Enclosure_2_Sample_Exhibit_E_-_Corporate_Compliance_Code_of_Conduct_(Third_Parties).pdf

PDF 33 KB Posted

Attached to
FOHC Lobbies AV
Solicitation number
66600-2526-236
Issued by
San Mateo County, San Francisco City, California

About this file

This is a Corporate Compliance Code of Conduct document for third-party contractors working with San Mateo Medical Center (SMMC), a public hospital and clinic system in San Mateo County, California. The document establishes mandatory compliance requirements for all contractors regarding federal, state, and local health care program regulations. Contractors must submit accurate information for federal health care cost reports, including specific documentation related to Disproportionate Share Hospital (DSH) payments and acute available bed counts. Any suspected violations of federal health care program requirements must be reported to the SMMC Compliance Officer within fifteen days of discovery. SMMC provides a Disclosure Program accessible via a Compliance Hotline at (800) 965-9775 for reporting incidents directly to the Compliance Officer.

The Code of Conduct prohibits contractors from offering, giving, or accepting kickbacks, bribes, payments, gifts, or anything of value in relation to business or regulatory relationships with SMMC. Contractors are responsible for acquiring sufficient knowledge to recognize potential compliance issues applicable to their contractual duties and must avoid any financial, business, or other activities that may interfere with or appear to interfere with their performance or that involve the use of SMMC or County property, facilities, or resources. SMMC is committed to non-retaliation and will maintain confidentiality and anonymity regarding disclosures made through the established channels. Contractors must cooperate fully and honestly during audits conducted by outside agencies, including compliance audits regarding federal and state regulation enforcement and accreditation standards. Non-compliance with these requirements may result in contract termination and other penalties as permitted by law.

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Text version

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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