Light at the End of the Tunnel

Edition: March 2003 - Vol 11 Number 03
Article#: 1481
Author: Mark Thill

The ghost of the year past isn’t necessarily a goblin to GPO executives. Maybe it’s more of a poltergeist.

True, the government investigations, the hearings and the newspaper articles had just about every GPO pretty spooked in 2002. But in hindsight, GPO executives are downright optimistic about the long-term effects of everything that happened, if for no other reason than that events have shed some much-needed light on exactly what it is that GPOs do.

Repertoire spoke with several GPO executives to find out how they’re interpreting the events of 2002. Here’s what they had to say.





AmeriNet:

Bud Bowen, CEO




How much of what happened since last spring – the newspaper articles, the Senate hearings, etc. – was justified? Why or why not?



Bowen: Any time there’s a misunderstanding about something, questions are appropriate. Clearly, [group purchasing] is a business, which, to the vast majority of people in this country, is unknown. So it shouldn’t be surprising that in light of the New York Times reports, the Senate staffers looked at this and said, “I’ve never heard about this. What’s this all about?”

There continues to be a great deal of misunderstanding and misperceptions about the business. People can always spin an issue the way they want it to be spun. The group purchasing industry – which is still pretty much a cottage industry – allowed itself to be represented by someone outside the industry. When that happens, you can expect exactly what happened to occur. It would be portrayed in ways other than what it really is. That’s the part that’s been difficult to deal with.



The Senate appeared to be very concerned about access to new technologies. Today, can manufacturers of innovative technologies gain access to GPOs, or is access barred to all but the market share leaders? Does AmeriNet see this as a problem or issue? What is our organization doing to open up access?



Bowen: This hasn’t affected us at all. AmeriNet has always taken the approach not only to be open to startup technology companies, but also to look for them. If we can locate a company with a true breakthrough technology, particularly one that enhances patient care or efficiency, that’s an opportunity for us to establish a significant competitive advantage. We have a great track record of seeking new technologies.



Several years ago, AmeriNet introduced a program called Health Industry Technology, designed to promote new technologies. What’s the status of that program?



Bowen: We have a very large constituency of healthcare providers – 1,800 acute care hospitals, 1,500 long-term-care facilities, clinics and so on. We wanted to create an opportunity for companies that were developing new products to have them tested, evaluated and reviewed by actual healthcare providers during the development process. [The goal was] to make sure they were on track with what they were building and to evaluate the usefulness and benefit of the technology to the provider. We wanted to assist them in building the right product and, at the same time, give our members early access to emerging technologies. It was and is a very exciting concept. But we couldn’t stimulate much interest on the product developer’s side. So the program has been suspended – despite that, conceptually, it’s a great idea.



AmeriNet published a Code of Conduct in November. Why did you feel compelled to produce it? Your Web site says that the Code restates everything AmeriNet has stood for until now. Is there anything new in it? What do you consider to be the most important part of it?



Bowen: We’ve formalized and published two documents. The first contains our standards of business ethics and conduct, and highlights the fundamental terms under which we conduct our affairs, particularly from a conflict-of-interest perspective – which I think is the most important part of this dialogue. The second document states our contracting principles, that is, the strategies, techniques and practices we employ as we do contracts. We do that so the suppliers will understand the way we do business, and so that our members will better understand the approach we take. They really don’t reflect anything different from the way we have operated from day No. 1. But we’ve never published it before.



Why do you say that potential conflicts of interest are the most important part of this discussion?



Bowen: If we take a look at the business we’re in, we have to be viewed by our members as trusted intermediaries on their behalf. We certainly expect that the people in charge of making buying decisions for non-profit hospitals are doing so with the utmost integrity. And we are, in a way, acting as their agents as we negotiate agreements. We have to operate under the same level of integrity and honesty as we expect them to operate.



What is AmeriNet’s stance on sole- and multiple-sourcing? How about the bundling of dissimilar products?



Bowen: We traditionally have not done sole-source contracting. We like to provide choices to our members. We don’t contract with everybody, but we like to contract with the market share leaders, because that’s whom our members are buying from. We do have a few sole-source contracts, but generally we’ve negotiated those because of particular market dynamics.

One of the things missed this past year is the fact that sole-source contracts are not necessarily the choice of the group. It may be the choice of the supplier, say, for example, in the suture and wound closure market. Ethicon will only contract on a sole-source basis. And it controls 80 percent to 85 percent of that market.

