chain disruptions, what
technology services and IT products did your organization provide to members and their
patients? What information and best practices services did you provide to the public?

TPC:
During the pandemic, TPC created Member dashboards to both track and predict
pandemic impact in their respective markets. The purpose of the dashboards was to
determine the current and potential future PPE needed to support the delivery of care.
TPC also created recommended inventory standards to help our Members manage and
monitor PPE inventory and help the Members be better prepared for any potential spike in
PPE needed. Members used the dashboards to place orders for clinical supplies and staff
their health systems appropriately. In addition, TPC shared the data tool with the
Members to help them understand the needs of each other. Members that were getting
hit harder by the pandemic were able to request support and supplies from other
Members within TPC. To help with the public, TPC established formal lines of
communication to support Members with their sharing of innovative solutions to setting
up remote sites to screen for COVID impact. TPC pushed out email communication and
offered access to materials and webinars where the Members shared lessons learned and
solutions to help manage the surge of COVID patients.

REPORTINGPOTENTIALETHICALVIOLATIONS

50. What process is used to protect the confidentiality of the reporting employee’s identity
and what safeguards are in place to mitigate the opportunities for retaliation?

TPC:
Employees may report by way of email, telephone or anonymously in writing to the
President/CEO, Human Resources or the Chair of the Board of Managers. Any report of an
infraction, of any kind, is investigated promptly, discreetly, professionally and may involve
external counsel to provide protection against retaliation.

51. Describe how the GPO follows up on reports of suspected violations of the code of business
ethics and conduct to determine if a violation has occurred and if so, who was responsible.
Describe corrective and other actions taken in such circumstances.

TPC:
All employees are responsible for monitoring compliance through the organization. The
President/CEO and Human Resources are responsible for conducting investigations of
reports of non-compliance. The Chair of the Board of Managers is notified promptly of
any investigation.
52. Describe the processes the GPO follows up on, to monitor on a continuing basis, adherence
to the written code of business ethics and conduct, and compliance with applicable federal
laws.

TPC:
TPC will complete HGPII’s Annual Public Accountability Questionnaire and implement the
best practices deemed most relevant and applicable by the President/CEO, CFO and Vice
Presidents that lead contracting. Ongoing and periodic targeted training and education
sessions occur with individual staff members responsible for contracting and with the
entire TPC staff. TPC also consults with outside legal counsel to periodically review TPC’s
code of business ethics and conduct practices. In addition, TPC provides training and
education on Anti-Trust regulations to support TPC’s fair and equitable business
practices.

53. Are periodic reports on the GPO’s ethics and compliance program made to the GPO’s
Board of Directors or to a committee of the Board? If so, please state how often and in
general, what information is reported? Are periodic reports on the company’s
participation in HGPII made to the GPOs Board of Directors or to a committee of the
Board? If so, please state how often and in general, what information is reported.

TPC:
The President/CEO provides an annual report to the Board of Managers regarding the
compliance program and business ethics policy, as well as the company’s participation in
the HGPII.

54. How many of your GPO employees attended the most recent Best Practices Forum?
Include the name of the most senior executive who attended.

TPC:
Four TPC employees attended the Best Practices Forum in 2023. TPC’s most senior
executive in attendance was Mark Phalen, Senior Vice President & CFO. Kelly Love (Vice
President of Strategy and Communications), Alex Brown (Vice President, Supply Chain
Operations) and David Shamlin (Director, Supply Chain Operations) were also in
attendance.
List the name, title and contact information of the senior manager assigned responsibility
to oversee the business ethics and conduct program. Provide the name, title and contact
information for the individual(s) responsible for responding to this report.

TPC Senior Manager: Roger Nolan, President & CEO

TPC, 5700 Granite Parkway, Suite 900, Plano, TX 75024 / 469.366.2105
[email protected]

TPC contacts responsible for responding to this report:

Roger Nolan, President & CEO
TPC, 5700 Granite Parkway, Suite 900, Plano, TX 75024 / 469.366.2105
[email protected]

Mark Phalen, Senior Vice President & CFO

TPC, 5700 Granite Parkway, Suite 900, Plano, TX 75024 / 469.366.2112
[email protected]

Kelly Love, Vice President, Strategy & Communications

TPC, 5700 Granite Parkway, Suite 900, Plano, TX 75024 / 469.366.2136
[email protected]