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 (Third Parties), issued by Santa Monica Medical Center (SMMC). 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 claims and reports, including specific documentation like acute available bed count for Disproportionate Share Hospital (DSH) payments, and must report any suspected violations within 15 days of discovery.
The document establishes strict ethical guidelines for contractors, prohibiting kickbacks, bribes, inappropriate gifts, or any activities that might interfere with contractual duties. Contractors have access to an SMMC Disclosure Program via a compliance hotline (800-965-9775) and are guaranteed non-retaliation and confidentiality when reporting issues. The code emphasizes that non-compliance could result in contract termination and potential legal penalties. Contractors must proactively recognize potential compliance issues, seek appropriate advice, and commit to full cooperation during any external audits or compliance reviews.
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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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