AmeriNet has also stayed away from corporate contracting. We are not averse to corporate agreements. With companies that have multiple business lines and disparate product areas, it makes sense that if the member purchases more of that company’s products, the member realizes certain benefits. There’s nothing wrong with that. What we don’t do is create contracts that require a member to purchase a particular product line in order to get the optimum benefit from a different product.



What kind of input have your members been giving you? Do they have concerns about what AmeriNet is doing? Have they expressed support?



Bowen: Our members see this as a non-issue. The things that were at issue have not applied to AmeriNet. The members are concerned – as I am – that if some group activities were prohibited, it could have a very profound effect on the ability of the group to get good terms and contracts. Through the whole process, no one seems to have any concern about the hospitals. If prices go up, they’re the ones who can least afford it. That’s what I hear most commonly from our members.



How would you sum up the effects of the past year on the group purchasing industry?



Bowen: Sunshine is always good. In the past year, a lot of light has been shed on the group purchasing industry. That may be painful, but good things will come from it. I think the fact that GPOs are more sensitive to the appearance of conflicts of interest is good. Let’s make sure it’s as clean an industry as it can be.



MedAssets HSCA:

Rand Ballard, Executive Vice President



Gary Johnson, Director of Marketing & Marketing Services




Do you think that everything that has happened since last spring – the newspaper articles, the Senate hearings, etc. – was justified? Why or why not?



Ballard: I don’t know if it was justified or not, because we weren’t painted negatively in any of those articles. Neither MedAssets nor any of its employees has ever taken stock from suppliers. Our business relationships are very traditional. No venture capital companies have invested in suppliers that we then do business with. We don’t have a private label program.



One of the big issues, at least to the Senate, is access to new technologies. Today, can manufacturers of innovative technologies gain access to GPOs, or is access barred to all but the market share leaders? Does MedAssets HSCA see this as a problem or issue? What can GPOs – specifically MedAssets HSCA – do to open up access?



Ballard: We’ve always been open to small, innovative suppliers. Anyone can go into our Web site and complete an RFI. We’ve picked up suppliers through this process. We just held the first ever joint technology forum with the Medical Device Manufacturers Association (MDMA), which brought 13 potential new suppliers who felt they didn’t have an opportunity with group purchasing organizations. We brought in our committees, who evaluated these suppliers. We had a great two-day meeting.



Johnson: That came about after we met with MDMA and learned about its mission representing innovative technology companies. They told us they were trying to open access for this group of manufacturers, many of whom lack sizable marketing budgets. So we said, “Let’s create a venue where you can present your case to our clinicians and membership.” We got a very positive response from our members who attended, as well as the vendors. We’re looking forward to doing one or two forums in 2003.



How do you evaluate new technology?



Ballard: We have 14 different committees, each focusing on different disciplines. We turn new technology over to our member committees. They do the evaluations. They determine if a technology is truly new and different. We view technology as a good thing, but we want member validation that that’s where we should go.

We feel that we have an obligation to present opportunities to our members to improve care and reduce costs. Because our committees are truly operating committees (run by the customers), they have a large appetite to continue this process. They believe that the end game will be better results for patients and hospitals.



What about the charge that GPOs only want to contract with market share leaders?



Johnson: Part of our strategy is to present multiple vendors to our members. So right away, we’re obligated to look beyond the obvious market share leader. One of the beefs you often hear about is the sole-source, seven-year contracts. By the time these contracts are in place, another manufacturer comes on the horizon and gains a [Food and Drug Administration] 510(k) for a device that genuinely impacts quality of care. With our model, we build that in. And we have the ability to add on such manufacturers because we have multiple-choice contracts.



Ballard: That’s one way we’re different. Some groups own their hospitals; others are owned by their hospitals. But as an independent corporation, MedAssets HSCA has to earn the business. We have to be customer-centric. We have to listen to what customers want. If a technology is new and will save our customers money, we’re with it from the beginning, getting it on contract.



What’s your stance on private-label programs?



Ballard: We don’t have any private-label agreements or licensing fees. We believe these products add cost to the supply chain. We did investigate the concept for a year, but ultimately decided it wasn’t the right thing to do.



How about administrative fees?



Ballard: We believe a 2 percent to 3 percent administrative fee is what the GPO should live on, depending on the agreement.



