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CHILDREN’S HOSPITAL & MEDICAL CENTER CORPORATE COMPLIANCE PLAN - page 1 / 15

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CHILDRENS HOSPITAL & MEDICAL CENTER CORPORATE COMPLIANCE PLAN

I.

INTRODUCTION

It is the policy of Children’s Hospital & Medical Center (the “Hospital”) that its business and affairs be conducted at all times in accordance with ethical business practices and applicable laws and regulations. The Hospital places the highest importance on its reputation for honesty, integrity and high ethical standards. To that end, and in accordance with the Hospital’s Code of Conduct, the Hospital has developed this Corporate Compliance Plan (the “Plan”) to present and reaffirm its commitment to ethical conduct and adherence to applicable laws and regulations.

This Plan provides standards by which “ Staff,” defined as the Board of Directors, employees, members of the medical staff, allied health professionals, students, residents, volunteers and agents, will conduct themselves. Hospital as used in this Plan refers to all facilities, units, departments and clinics operated by the Hospital regardless of location.

II.

COMPLIANCE STANDARDS, POLICIES AND PROCEDURES

The Hospital is subject to numerous federal and state laws and regulations that govern the activities of Staff who are expected to be knowledgeable of and in compliance with the laws and regulations that affect their area of responsibility. Staff that violate laws or regulations risk individual criminal prosecution, civil actions for monetary damages and exclusion from federally funded health care programs. In addition, actions of Staff may subject the Hospital to the same risks and potential penalties. Accordingly, any Staff that violate federal or state laws may be subject to disciplinary action, up to and including termination of their employment/affiliation. Questions regarding laws or regulations or any other part of the Plan should be directed to the Compliance Officer at 402-955- 4122.

The Hospital has developed the Children’s Hospital Code of Conduct that presents behavioral expectations and basic legal principles under which Staff must operate. Staff is responsible for ensuring that their behavior and activity are consistent with the Code of Conduct which is attached to the Plan.

In addition to the Code of Conduct, the Hospital has developed or will develop policies and procedures that address areas issues and activities that are especially complex or have been identified as compliance risk areas. These policies will be tailored to the specific needs of that area and will be distributed to and reviewed with affected Staff as part of their training and education. As with all compliance policies, these specific policies and procedures will be reviewed regularly and modified to reflect organizational and regulatory changes.

III.

COMPLIANCE OVERSIGHT RESPONSIBILITY

The Board of Directors in order to reaffirm its commitment to ensure that the Hospital operates in compliance with all laws and regulations of the United States and the State of Nebraska has adopted a compliance program which is codified in this Plan. The Board of Directors has established the Audit and Compliance Committee, and delegated its direct compliance oversight responsibilities to such committee. The Board of Directors also appointed a Compliance Officer

CORPORATE COMPLIANCE PLAN 5/6/10

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