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STERLING

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Title: STERLING


1
STERLING
HEALTHCARE
Corporate Compliance Training
2
Corporate Compliance
  • Welcome!
  • Sterling is proud of its long-standing tradition
    of delivering exceptional patient care and
    quality service to its many hospital clients.
    This includes conducting business according to
    the highest ethical standards and in compliance
    with all relevant legal and regulatory
    requirements.
  • As part of our association with Sterling
    Healthcare as an employee or a contracted
    healthcare professional you and I are expected
    to do the right thing by conducting all
    business activities in a professional and ethical
    manner.
  • Our Compliance Program has been instituted to
    provide regulatory and ethical guidance to
    everyone associated with Sterling, and to
    establish a culture that promotes prevention,
    detection, and resolution of instances of conduct
    that do not conform to laws and business
    policies.
  • Your commitment to practice lawful and ethical
    conduct, and to serve others with your special
    talents and abilities is critical to the success
    of Sterling, its employees, clients, and
    stakeholders.
  • Eugene F. Dauchert, Jr.
  • Chief Executive Officer

3
Corporate Compliance
  • Service
  • Integrity
  • Lawful
  • Values
  • Ethics
  • Respect
  • ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ?
  • Sterlings SILVER Standards

4
Corporate Compliance
  • Why a Corporate Compliance Program?
  • Recommended by the Office of Inspector General
    (OIG) to help prevent fraud and abuse in Federal
    healthcare programs.
  • Assists in establishing a culture within the
    organization that promotes prevention, detection
    and resolution of activities that do not conform
    to laws and ethical and business policies.
  • Considered a plus in the event violations or
    offenses are discovered penalties (fines) may be
    reduced in the presence of an effective
    compliance program.
  • Ethics and compliance programs are now considered
    good business practice in all industries.
  • A compliance program does not make money, but
    it can save money for the organization (by
    reducing or eliminating potential fines).

5
Corporate Compliance
  • Sterlings Compliance Program
  • Modeled from the OIGs Compliance Program
    Guidance for healthcare organizations.
  • Implemented under the guidance and supervision of
    the Corporate Compliance Officer who is appointed
    by Sterlings CEO with advice and consent of the
    Board of Directors.
  • Multidisciplinary Compliance Committee,
    representing all subsidiaries and key operating
    areas of Sterling, supports the Compliance
    Officer in the programs implementation and
    maintenance.
  • On-going reporting of compliance activities to
    Sterlings Executive Committee and Board of
    Directors.

6
Corporate Compliance
  • Mary Ellen Haynes, our Compliance
  • Officer, is committed to
  • Ensuring that the Compliance Program at Sterling
    includes
  • documented compliance standards
  • education and training for all workforce members
  • clear pathways for reporting violations
  • enforcement of standards with clear disciplinary
    guidelines and
  • evaluation for effectiveness through ongoing
    auditing and monitoring activities.
  • Serving as a resource to you on any compliance
    matter that raises a question or concern for you.

7
Corporate Compliance
  • Compliance Standards
  • Code of Conduct the core instrument on which
    Compliance training is based, it summarizes the
    standards of ethical and professional conduct
    that are expected of everyone associated with
    Sterling.
  • Compliance Policies/Procedures define the
    structure and operation of the Compliance
    Program, provide detailed procedures for carrying
    out the Program, and identify and address
    specific areas of risk to Sterling.
  • Availability the Code will be provided to all
    employees upon hire. The Code and
    Policies/Procedures will remain posted on the
    Sterling Intranet for instant reference. Contact
    the Compliance Officer for copies of any of the
    compliance material.

8
Corporate Compliance
  • Real integrity is doing the right thing,
  • knowing that nobodys going to know
  • whether you did it or not.
  • - Oprah Winfrey

9
Corporate Compliance
If you suspect illegal or non-compliant activity,
what should you do?
  • You have a responsibility to report any activity
    that you either know or suspect is in violation
    of any law or policy.
  • If you do not report serious violations or
    illegal activity that you knew about, you could
    be subject to disciplinary action, even if you
    were not directly involved in the activity.
  • When you report in good faith, your identity
    will be kept confidential to the extent permitted
    by law.
  • No disciplinary action or retaliation will be
    taken against you when you report a perceived
    concern or violation in good faith.