Sole- and multiple-source contracts? Bundling?



Ballard:< The vast majority of our contracts are multi-source. Some are dual-source. Our members want flexibility. They also want the option to commit. So we have a separate, optional committed-volume program.



Under what conditions, if any, are sole-source contract appropriate?



Ballard: If there are only two vendors in a certain product area, they will say, choose one or the other.



Johnson: The circumstances as seen by the members determine that. In a situation where several products meet or exceed quality-of-care requirements, there’s nothing to gain by going with the more expensive one. In those circumstances, the members would most likely say, “Pick one.” But as a general rule, they tend to go with at least two choices.



Have you put together a code of conduct in the wake of everything that’s happened? Why or why not? What points does it cover?



Ballard: We codified our existing business practices. So it’s a business philosophy that extends throughout the organization. We sent it to Sen. Herb Kohl’s [Senate Judiciary Antitrust Subcommittee] and got back very positive responses.



What are some highlights?



Ballard: No corporate officer or anyone involved in contracting can own even one share of stock in a company with whom we do business. We’re not going to have conflicts. None of us can sit on the board of a company that either does or might want to do business with us. This wasn’t a big deal for us because we were already following these procedures. We also have a full disclosure policy. We disclose the entire business relationship to our customers. We’ve been doing this all along, but we did an exhaustive internal audit to make sure we’re clean. And we took the opportunity to write an entire business ethics process. A lot of it’s common sense, but we’re pretty proud of it.



What kind of input have your customers been giving you? Do they have concerns about what MedAssets HSCA is doing? Have they expressed support?



Ballard: We have shared our draft code of conduct with several of our large customers and have received nothing but glowing reports. We get comments like, “This is what we expected you would have been doing all along.”



Johnson: We’ve been told by a number of our IDN customers that their GPO relationship has become a discussion item for the board of directors. Before, group purchasing organizations weren’t on their radar screens. But a lot of healthcare systems are working hard to build a brand name. When they recognized the risk of affiliating with a group partner who might tarnish that brand, it became a board matter. Affiliating with GPOs is now seen as a strategic decision. And I don’t see it going back.

So we see more questions from IDNs like, “Please list the suppliers in whom you own stock or in whom you have an equity relationship.” That tells me that [the events of the past year] have made an impact. They want to make sure they understand whom they’re doing business with as a GPO.



Consorta:

John Strong, President and CEO



Darrel Weatherford, COO




How much of what has happened since last spring – the newspaper articles, the Senate hearings, etc. – was justified? Why or why not?



Strong: It’s our position that we’ve done nothing wrong, nor engaged in any practices that would be questionable. Further, we believe that our policy (in terms of our compliance with the laws and regulations set by the state and federal authorities) has been strong since the inception of the company and we’re proud of it. That’s not to say we can’t memorialize all our business practices in a code of conduct. We’re in the process of doing that. We believe ours will be a benchmark for group purchasing business practices.



One of the big issues, at least to the Senate, is access to new technologies. Today, can manufacturers of innovative technologies gain access to GPOs, or is access barred to all but the market share leaders? Does Consorta see this as a problem or issue? What can GPOs, specifically Consorta, do to open up access?



Strong: We’ve always engaged in an open and all-inclusive contracting process, which has included anyone who is a viable manufacturer of a product that Consorta or its members could identify. We’ve not engaged in so-called corporate programs in which a bunch of disparate product lines are brought together.



Weatherford: We’ve awarded contracts to non-market-share-leading companies on a number of occasions because that’s where we found the most value. There are other players out there with equally good or better products who are able to offer value better than others. We have to be creative and look at those opportunities. We think we can drive better value for our hospitals that way.



What about administrative fees? What’s fair? What’s your policy?



Strong: We’ve always capped our administrative fees at 3 percent. We never collected any marketing fees. Nor have we ever done private labeling of products. We’ve always engaged in member-driven contracting, in the sense that every member has a voice. We have a group of 10 subcommittees with representatives from each of our shareholders. They award the contracts, not Consorta.



What kind of input have your members been giving you?



Strong: As a group, our shareholders are pleased at how we’ve responded. They would like to get on with things.



Do you think group purchasing will change because of all that’s happened in the past nine months? If so, how?



