The Organizational Integrity Program

Transcription

1 The Organizational Integrity Program Supporting Right Relationships SJMHS New Associate Orientation 1

2 Overview Integrity Why is this important? Standards of Conduct Supporting Right Relationships Key Areas: privacy and security of information, conflicts of interest, fraud and abuse, False Claims Act What is expected of you as an Associate of SJMHS Integrity Scenarios The Organizational Integrity Program (OIP) Overview Your Local Integrity Officer Where to Find Help The Integrity Line No Retaliation Policy Education and Training 2

3 Organizational Integrity Program (OIP) The OIP demonstrates SJMHS commitment to ensure integrity in our operations and compliance with laws and regulations The OIP includes the 7 Elements displayed at right You should be aware of: Oversight responsibilities for the OIP Reporting issues and concerns Education and training Standards of Conduct, Policies & Procedures Oversight Responsibilities Reporting Issues and Concerns Education & Training Organizational Integrity Program Response & Prevention Monitoring & Auditing Enforcement & Discipline 3

4 Why Integrity? Integrity: Firm adherence to a code, especially moral values (Merriam Webster) Integrity is fundamental to our Mission and Values We all want to work in a place where: We can count on one another to do the right thing We have ways to discuss and resolve issues about what is right Everyone is comfortable asking questions and raising concerns without fear 4

5 Are Compliance and Integrity the Same Thing? Compliance Let s go out and not break the law today Can I do this? Integrity Compliance with law is the minimum expectation Emphasis on ethical behavior and actions consistent with Trinity Health s Mission and Values Should I do this? Why Is This Important? In health care today, we frequently face situations where the answers are not always clear Can you think of examples you ve faced in your prior work? 5

6 Standards of Conduct The Standards of Conduct describe behaviors and conduct expected of all: Associates Contract workers Medical staff Volunteers Our business partners The Standards of Conduct include questions and answers to common situations encountered in the workplace 6

7 Supporting Right Relationships Achievement of our Mission and Vision requires us to maintain Right Relationships with: Patients, residents, their family members and others in our care Co-workers and other team members Vendors, business partners and others who assist us in delivering health care services Government and other payers that pay for the health care services we provide Our organization and our communities 7

8 Relationships with Patients, Families and Others Associates are expected to: Deliver services with compassion, dignity and respect Maintain a positive, courteous and customer-service oriented attitude Speak kindly to patients, their families and others Act in the best interests of patients and others in your care Respond to requests for information, input or assistance in a timely manner Deliver services in accordance with all professional standards Maintain complete, accurate and timely medical records Protect the privacy and confidentiality of all medical and other information 8

9 Privacy and Security of Information Various federal and state laws require SJMHS to protect the privacy and security of patient information You must respect and protect the privacy and confidentiality of all patient, business and other information you may use or encounter in your work This includes: Securing documents, files and other records containing patient and business information Using information systems properly and only for authorized business purposes Protecting the physical security of any computer or other devices containing patient or business information 9

10 Relationships with Co-Workers and Others Associates are expected to: Treat others with honesty, dignity, fairness and respect Maintain a positive, courteous and customer-service oriented attitude Speak kindly and patiently to co-workers and others Respond to requests for information, input or assistance in a timely manner Communicate with others in a clear, open and honest manner Address differences directly with the individuals involved Respect the diversity of others Respect the individual privacy of co-workers and others 10

11 Relationships with Vendors, Business Partners and Others Associates are expected to: Maintain a positive, courteous and customer-service oriented attitude with vendors and business partners Maintain objectivity and avoid actual or potential Conflicts of Interests in relationships with vendors and business partners Follow policies requiring disclosure and advance approval of any situation that could represent a Conflict of Interest with your work at SJMHS Make decisions in the best interest of our patients and SJMHS 11

12 Conflicts of Interest What is a Conflict of Interest? When outside activities or relationships influence or could appear to influence decisions you make at SJMHS Examples of Potential Conflicts of Interest Accepting or offering gifts and entertainment, including free or discounted travel, lodging, meals, from/to vendors or others doing business with SJMHS Working for a competitor of SJMHS Doing business with or recommending a company in which you or a family member has an employment, ownership or compensation arrangement SJMHS You must obtain the advance approval of your supervisor for any situation that could present an actual or potential Conflict of Interest 12

