Enclosure_2_Sample_Exhibit_E_-_Corporate_Compliance_Code_of_Conduct_(Third_Parties).pdf

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Attached to
Orthopedic Hardware Removal and Extraction System Services
Solicitation number
66600-2526-252
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 San Mateo County, California. The document establishes compliance requirements and ethical standards that all contractors must acknowledge and adhere to as a condition of their engagement. Contractors are required to demonstrate full commitment to compliance with all Federal, State, and governmental health care program requirements, including accurate submission of health care cost reports and acute available bed count information for Disproportionate Share Hospital payments. Contractors must report any suspected violations of Federal health care program requirements to the SMMC Compliance Officer within fifteen days of discovery and have access to an anonymous disclosure program via the Compliance Hotline at (800) 965-9775.

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 or the County, and requires prompt reporting of any such offers or receipts to the Compliance Officer. Contractors must not engage in any financial, business, or other activity that may interfere with or appear to interfere with their contractual duties or involve unauthorized use of SMMC/County property, facilities, or resources. Non-compliance with these requirements and health care program regulations may result in contract termination and other penalties permitted by law. Contractors are responsible for acquiring sufficient knowledge to recognize compliance issues applicable to their duties and must cooperate fully in all audits and compliance reviews conducted by outside agencies. By executing an agreement with SMMC, an authorized contractor representative certifies understanding of and commitment to this Code of Conduct.

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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.

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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.

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