Enclosure_2_Sample_Exhibit_E_-_Corporate_Compliance_Code_of_Conduct_(Third_Parties).pdf
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- Attached to
- Hosptial and Professional Coding Audits
- Solicitation number
- 66000-2526-219
- Issued by
- San Mateo County, San Francisco City, California
About this file
This document is Exhibit E: Corporate Compliance SMMC Code of Conduct for Third Parties, involving Santa Monica Medical Center (SMMC) and its contractual partners. The exhibit outlines comprehensive compliance requirements for contractors working with SMMC, mandating full adherence to federal, state, and governmental health care program regulations. Contractors are required to submit accurate reports, including details like acute available bed count for Disproportionate Share Hospital (DSH) payments, and report any suspected violations of health care program requirements within fifteen days of discovery.
The document establishes strict ethical guidelines for contractors, prohibiting kickbacks, bribes, inappropriate gifts, and activities that might interfere with contractual duties. Contractors must cooperate fully with potential audits, understand compliance issues applicable to their duties, and have the right to use SMMC's Disclosure Program through a dedicated Compliance Hotline. Non-compliance could result in termination of the agreement and potential legal penalties. The code emphasizes transparency, honesty, and commitment to maintaining the integrity of health care program interactions, with SMMC committed to non-retaliation and maintaining confidentiality for reported incidents.
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EXHIBIT E
CORPORATE COMPLIANCE SMMC CODE OF CONDUCT (THIRD PARTIES)
Contractor recognizes and is fully dedicated to advancing SMMC’s commitment to full compliance with all Federal, State, and other governmental health care program requirements, including its commitment to prepare and submit accurate claims consistent with such requirements.
Contractor will comply with all Federal, State or other governmental health care program requirements.
Contractor, to the extent its contractual duties require it to submit the reports covered in this paragraph, will promptly submit accurate information for Federal health care cost reports including, but not limited to, the requirement to submit accurate information regarding acute available bed count for Disproportionate Share Hospital (DSH) payment.
Contractor will report to the SMMC Compliance Officer any suspected violation of any Federal health care program requirements within fifteen (15) days of discovery of the violation.
Contractor has the right to use the SMMC Disclosure Program by calling the Compliance Hotline at (800) 965-9775 or reporting incidents directly to the Compliance Officer. SMMC is committed to non-retaliation and will maintain, as appropriate, confidentiality and anonymity with respect to such disclosures.
Contractor understands that non-compliance with Federal and State health care program requirements, and failing to report any such violations, could result in termination of the Agreement and/or any other penalties as permitted by law.
Contractor is responsible for acquiring sufficient knowledge to recognize potential compliance issues applicable to the duties outlined in the Agreement and for appropriately seeking advice regarding such issues.
Contractor will not offer, give, or accept any “kickback,” bribe, payment, gift, or thing of value to any person or entity with whom SMMC has or is seeking any business or regulatory relationship in relation to said business or regulatory relationship (other than payments authorized by law under such relationships). Contractor will promptly report the offering or receipt of such gifts to the SMMC Compliance Officer.
Contractor will not engage in any financial, business, or other activity which may interfere or appear to interfere with the performance of the duties under the Agreement or that involve the use of SMMC/County property, facilities, or resources.
Template Version December 2, 2016 1
Contractor will cooperate fully and honestly in the event that SMMC and/or County is audited by an outside agency including, but not limited to, compliance audits regarding enforcement of Federal and State regulations, any applicable accreditation standards, and/or SMMC system-wide policies.
TO REPORT VIOLATIONS,
CALL THE COMPLIANCE HOT LINE: (800) 965-9775
Contractor, in executing this Agreement, certifies that an authorized representative has received this Code of Conduct, understands it, has authority to commit Contractor to this Code of Conduct, and has committed Contractor to comply with this Code of Conduct.
Template Version December 2, 2016 2
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