Strong: It won’t change anything for us. I think that our code of conduct memorializes what we’ve been doing all along. It builds in some new language around the roles of some of our committees. And it will require us to report certain things, at least on a biannual basis. But I don’t think that anything is going to change fundamentally for Consorta, with regard to access by manufacturers, revenue collection policies and so on. People will have the same access as they have in the past – and they’ve always had good access.

It will put parameters around sole-source contracting and contracts of duration greater than three years. Frankly, our shareholders still believe sole-source contracting holds value, and that there are clinical and operational reasons for contracts longer than three years. Now, there are parameters we have to follow.





Premier:

Pat Poston, Senior Vice President, Communications



Are you in contact with the Senate Subcommittee? What’s the next step?




Poston: We’re staying in touch with the staff of the Subcommittee as its leaders determine what its future course will be in the new Congressional term, with the intention of cooperating as we have in the past and keeping the Subcommittee informed of our progress. For example, in addition to sharing our progress in implementation of the industry-wide Code of Conduct for GPOs and Premier’s Additional Principles complementing the Code, we’ve shared with the Subcommittee the results of Premier’s independent effort to identify and adopt the best ethical standards relating to group purchasing [in a report issued in October 2002 by an outside expert, Kirk O. Hanson]. Senator Kohl has commended our efforts so far, and we continue working aggressively on implementation.

We’ve been in communications with the GAO and FTC, and provided them information as they follow up on the requests the Subcommittee made of them (reported at the Apr. 30, 2002 hearing). We’ll certainly cooperate with any further requests they have of Premier.

To assure that our policies, processes and practices reflect the Premier Ethical Standards we adopted, Premier has assembled a multi-disciplinary work team with expertise from contracting to human resources management to legal, finance and communications. The team has analyzed each of the ethical standards and identified all the internal tasks needed to assure compliance, as well as the responsibility and timelines for having the tasks completed. The specific tasks, numbering well over 100, include adding language to policies, redoing some processes entirely, developing education materials for our staff and hiring a compliance officer. Virtually all Premier units are involved to some extent or another – for example, in December we held Premier-wide staff training on our Best Ethical Standards.



In August, Premier announced its support for the HIGPA Code of Conduct and its adherence to further principles, including caps on administrative fees, eliminating the bundling of unrelated products, elimination of vendor equity agreements and multi-source contracting for clinician-preference items. Which principles have you been able to implement? Have you been forced to change existing contracts or relationships with existing vendors in order to adhere to them?



Poston:
It is not our expectation that GPOs will need to modify existing, valid contracts. However, if existing contracts are being modified for various other reasons, Premier is taking the opportunity to conform the contracts or categories to the commitments we’ve made. An example is Premier’s contract for pulse oximetry products. This category is now multi-sourced rather than sole-sourced, as in the past.

It’s important to understand that Premier, in many instances, had already updated its policies and practices along the lines incorporated in the new code and standards. We were doing this in response to the environment and changes in members’ needs and the marketplace, as well as our work with Professor Hanson (begun in March 2002).

In 1996, when Premier was created, inflation was rampant and unpredictable, hospitals were locked in to rate-limited managed care contracts, the vendor community had consolidated tremendously and medical technology was pretty stable. It made sense business-wise for Premier to come out with long-term, sole-source, committed contracts offering multi-year price protection.

But over the past three years, Premier adjusted strategies in response to changes in member needs and marketplace changes – low inflation, diminishing of managed care pressures, more rapid technology advances, consolidation of members into multi-hospital systems. Among the adjustments we were making, in advance of Code activity, were shorter contract terms, more multi-sourcing of clinical items, movement of commitment levels from GPO-wide to local-system-wide.



Your code of conduct calls for the elimination of administrative fees in excess of 3 percent. Have you been able to implement this?



Poston:
Premier receives no contract administration fees on medical products in excess of 3 percent. We’d been moving in this direction for some time and were ready to include the fee limit in our commitments. Premier’s Best Ethical Standards (flowing from the Hanson report) go further: We’ve committed to standardize the contract administration fee for product categories and state the fee in advance to all prospective bidders. In other words, the amount of the contract administration fee will not be a contracting variable for negotiation.



How about “up front” administrative fees?



Poston: Premier has not charged up-front administrative fees and marketing fees in the past. Our updated policies and procedures make that explicit.



Administrative fees paid in the form of vendor equity?



Poston: Premier has no remaining contracts for medical products in which administration fees are paid in the form of vendor equity, having concluded that practice in prior years.



