Enclosure_2_Sample_Exhibit_E_-_Corporate_Compliance_Code_of_Conduct_(Third_Parties).pdf
PDF 33 KB Posted
- Attached to
- Coding Services
- Solicitation number
- 66000-2526-232
- Issued by
- San Mateo County, San Francisco City, California
About this file
This is a Corporate Compliance Code of Conduct exhibit for third-party contractors working with San Mateo Medical Center (SMMC), a public hospital and clinic system in California. The document outlines SMMC's commitment to federal and state healthcare program compliance and establishes mandatory conduct standards for all contractors engaged to provide services. The coding services contract, for which this compliance document applies, requires proposals due February 11, 2026, at 1:00 p.m. via the eProcurement portal, with questions accepted until January 28, 2026. The contract is structured as a five-year agreement with no renewal options mentioned. The coding services scope encompasses support for Emergency Room visits, inpatient cases, long-term care, observation cases, same-day surgery, and clinic visits, with all coders required to hold AAPC or AHIMA certification and be located within the United States. Services must achieve a minimum 95 percent accuracy rate with semi-annual quality measurement reporting.
Contractors must comply with all federal and state healthcare program requirements and are responsible for promptly reporting suspected violations to the SMMC Compliance Officer within 15 days of discovery through the Compliance Hotline at (800) 965-9775. The code of conduct prohibits kickbacks, bribes, gifts, or payments to any entity with whom SMMC conducts business and forbids activities that interfere with contract performance or involve unauthorized use of SMMC or County property and resources. Contractors must maintain cyber liability insurance of $5,000,000 per occurrence, demonstrate five years of similar services experience, and provide proof of legal authorization to conduct business in California, SAM.GOV registration, and non-debarred status. Non-compliance with healthcare program requirements or failure to report violations may result in contract termination and other penalties permitted by law. The procurement offers local business and non-profit preferences with 5 to 10 percent preferential points available for small or micro businesses, and the contract is established as a cooperative procurement allowing other organizations to utilize the resulting agreement.
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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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