10
Corporate Compliance
  • Reporting Options
  • Talk to your supervisor. Your supervisor is
    responsible for addressing and responding to your
    questions and concerns in a timely manner.
  • Contact other Sterling management. If you feel
    uncomfortable talking to your supervisor, or your
    supervisor is involved in the activity you are
    reporting, consider contacting other Sterling
    management.
  • Contact the Compliance Officer. You may contact
    the Compliance Officer in a variety of ways.
  • Call the Compliance Hotline at 800-826-6762. You
    may report anonymously 24 hrs./day, 7 days/wk.,
    365 days/yr.

Lines of communication for reporting known or
suspected violations are ALWAYS open!
11
Corporate Compliance
  • Contacting Our Compliance Officer
  • By telephone or voice mail to our Compliance
    Line 866-625-8048 (toll-free)
  • To our Compliance E-mail Box compliance_at_sterling
    healthcare.com
  • By direct e-mail MaryEllen.Haynes_at_sterlinghealth
    care.com
  • By telephone or voice mail directly
    919-768-4612
  • or toll-free at 800-476-4587, ext. 4612
  • By personal meeting (use the email address or
    phone numbers above to schedule)
  • By letter addressed to
  • Mary Ellen Haynes
  • Corporate Compliance Officer
  • Sterling Healthcare
  • 1000 Park Forty Plaza, Suite 500
  • Durham, NC 27713

12
Corporate Compliance
  • Calling Our Compliance Hotline
  • Our Compliance Hotline is available 24 hours per
    day, 7 days a week, 365 days per year for
    reporting illegal activity or compliance
    concerns. (This includes issues related to Fraud
    Abuse, Human Resources, and Privacy
    Security.)
  • The Hotline is a highly confidential means of
    reporting and you may report anonymously no
    attempt will be made to identify you.
  • Our Hotline is administered by an independent
    third party, National Hotline Services calls are
    answered by live operators who ask questions to
    prepare a report.
  • Reports are transmitted to the Compliance Officer
    via a secure method.
  • Callers are given a report number and a callback
    date when they may call back to the Hotline for a
    status.
  • The Compliance Officer will provide a response to
    the Hotline that will be read to the caller at
    the time of callback.

13
Corporate Compliance
  • Do The Right Thing
  • DO NOT close your ears and eyes to illegal or
    non-compliant activity within the Sterling
    organization.
  • HELP preserve Sterlings lawful and ethical
    business practices by reporting any known or
    suspected violations.

14
Corporate Compliance
  • Responding to Reported Concerns/Violations
  • All reports, including Hotline calls, will be
    investigated promptly and with the utmost
    integrity under the supervision of the Compliance
    Officer.
  • All reports of compliance concerns/violations are
    kept strictly confidential.
  • No report or call will go unaddressed!
  • If the investigation determines that a violation
    has occurred, resolution of the matter may
    include
  • Development/implementation of an action plan.
  • Institution of disciplinary action, based on the
    severity of the violation and in accordance with
    Sterlings Progressive Discipline Policy.
  • The Compliance Officer will collaborate with
    applicable administrative personnel to ensure
    that determined disciplinary actions are
    instituted.

15
Corporate Compliance
  • Upon the conduct of each
  • depends the fate of all.
  • - Alexander the Great

16
Corporate Compliance
  • Your Responsibilities Toward Others
  • Follow The Rules. You have a personal duty and
    responsibility to comply with all legal and
    ethical requirements, all applicable professional
    standards, and all policies and procedures that
    apply to you and the Sterling organization.
  • Be Honest. You are expected to be honest in all
    aspects of your role with Sterling. Lying,
    cheating, stealing, falsifying records, and
    unauthorized access to, or disclosure of,
    confidential information will not be tolerated.
  • Respect Everyone. You are to treat everyone you
    come in contact with in your role at Sterling
    with the utmost courtesy and respect. No form of
    harassment or discrimination will be tolerated.
  • Protect Privacy Confidentiality. You are not
    to access or disclose any confidential or
    proprietary information unless you are authorized
    to do so, or your job requires it. This includes
    confidential information about Sterling, its
    employees, financial status, internal operations,
    etc., as well as information about patients or
    Sterling health plan participants. Any
    authorized disclosure of information should be
    limited to the minimum necessary to accomplish
    the task.

