Enclosure_2_Sample_Exhibit_E_-_Corporate_Compliance_Code_of_Conduct_(Third_Parties).pdf

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Attached to
After-Hours Pharmacy Remote Order Entry Services
Solicitation number
66000-2425-201
Issued by
San Mateo County, San Francisco City, California

About this file

This document 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 San Mateo County, California. The code of conduct establishes compliance requirements for all contractors engaged by SMMC, including obligations to comply with Federal and State health care program requirements, submit accurate information for Federal health care cost reports such as Disproportionate Share Hospital (DSH) payment data, and report suspected violations of health care program requirements to the SMMC Compliance Officer within fifteen (15) days of discovery. Contractors are prohibited from offering, accepting, or giving kickbacks, bribes, payments, gifts, or things of value in relation to any business or regulatory relationships with SMMC, and must not engage in activities that interfere with contract performance or involve unauthorized use of SMMC or County property and resources. The contract term for the After-Hours Pharmacy Remote Order Entry Services procurement is five years, with a proposal submission deadline of June 26, 2025, at 1:00 PM.

The estimated contract budget is $1,000,000. Evaluation will be weighted 75% on method, approach, experience, and organizational capacity, and 25% on price, with the County reserving the right to conduct interviews with top-scoring proposers before making a final selection based on overall best value. Contractors must maintain comprehensive insurance coverage including cyber liability, general liability, workers' compensation, and professional liability; employ personnel located in the United States; conduct background security checks; provide annual security awareness training; and maintain an incident response plan with breach notification within 24 hours. Additional compliance requirements include adherence to the Living Wage Ordinance, Section 504 Rehabilitation Act compliance, and strict HIPAA Business Associate Requirements. All work products and intellectual property developed under the contract will be retained by the County of San Mateo. The Compliance Hotline (800) 965-9775 is available for contractors to report violations, with SMMC committed to maintaining confidentiality and preventing retaliation against those making good-faith reports.

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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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