Enclosure_2_Sample_Exhibit_E_-_Corporate_Compliance_Code_of_Conduct_(Third_Parties).pdf

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Attached to
Laser equipment and Techs for the OR
Solicitation number
66600-2526-250
Issued by
San Mateo County, San Francisco City, California

About this file

This document is a Corporate Compliance Code of Conduct exhibit established by San Mateo Medical Center (SMMC), a public hospital and clinic system operated by San Mateo County, California, for all third-party contractors. The code of conduct outlines mandatory compliance requirements for contractors providing laser equipment and technical support services for operating room use. Contractors must comply with all Federal and State health care program requirements, including accurate submission of healthcare cost reports and acute bed count information for Disproportionate Share Hospital payments. All suspected violations of Federal health care program requirements must be reported to the SMMC Compliance Officer within fifteen days of discovery. Contractors have access to the SMMC Disclosure Program through a Compliance Hotline at (800) 965-9775 and are protected against retaliation for good-faith disclosures. The contract term includes specific performance obligations related to operating room technical support, with compliance violations subject to contract termination and legal penalties.

The code of conduct establishes strict prohibitions against kickbacks, bribes, gifts, or payments of value in relation to SMMC business or regulatory relationships, and requires contractors to avoid any activities that interfere with contractual duties or involve misuse of SMMC or County property, facilities, or resources. Contractors must cooperate fully with audits conducted by outside agencies regarding Federal and State regulatory compliance, accreditation standards, and SMMC system-wide policies. All contractor personnel must obtain fingerprinting and background clearance certification, comply with HIPAA requirements, and satisfy Section 504 accessibility compliance standards. An authorized representative of the contractor must execute the agreement and certify understanding and commitment to comply with the code of conduct. The document serves as a mandatory compliance framework applicable to all vendors and contractors supporting SMMC operations, with enforcement mechanisms including contract termination and legal remedies as permitted by law.

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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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