How about this, from your code: “Operation of technology breakthrough and technology assessment programs that are fair, timely, confidential and unbiased, with an opportunity for review of decisions”?



Poston: Premier has several ways to identify and contract for new technologies, including the regular, ongoing tech assessment of our various contracting programs. If we find a superior and desirable new technology and we have no contract for a comparable product, we simply make efforts to bring it under contract with favorable terms for our members.

The Premier Technology Breakthrough Program applies specifically (and only) in the case where we have an existing sole-source contract for a product “challenged” by a new product in the marketplace, which promises superior quality and cost outcomes. The Breakthrough Program provides for an evidence-based assessment of the new product’s claims. Our contracts with incumbents contain a provision that enables Premier to contract additionally for the new product if the breakthrough claims are upheld through this objective assessment.

We are broadening the means by which seller companies are informed of opportunities for contracting with Premier, accessing the Breakthrough Program, etc. For example, we will have far more detailed information on our Web sites, ranging from how to make contact and get information to grievance procedures. We’re also making sure internal processes for responding to and tracking company inquiries and communications are in place and updated.

We are broadening technology assessment and engaging our members to help us seek out emerging new technologies of merit. Our contract for the Given “camera pill” last year is a good example. We’ve also worked hard with our members in preparation for drug-eluting stents.



Premier has stated that future contracts for physician-preference products will be based on the following principles: multi-source contracting, a lack of GPO commitment levels and a lack of “bundling” with unrelated products. Have you been able to deliver on this promise?



Poston:
This commitment has been incorporated into our contracting processes and is being used for all relevant contracting going forward.



How about contract terms of three years or less, subject to modification should economic conditions require longer-term agreements in the best interests of your hospital members?



Poston:
This commitment has been incorporated into our contracting processes and is being used for all relevant contracting going forward. (We were already moving in this direction by early 2002, given marketplace environment and rapid changes in technology.)



Any other changes of note?



Poston:
Premier has committed that in future years we will make public disclosures of financial information, etc., to the same extent that is required for our not-for-profit hospital and health system owners. Our Best Ethical Standards also include our commitment to abide by the following:

1) A designated compliance officer to oversee compliance with the HIGPA code and other ethics commitments, to do annual reporting and raise other policy issues of ethical significance with management and the board.

2) Review by audit committee. The Audit Committee of the GPO will meet at least annually without management present to hear from the ethics and compliance officers and to discuss any issues brought forward by these officers.

3) Annual report on ethics performance. The GPO will make an annual report to its audit committee, board and members regarding its compliance with its own ethical policies.



Are the days of the broad “corporate contracts” over? If so, what’s the upside and downside for your members?



Poston:
Premier has always distinguished between corporate partner relationships and corporate overlay agreements (overarching agreements that govern various sub-agreements with a multi-divisional company for the products of its affiliated companies we choose to contract for). Premier and its members seek sustained working relationships with companies that are able and willing to partner in the processes of improving healthcare quality and cost-effectiveness. We’ve communicated that such relationships aren’t so much based on company size or purchasing volume as on the co-production with us of real value for our members and work together on improving the healthcare supply chain and care processes. We believe there’s a great future in that kind of relationship.





Novation:

Jody Hatcher, Senior Vice President



What’s going on with Novation and the Senate Subcommittee?



Hatcher:
We’re in continual contact with the Senate Subcommittee. We fully intend to move forward with them. We’ve apprised the Subcommittee ahead of time about key things we’re doing that may be of interest to them. What we don’t want is a lack of understanding of what we do – or a lack of communication leading to further misunderstanding.



The Senate appeared to be particularly concerned about access to new technologies. Today, can manufacturers of innovative technologies gain access to GPOs or is access barred to all but the market share leaders? What can Novation do to free up access?



Hatcher:
Our contracting process has always been open to all suppliers – in fact, currently 25 percent of our suppliers are small suppliers, such as Megadyne, a manufacturer of innovative grounding pads. We want to go even further in advancing technology to our members.

In our operating principles [released August 2002], we recognized the need to create a uniform approach across the organization to looking at new technology. So we’ve created a centralized function under the direction of Cathy Denning, for this purpose. She has a clinical background and will be in charge of managing the technology assessment process. Her team has done some due diligence on third party resources that look at new technology, and we’ve begun to establish relationships and agreements with them.

