Vendor Compliance SEC³URE | Compliance and Privacy Services | UC Davis Health

All individuals who represent a company doing business with or seeking to do business with UC Davis Health must register in SEC³URE. The following representatives are excluded from SEC³URE registration:

• Clinical Engineering Representatives (Contact the Clinical Engineering Office)
• Building Contractor Representatives (Contact Facilities Design and Construction for more information)
• Third-Party Payer Representatives (Auditors)
• Clinical Trial Monitors
• Delivery Services (i.e. FedEx, Amazon, Pizza Hut)
• Representatives with a UC Davis Health printed badge

Generally, any Representative with access to patient care areas must sign a confidentiality agreement, but the following may be acceptable in lieu of a confidentiality agreement:

1. A HIPAA Business Associate Agreement,
2. A determination by the Compliance Department that the vendor is acting as a member of a covered entity (as defined by HIPAA), or
3. Provisions to ensure that the vendor does not have access to protected health information.

For additional information or questions about the confidentiality standards, contact the UC Davis Health Compliance Department at (916) 734-8808 or hs-compliancehelp@ucdavis.edu.

In general, a Representative may not utilize University resources, especially for a commercial purpose.

No. Representatives may not provide gifts or giveaways of any nature (pens, note pads, coffee/coffee mugs, gift cards, etc.) to UC Davis Health workforce members during their visit. For additional information about our gift and conflict of interest (COI) policies, visit the Compliance conflict of interest webpage.

UC and UC Davis policy allow for University departments to solicit vendors for unrestricted donations so long as:

• There are no company promotional materials at the event.
• The appropriate University departments are notified and approve of the event.
• The vendor does not provide the donation directly to any individual. 

An unrestricted donation is one that doesn’t have any “strings attached” and where the department has full autonomy to decide how it will be used. For example, the vendor cannot present at the supported event or require that the donation is used for a particular activity.

The department may decide to use a vendor’s donation to purchase food for an event or fund an employee’s travel expenses, but these items must be purchased/reimbursed directly by the department and not the vendor. Additionally, the vendor cannot have any involvement in the selection of the individual recipients (i.e. the training participant or a conference attendee). 

Funds donated to support educational activities must be managed in accordance with conflict-of-interest standards set by the relevant national governing body or by ACCME if no governing body exists. Departments must notify the learners of the vendor’s support, but cannot imply that the vendor has “sponsored” the activity. For example, the department can say, “This activity is supported in part by a donation from [name of vendor]”, but cannot say the activity is “sponsored” by the vendor. 

Any donation to the department must be approved by department leadership and may require additional approval in accordance with PPM 260-15. For additional information about accepting donations, please contact the UC Davis Health Sciences Development and Alumni Relations.

Patient Attendees: Generally, nominal vendor-donated giveaways (i.e. $10 gift cards) can be provided to patients so long as the intent is not to encourage or entice them to seek care, purchase items or services or to select a particular provider. Please contact Compliance or Legal Affairs if you have questions about providing giveaways to patients.

Employee Attendees: While distribution of vendor-donated prizes and awards to employees is not explicitly addressed in University policy, giving gifts and prizes to employees using University funds is allowed and the value should be limited to avoid tax implications in accordance with University of California – Policy G-41 (PDF) and UC Davis PPM Employee Non-Cash Awards (380-50).

Please note that donations cannot be accepted if they are provided as promotional items or with the intent of directing business to the vendor. We recommend that all giveaways valued at more than $25 are first reviewed by Compliance.

Yes. Representatives are allowed to visit UC Davis Health at the request and invitation of our personnel only. Departments can revoke that invitation at any time and ask them to leave if the Representative is not following the unit’s policies or is disrupting business operations. Furthermore, departments may implement additional rules for vendor on-site visits that exceed University standards in order to meet the individual needs of each location. Representatives who fail to comply with University/department policies or legal/regulatory requirements are subject to reprimand, up to and including termination of visiting privileges. If you or your department is having issues with a vendor or you have had to ask a vendor to leave your department, please contact the UC Davis Health Compliance Department at (916) 734-8808 or hs-compliancehelp@ucdavis.edu.

Remember, the presentation of products and services by a Vendor Representative at UC Davis Health is a privilege, not a right.

• Vendor SEC³URE rules overview (PDF)
• UC Davis Health workforce SEC³URE rules overview (PDF)

UC Davis Health Electronic Policy Management System, Ellucid. (login required to access these links)

• 2202, Vendor Access and Conduct Policy
• 2601, Gifts and Interactions with Vendors 
• 2526, Pharmaceutical Manufacturers’ Representatives