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Inspector General hotline at 1-800-447-8477.

You must also report anything you see or hear that may be a violation of rules or policies dealing with the following:

1. Financial records

2. Living wills

3. Patient care

4. Personal conduct

5. Personnel issues such as: equal employment, sexual harassment, personal conduct, the Fair Labor Standards Act and time and attendance.

Compliance Policies

The health system’s Board of Directors has adopted the following policies:

Policy 1—University Health Systems of Eastern Carolina will not take any adverse action or retribution against any employee due to the good faith reporting of a suspected violation or irregularity.

Policy 2—Employees are expected to obey and report any suspected violations of the following:

1. Federal, state, and local laws and government regulations

2. Health system policies and procedures

3. Organizational rules and regulations

4. Corporate Compliance Program

5. Code of Conduct

Policy 3—All clinical professional services will be documented in the medical record, and such documentation will comply with applicable payer regulations.

Policy 4—All clinical professional services will be coded to accurately reflect the documentation in the medical record.

Policy 5—All claims shall be submitted in compliance with applicable payer regulations or requirements.

Policy 6—Employees will not knowingly and willfully solicit, receive, offer or pay any remuneration directly or indirectly, in cash or in kind, in exchange for Medicare and/or Medicaid referrals.

Policy 7—Employees will not knowingly and willfully (1) falsify, conceal or cover up a material fact, (2) make any false, fictitious or fraudulent statement or representation, or (3) make or use false writing or document known to contain false, fictitious or fraudulent statement in information submitted to the government.

Policy 8—Employees will not conceal or fail to disclose knowledge of an event affecting an initial or continued right to any benefit or payment with intent to secure such benefit or payment fraudulently.

Policy 9—Employees/agents will not knowingly present or cause to be presented false or fraudulent claims, including situations where (1) the service was not provided as claimed, (2) the service was provided during a period in which the provider was excluded from the program and 3) the service was provided due to false or misleading information on coverage in order to influence a decision regarding when to discharge a person from inpatient hospital services.

March 17, 2009

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