We view this as a foundational change, not a band-aid. We view our ability to [incorporate new technology] as a way to differentiate ourselves from others in the marketplace. Our Technology Forum is one example, and you’ll see others in the future.



What’s the Technology Forum



Hatcher:
It’s a section of our public Web site where suppliers can go and submit their new technologies. It’s open to all manufacturers, both on and off contract, as well as our members. We’ve recently gone live with it and we’re seeing more submissions going through that process. In the coming months, we may sign some agreements with some of these technology manufacturers.

We want to be a catalyst in delivering new technology where practical, contrary to the impression in the marketplace.

You have to remember that Novation isn’t that old. We were formed in 1998. We spent much of our time consolidating two contract portfolios [those of VHA and the University HealthSystem Consortium], which had more than 900 contracts. Now that we’ve completed that, you’re going to see Novation turn the corner on how we work in the marketplace. We believe we’re in a market leader position. Technology assessment and the ability to accelerate the introduction to new technology is just one way to push forward on that leadership position.



In your operating principles [released August 2002], you said that Novation will re-bid product agreements or add vendors to agreements in the event that a new, better technology enters the market. Have you done so yet?



Hatcher:
In November, we introduced an agreement with St. Jude Medical for its proprietary atrial fibrillation suppression technology. This is a unique technology, which we put on contract quickly. We’re also evaluating the pulse oximetry situation and may have something to share in the next 60 days.

We’re trying to maintain a delicate balance. We want to address the concerns raised by the Subcommittee, but we don’t want to do things that would be detrimental to our members and our integrity. We sign agreements in good faith and we want to live up to them. So we are not prepared to revisit every single agreement, but instead move forward prospectively, as we agreed to do in our Operating Principles. Now, where there are clear patient benefits by adding a vendor, we’ll absolutely review them.

The Subcommittee understood this when we spoke with them about it. They recognize that our challenge will be to sort through the noise created in the marketplace. We’re faced with differentiating between what is new and innovative technology, and what is just different, but not necessarily better.



How will you do that?



Hatcher:
We’ll place the burden on manufacturers to demonstrate that they really have a new technology. And we’ll make sure there’s some objectivity involved. We intend to use significant member hospital involvement to gain the perspective of the end user in a clinical setting.



Your operating principles stated that Novation wouldn’t sign agreements whose initial terms are longer than three years. Have you begun to implement this?



Hatcher:
When we were created in 1998, we put into place a boilerplate agreement that calls for a three-year agreement with two one-year renewal options. We’ve exceeded that in some circumstances, but the vast majority are three years in duration.

The key to our process is this: We have about 30 councils and task forces with more than 400 members, many of whom are clinicians, lending input into our contracting decisions. That input is complemented by the quantitative research we do with our members on every agreement. We try to balance quality criteria, financial criteria and the reality of what’s reasonable and feasible.

But if we’re not able to convert, then we won’t be successful in extracting value from our contracting process. So our members have to be prepared to convert if the manufacturer offers competitive value and a quality product.



Your operating principles also state that contracts for clinical-preference products will be dual- or multi-source, subject to member review and approval. Have you implemented this provision?



Hatcher:
Already, 70 percent of our agreements by volume are either dual- or multi-source. And if you look at some of the clinical preference areas, 90 percent of them by volume are the same. Most of the sole-source agreements we have in place are in the commodity areas, where it’s easier for members to commit to one supplier.

For example, we just recently signed a multi-source agreement for needles and syringes. As we move forward, there will be a small fraction of clinical-preference categories in which, based on member input, we’ll offer a sole-source agreement. Our IV catheter agreement is sole-source with BD because the member council drove us to that decision. There was a significant financial savings for the member hospitals in doing so. In both of these instances, we shared our decisions in advance with the Senate Subcommittee.

Although we are voluntary, our objective is to create value that will drive participation by our members and market share for our manufacturers.



What’s your challenge for the year ahead?



Hatcher:
We need to improve communication with those outside Novation. As they have reflected on the past year, our members – particularly those in the councils – have scratched their heads. They’re telling us that we already do a lot of the things we’re supposed to be doing. But that’s not publicly known. The vast majority of the supplier community doesn’t know how we work.

We welcome more transparency in the awards we make and certainly with the folks in Washington. We look at the past year as an opportunity to improve ourselves and to push on the leadership position we’ve been privileged to have.