17
Corporate Compliance
Dont Solicit Gifts or Gratuities
  • Neither you nor members of your family are to
  • seek or solicit gifts or other personal favors
    from
  • any current or potential customer, vendor or
    supplier of
  • Sterling.
  • Acceptance of cash gifts is strictly prohibited.
  • Any gift received that is valued at more than
    100 must be reported to the Compliance Officer
    on the Gifts Gratuities Disclosure Form.
  • This reporting requirement includes gifts
    received in connection with normal business
    activities (such as meals, golf/fishing outings,
    tickets to sporting events or concerts, gift
    baskets, etc.)
  • Everyone must avoid accepting gifts that may
    create a conflict of interest or make it
    difficult to objectively carry out their job
    responsibilities.

18
Corporate Compliance
  • Your Responsibilities Toward Others
  • Provide High Quality Care Services. Delivering
    exceptional patient care and quality service to
    our many hospital clients is Sterlings primary
    focus. As an employee or an associate of
    Sterling, you are expected to uphold these
    quality standards which include
  • Performing all job responsibilities with the
    highest level of integrity and quality.
  • Treating all customers, clients and each other
    with dignity and respect.
  • Addressing any deficiency or error promptly,
    taking appropriate action, and following to
    resolution.
  • Ensuring that all Sterling workforce members are
    fully competent to perform job responsibilities,
    and no previous actions have resulted in
    healthcare convictions or debarment from
    government programs.
  • Providing medical care that ensures medical
    expertise and experience, that is medically
    appropriate, that offers human dignity and
    prohibits discrimination against patients.

19
Corporate Compliance
  • Your Responsibilities Toward Others
  • Responding to Government Investigations.
    Sterling desires to cooperate fully with any
    government investigation into our business and/or
    ethical practices. However, to ensure Sterling
    provides the appropriate response, if you are
    approached by a government agent, refer the agent
    to your supervisor.

The Compliance Officer and General Counsel should
be notified immediately of this type of activity,
and particularly prior to release of any
documents or other items. Guidance will be
provided to ensure that Sterling responds
cooperatively, but also protects its legitimate
business interests.
20
Corporate Compliance
  • Financial Business Standards
  • Keep Accurate Timely Records. You are expected
    to ensure that all records for which you are
    responsible are accurate and completed on a
    timely basis. Failure to accurately record
    material information, or the recording of false
    or misleading information is not acceptable under
    any circumstances and could result in your
    immediate termination.
  • Protect Company Assets. Sterlings assets are
    solely for use in conducting authorized company
    business. Company assets include computers,
    software, office supplies, as well as other types
    of property such as cash, company records and
    patient information. Employees who improperly
    use company property, funds, or information, or
    assist in the inappropriate use will be subject
    to disciplinary action.

21
Corporate Compliance
  • Financial Business Standards
  • Ensure Accurate Billing Coding Practices.
    Sterling is committed to ensuring that its
    billing and reimbursement practices comply with
    all laws, rules and guidelines so that bills
    presented to patients and payors are accurate and
    compliant. This includes
  • Billing only for services that are medically
    necessary, actually provided, and properly
    documented in the patients medical record.
  • Not knowingly submitting for reimbursement a
    claim we know to be false, fraudulent or
    fictitious.
  • Assigning diagnostic, procedural or billing codes
    that accurately reflect the services that were
    provided upcoding, unbundling, or any other
    means of artificially enhancing reimbursement is
    unlawful and strictly prohibited.
  • Regularly reviewing records for credit balances
    and promptly refunding any overpayments.
  • Maintaining records in a secure manner for the
    period of time required by law. Premature
    destruction or alteration of any document in
    response to, or in anticipation of a request by
    any government agency or court is strictly
    prohibited.
  • Responding to questions and complaints related to
    patient bills in a direct and honest manner.
  • All workforce members whose responsibilities
    include involvement in patient registration,
    submission of charges, diagnostic or procedural
    coding of charges, or billing of charges must
    follow all laws, rules and guidelines.
  • Sterling is committed to providing appropriate
    training and guidance toward this end.

22
Corporate Compliance
  • Avoid Conflicts of Interest
  • As part of your association with Sterling, you
    are expected to avoid situations
  • that may influence your ability to be objective
    in your decision making, affect
  • your job performance, or result in personal
    financial gain.
  • Examples include
  • Serving as an officer/employee of an organization
    that is a competitor of Sterling.
  • Hiring Sterling vendors/contractors to perform
    personal work without administrative approval.
  • Endorsing/giving a testimonial for a vendor,
    supplier, contractor without administrative
    approval.
  • Misusing confidential information for personal
    gain.
  • Promoting a business in which you have a direct
    or indirect interest on company time.
  • Everyone must ensure that their activities and
    the
  • transactions they enter into do not violate
    federal anti-
  • kickback statutes. Any financial arrangements
    must
  • reflect the fair market value of goods/services
    provided.

