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Unformatted text preview: Alan Yuspeh et al. 3 Alan Yuspeh, Kathleen Whalen, Jerone Cecelic, Steven Clifton, Lisa Cobb, Mark Eddy, Jill Fainter, Julie Packard, Susan Postal, Joe Steakley, and Paula Waddey ABOVE REPROACH: DEVELOPING A COMPREHENSIVE ETHICS AND COMPLIANCE PROGRAM The authors all hold positions with Columbia/HCA Healthcare Corporation and have been actively involved in the ethics and compliance efforts of that organization over the last two years. The authors hold positions as follows: Alan R. Yuspeh, J.D., senior vice president, Ethics, Compliance & Corporate Responsibility; Kathleen M. Whalen, J.D., director, Ethics and Compliance Program Development; Jerone C. Cecelic, J.D., director, Corporate Integrity; Steven E. Clifton, J.D., vice president, Legal Operations; Lisa Cobb, vice president, Business Office Support; Mark J. Eddy, C.P.A., assistant vice president, Internal Audit &Consulting Services; Jill Fainter, assistant vice president, Quality Standards; Julie K. Packard, director, Billing Compliance, Support, Governmental Operations; Susan N. Postal, R.R.A., vice president, Health Information Management Services; Joe N. Steakley, C.P.A., senior vice president, Internal Audit & Consulting Services; Paula E. Waddey, C.P.A., director, Education & Training, Governmental Operations. Executive Summary How can a healthcare organization improve the publics confidence in the conduct of its business operations? What can it do to ensure that it can thrive despite being the subject of public and governmental scrutiny and doubt? Healthcare providers must establish standards of conduct that are above reproach and ensure that those standards are clearly articulated and strictly adhered to. This article descibes the merits of a comprehensive ethics and compliance program, suggests five basic elements of such a program organizational support/structure, setting standards, creating awareness, establishing a mechanism for reporting exceptions, and monitoring and auditingand then demonstrates how those elements should be applied in several high-risk areas. 4 Frontiers of Health Services Management 16:2 Fundamentally, an ethics and compliance program has two purposes: to ensure that all individuals in an organization observe pertinent laws and regulations in their work; and to articulate a broader set of aspirational ethical standards that are well-understood within the organization and become a practical guideline for organization members making decisions that raise ethical concerns. Every ethics and compliance program should contain certain fundamental aspects. First, the effort must have the active support of the most senior management in the organization. To instill a commitment to ethics and compliance absent a clear and outspoken commitment to such purposes by organization leaders is simply impossible. Second, an ethics and compliance program is fundamentally about organizational cultureabout instilling a commitment to observe the law and, more generally, to do the right...
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- Spring '10