13 Relationships with Government and Other Payers Associates are expected to: Act with honesty and integrity in all business activities Follow all laws and regulations that apply to your work and ask for assistance if you have questions Follow all requirements of government (e.g. Medicare and Medicaid) and other third-party payers that pay for health care services Participate in training and education on laws and regulations that apply to your work responsibilities Cooperate with any government investigation. Never destroy or alter documents or make false statements in connection with a government investigation 13

14 Fraud and Abuse What is Fraud? Intentional acts of deception or misrepresentation Acting with knowledge or in reckless disregard of the rules What is Abuse? Improper or excessive use of a program or service (e.g. Medicare or Medicaid) Examples of fraud and abuse in health care Falsifying records Submitting inaccurate or misleading claims for services Submitting claims for services never provided Submitting claims that don t meet payer requirements Lying to obtain payment for services Offering or paying money, goods, or anything of value for patient referrals Offering or giving something of value to patients to encourage them to use or purchase health care services 14

15 The False Claims Act SJMHS is a participant in the federal health care programs like Medicare and Medicaid The False Claims Act is a federal law that makes it a crime to knowingly make a false record or file a false claim involving federal health care programs Refer to the False Claims Act (FCA) information in your Standards of Conduct describing: What is a False Claim? Information on state laws similar to the federal FCA Penalties for violating the FCA Protections for individuals who file a lawsuit under the FCA Our commitment to prevent and detect fraud, waste and abuse in federal health programs 15

16 What is Expected of You Review and follow the Standards of Conduct at all times Pay particular attention to areas that may impact your job responsibilities Ask questions if you re uncertain what to do see Where to Find Help Speak-up when concerned about actions or behaviors that are inconsistent with the Standards of Conduct You will be held accountable for actions and behaviors inconsistent with the Standards of Conduct Violations may result in disciplinary action, up to and including termination 17

17 Integrity Scenarios 18

18 Handling Difficult Integrity Issues Examples: You suspect your co-worker is leaving work early and that another co-worker is swiping their badge at the end of shift time You suspect your manager may be using hospital resources for personal use What do you do? 19

19 Questions to Ask Yourself When faced with a difficult issue or situation where you don t know what to do, consider the following: Is the decision being considered consistent with our Mission and Values? Would I be comfortable telling my family about the issue or having it described on television or in a newspaper? Could the issue impact the reputation of SJMHS if it was made public? Could the issue negatively impact patients or the communities we serve? Is there something about the issue that bothers you, makes you feel uncomfortable, or just doesn t feel right? If the answer to any of these questions is yes, seek help 20

20 Where to Find Help You are responsible for seeking answers to your questions and concerns Many resources are available to assist you including: Your Supervisor or Manager (usually the best place to start) Higher-Level Manager Human Resources Mission/Spiritual Care/Ethics Resources Quality, Risk Management and Safety Departments Privacy and Security Officials Local Integrity Officer The Trinity Health Integrity Line 21

21 Local Integrity Officer Our System Integrity Officer is a member of senior management, responsible for the operation of the Organizational Integrity Program. Ruth Shantz, SIO 22

22 Trinity Health Integrity Line You may also file a report online at: Use access code: THO 23

23 Trinity Health Integrity Line Available 24/7/365 Answered by an outside service using trained professionals Reports are sent to the Trinity Health Organizational Integrity Department within 1 business day Calls and reports are not recorded/traced and Integrity Line does not use Caller-ID Callers may remain anonymous, if you chose; All reports are treated confidentially Individuals can check back later on status and resolution of reports 24

24 No Retaliation Policy SJMHS policy strictly prohibits retaliation, in any form, against an individual reporting an issue or concern in good faith Retaliation is subject to discipline, up to and including termination of employment, suspension of medical staff privileges, or termination of business relationships 25

25 Education and Training Education and training is a key component of the OIP today s program is an example You will be asked to participate in periodic OIP education and training programs your participation and support is required The duration and frequency of OIP training will depend on your specific job at SJMHS Additional training is required if your role requires knowledge and understanding of specific laws and regulations that apply to federal health care programs Your Manager or Supervisor is responsible for ensuring your education and training needs are met and can answer your questions 26

26 We Are All Accountable SJMHS is committed to acting with integrity and making decisions based on the highest standards of ethical behavior This commitment includes full compliance with all applicable laws and regulations As an associate of SJMHS, your support is critical to our success! We are all accountable support of our OIP is an expectation and a requirement for all who work at SJMHS Thank-you for supporting Right Relationships! 27