Confidentiality Policy

Confidentiality Policy

Safeguarding confidential information is a fundamental obligation of the board and the executive director of the American Association of Surgeon Distributors. The confidential and proprietary information given will only be used to grant membership to the Association.

The following confidential information is necessary to process applications for membership:

  1. Case volumes – necessary to address utilization question.
  2. Pricing – necessary to ensure compliance with restraint on price increases.
  3. Investment – necessary to address the question of investment risk.
  4. Ownership percentage – necessary to ensure compliance with Stark Laws.
  5. Written contracts – necessary to ensure these exist with the hospital.
  6. Hospital contact – necessary to ensure pricing is the lowest and that the distributorship in no way leveraged referrals.

Confidentiality is protected in the following manner:

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AASD’s executive director will assure and maintain the confidentiality of all information provided on behalf of a distributorship’s application.  During the board’s review process, the name of the distributorship, its surgeons and its hospitals will be redacted from the application. Vendor pricing is not required. Written contracts with vendors only require the first page and signature page. Alternatively, the contract can be providing with all pricing redacted.