Saturday, January 6, 2007

Why we have a hot line

In my greeting to each class of new employees, I spend a couple minutes talking about “corporate compliance.” That is the technical term for hospital business ethics.

This month a new federal law requires hospitals and other providers[1] to “teach their employees how to ferret out fraud and report it,” according to a New York Times report.[2]

Corporate compliance policies affect all of us who work at CGH. For example, the arrangements we make with vendors and providers must be ethical and legal. None of us can negotiate or manage a contract for the hospital in a way that benefits himself personally. We cannot steer business to favored parties or people with whom we might have a personal or business interest. Our corporate compliance policies mean none of us can accept a monetary gift for providing services,[3] we cannot disclose confidential information, and we cannot use hospital equipment or supplies for personal use.

Under the new law, it is important for CGH to make sure employees know there are specific laws against Medicare or Medicaid fraud and abuse. Employees have an obligation to report a suspected illegality to their employer or to the government, and they have rights when they do so – such as no retaliation for such reporting. People who report suspected fraud to the government are sometimes called “whistleblowers,” and they have specific rights, as well.

We already have a strong corporate compliance policy, and we are updating it to comply with the new law. There will be changes in the employee handbook , as well.

When new employees join us, I am not the only one talking about corporate compliance. Deb Kurtz also addresses the subject with employees. She is CGH’s corporate compliance officer. She is the person any employee can go to about a suspect activity. Deb Kurtz even operates a “hot line” number – 492-5965 – to make it easy to contact her, anonymously, if you wish. She reports directly to the Corporate Compliance Committee of the Board of Directors.

There is a copy of the corporate compliance policy is in your department. Ask your supervisor to see it, and feel free to ask questions of your supervisor or Deb Kurtz if you think something is not right. If you think something at CGH might not comply with the law or is of questionable ethics, please speak up. Tell your supervisor or report the matter to Deb Kurtz at extension 5965.

[1] “Other health care providers” includes physicians groups, health maintenance organizations, pharmacies, medical equipment suppliers, and home care agencies.

[2] “At Hospitals, Lessons in Detection of Fraud,” New York Times, December 24, 2006.

[3] Employees may not solicit gifts from patients or others, but the Corporate Compliance Policy does permit an employee to accept an unsolicited gift of nominal value, that is, $30.00 or less. See CGH the Corporate Compliance Program Handbook, p. 13.

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