23
Corporate Compliance
  • Contributions Charitable Donations
  • Sterling receives requests, from time to time, to
    make contributions or charitable donations in the
    communities which it serves. The requested
    donations are generally to support community
    health and awareness initiatives that involve our
    hospital clients.
  • Sterling has established a Contributions
    Charitable Giving Committee that reviews all such
    requests. The Committee adheres to established
    guidelines and protocol when making decisions on
    requests for contributions and donations.
  • The Committee will ensure that all contributions
    and charitable donations are ethical, consistent
    ,and in compliance with all Sterling policies and
    procedures, as well as all federal, state and
    local laws, particularly the federal Stark
    self-referral and anti-kickback statutes.
  • All requests for contributions or charitable
    donations must be submitted to the Committee for
    review and a decision. A form is available for
    your use it is posted to the Intranet along with
    Compliance Policies and Procedures.

24
Corporate Compliance
  • There is no pillow so soft as a clear
    conscience.
  • - Japanese Proverb

25
Corporate Compliance
  • Our Commitment to You
  • Sterling is committed to ensuring that all
    employees and associates of the organization are
    aware of the conduct that is expected of them
    while performing their job responsibilities.
  • Training and education on our Code of Conduct and
    associated policies and procedures will be
    provided on an on-going basis.
  • It is critical that our Compliance Program
    effectively communicates compliance issues at all
    levels of the organization.
  • To that end, we encourage you to bring
    suggestions, ideas, concerns and problems to our
    attention through the regular chain of command,
    or by contacting the Compliance Officer or the
    Hotline.

26
Corporate Compliance
  • The ETHICS QUICK TEST
  • As you carry out your daily job responsibilities,
    you will make many decisions. Some will be
  • very simple, others more complicated. Our Code
    of Conduct and Compliance Policies and
  • Procedures, along with this training is intended
    to provide you with guidance for doing the right
  • thing and conducting all your business
    activities in a professional and ethical manner.
  • Additionally, the following ETHICS QUICK TEST may
    help you decide what you should do if
  • you are confronted with an ethical situation and
    are unsure how to handle it.
  • DOES this situation violate any laws,
    regulations, or policies/procedures?
  • WHY does this situation make me feel
    uncomfortable?
  • HOW would I feel if I did it?
  • HOW would it look to my family and friends or it
    if was printed in the newspaper?
  • IF you think it is wrong dont do it!
  • ASK QUESTIONS! If you cannot get a satisfactory
    answer from your supervisor, call the Compliance
    Officer of the Hotline.

27
Corporate Compliance
  • Achieving Ethical Lawful Excellence at Sterling
  • Compliance happens only when YOU make it happen!
  • Each and every one of us plays an integral part
    in the effectiveness of our Compliance Program.

Snowflakes are one of natures most fragile
things, but just look at what they can do, when
they stick together.
28
Corporate Compliance
  • Insert Compliance Post-Test Here

29
Corporate Compliance
  • Certificate of Completion of Compliance Training
  • I have completed the Corporate Compliance
    Training module and submitted my completed
    compliance post-test.
  • I have received a copy of Sterlings Code of
    Conduct and will follow instructions for review
    of the Code, and completion and submission of the
    Statement of Understanding and Compliance.
  • I agree to review and adhere to all compliance
    policies and procedures and direct any questions
    to the Compliance Officer.
  • Name
  • submit

30
Corporate Compliance
  • Certificate of Completion of Compliance Training
  • I have completed the Corporate Compliance
    Training module and submitted my completed
    compliance post-test.
  • I have received a copy of Sterlings Code of
    Conduct and will follow instructions for review
    of the Code, and completion and submission of the
    Statement of Understanding and Compliance.
  • I agree to review and adhere to all compliance
    policies and procedures and direct any questions
    to the Compliance Officer.
  • Name
  • submit

31
Corporate Compliance
  • Certificate of Completion of Compliance Training
  • I have completed the Corporate Compliance
    Training module and submitted my completed
    compliance post-test.
  • I have received a copy of Sterlings Code of
    Conduct and will follow instructions for review
    of the Code, and completion and submission of the
    Statement of Understanding and Compliance.
  • I agree to review and adhere to all compliance
    policies and procedures and direct any questions
    to the Compliance Officer.
  • Name
  • Date
  • submit
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