Enclosure_2_Sample_Exhibit_E_-_Corporate_Compliance_Code_of_Conduct_(Third_Parties).pdf
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- Attached to
- Provider Time Tracking, Invoicing and Approval
- Solicitation number
- 66600-2526-240
- 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 compliance requirements and ethical standards that all contractors must acknowledge and adhere to throughout their engagement with SMMC. Key obligations include submitting accurate information for federal health care cost reports, reporting suspected violations of federal and state health care program requirements within fifteen days of discovery, and refraining from offering or accepting kickbacks, bribes, or improper gifts. Contractors must cooperate fully with audits by outside agencies, avoid conflicts of interest involving SMMC property or resources, and maintain knowledge of applicable compliance issues related to their contractual duties. The document emphasizes SMMC's commitment to non-retaliation and confidentiality for those reporting violations through the designated Compliance Hotline at (800) 965-9775.
By executing any agreement with SMMC, contractors certify that an authorized representative has received, understood, and committed to compliance with this Code of Conduct. Non-compliance with federal and state health care program requirements or failure to report violations may result in contract termination and other legal penalties. This compliance framework applies to the Provider Time Tracking, Invoicing and Approval services contract, which involves a five-year agreement with the County of San Mateo and requires contractors to handle protected health information in accordance with HIPAA regulations and maintain specified insurance coverage including cyber liability protection of $5,000,000 per occurrence.
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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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