Flowers Hospital General Compliance Training-Students 2013

Compliance Program Written Policies and Procedures The Code of Conduct Corporate Compliance Officer and Compliance Committees –Facility Compliance Officers –Facility Privacy Officers Training & Education Auditing & Monitoring Confidential Disclosure Program & Hotline

Written Policies and Procedures Flowers Hospital has many written compliance policies and procedures and are located on the Flowers Hospital intranet. Questions regarding any Compliance Manual policy may be directed to your Department Director, the Facility Compliance Officer, or the Vice President, Corporate Compliance and Privacy Officer. 3

The Code of Conduct (the “Code”) is designed to provide all employees and affiliates with guidance to perform their daily activities in accordance with all federal, state and local laws, rules and regulations. The Code is an integral part of the Compliance Program, and reflects our commitment to achieve our goals within the framework of the law, through a high standard of business ethics and compliance. The Code is a collection of policy statements. Most sections of the Code of Conduct refer to more detailed policies covered in various department policy manuals. What is the Code of Conduct?

Compliance with the Code of Conduct and Compliance Policies The Code of Conduct is a mandatory policy of the Company. All colleagues will review the Code electronically via the Advanced Learning Center (or on paper, if requested) and acknowledge they have read the Code, understand it, and agree to abide by it. In addition, all colleagues will reaffirm these actions on an annual basis. Compliance with the Code of Conduct and other Compliance Manual policies will be considered in annual employee evaluations and decisions regarding promotion and compensation for all employees. The Code of Conduct is a unilateral statement of policy. Nothing in the Code is intended to create enforceable employee contract rights.

Expected Conduct Every colleague is required to comply with the Code of Conduct. Each individual is expected to perform his/her daily activities with the highest ethical standards and in compliance with laws, rules, regulations and statutes. If uncertain about a task or instruction given by a supervisor or co-worker, ask for clarification until comfortable. All colleagues are required to notify the Facility Compliance Officer (“FCO”), the Corporate Compliance Officer, or the Confidential Disclosure Program Hotline of any suspected or known violations of law, the Code of Conduct, or Compliance Policy.

Training & Education A variety of training and education programs are offered through the Advanced Learning Center. Required training includes General Compliance Training, HIPAA Privacy and Security training and Identity Theft. Job-specific compliance training lessons are required for certain job types. 7

Coding & Billing If you are responsible for coding or billing of services, you must not knowingly cause or permit false or fraudulent claims, and must adhere to all official coding & billing guidelines. –The Federal False Claims Act (FCA) provides that civil monetary penalties and other damages may be imposed against any person or entity that knowingly presents or causes to be presented a false or fraudulent claim to a federal healthcare program for payment. –The FCA includes certain “whistleblower” protections to protect an individual who files an action under the FCA. –Many states have developed their own false claims act laws. –Information on both the federal FCA and relevant state laws is available in the Compliance Manual on the CHS intranet. Furthermore, colleagues shall not engage in any intentional deception or misrepresentation intended to influence any entitlement or payment under any federal healthcare benefit program. Claims must be submitted only for services ordered, appropriately documented, and actually provided.

Stark Law Stark prohibits physicians from referring Medicare or Medicaid patients for certain services known as designated health services to any health care entity where the physician has a financial relationship, unless a legal exception applies. A physician or healthcare organization does not have to intend to violate stark; even a technical violation is considered a violation. A Stark violation may trigger False Claims Act liability and significant civil monetary penalties and fines may be assessed for violations.

Anti-Kickback Statute The Anti-Kickback Statute (AKS) prohibits the offer, payment, solicitation, or receipt of anything of value to induce or reward referrals or to generate Federal healthcare program business. AKS applies to any person or business; and, any item or service. Violation of AKS is intent-based; a business or person must knowingly and willfully set out to induce or reward referrals. AKS includes both criminal and civil penalties with possible jail time and significant civil money penalties.

HIPAA Privacy and Security HIPAA is a federal law which provides standards for protection of protected health information (PHI) and for individual rights to understand and control how PHI is used. Guidance for compliance with HIPAA exists in the form of: –Detailed policies and procedures for managing HIPAA privacy and security standards; and, –A designated Facility Privacy Officer; and, –Annual training requirements; and, –Administrative, physical and technical safeguards to prevent intentional or accidental inappropriate use or disclosure of PHI; and, –A documented process to mitigate harm to a patient or patients whose PHI may have been inappropriately used or disclosed; and, –A procedure for individuals to share complaints regarding use or disclosure of their PHI; and, –Other protections as required by HIPAA and state laws which may be more stringent than HIPAA.

Auditing and Monitoring Auditing and monitoring is routinely performed in an effort to prevent, detect and mitigate inappropriate conduct or activities. Auditing and Monitoring topics include, but are not limited to, a routine coding assessment at each affiliate, various claims (patient bill) audits, physician transaction and payment reviews, privacy and security audits, various quality of patient care audits, and a check to ensure all employees and medical staff are eligible to provide services to our patients. Errors identified during an audit are immediately corrected, including the repayment of funds when a billing error has occurred. The results of these activities are also used to determine future training topics, policy updates, and additional audit requirements.

Reporting Concerns Questions or concerns about potential compliance violations may be reported to: –Any Supervisor or Department Head –Facility Compliance or Privacy Officer –Confidential Disclosure Program Hotline It is recommended to first report your concerns through your local management Failure to report a known violation of the law, Code of Conduct, or any Compliance Policy could subject an individual to disciplinary action. Any colleague who attempts to divert or discourage reporting shall be subjected to severe discipline, up to and including discharge.

Confidential Disclosure Program A Confidential Disclosure Program Hotline has been established for all colleagues to report known or suspected violations of the Code of Conduct, written policy, or any federal, state or local laws, rules and regulations. This program may also be used for individuals who are uncertain whether an action is a violation and would like to communicate his/her concern on a confidential basis. Confidential Disclosure Program Hotline Number is

Human Resources Grievance Resolution If an individual is concerned about a personnel action that does not involve a violation of law, the Code of Conduct, or Compliance Policy, he/she may file a grievance at the entity where he/she is employed. The Human Resources Department can provide a grievance resolution form and assistance in preparing and presenting a grievance. Information regarding employee grievances is held in strict confidence. Note this process is separate from the Confidential Disclosure Program.

Investigation of Violations Once contact is made via the Confidential Disclosure Program, a prompt, appropriate, confidential investigation will be undertaken. The Corporate Compliance Officer will coordinate findings from the investigation and recommend corrective and/or disciplinary actions. When appropriate, we will return any overpayment amounts and notify the correct governmental agency of the overpayment situation.

Non-Retaliation and No Retribution for Reporting Retribution or retaliation against any person reporting suspected violations of the Code, law, or policy will not be tolerated.