Compliance Office Staff Responsibilities

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County Of San Diego

Health and Human Services Agency

Chapter: Compliance

Topic: Infrastructure

Key Words: Compliance Office, staff, responsibilities, investigations

SUBJECT : Compliance Office Staff Responsibilities NO: HHSA-M-2.4

PAGE 1 of 3

DATE: August 1, 2003

SUPERSEDES: N/A REFERENCE: 63 FR 8987 (February 23, 1998)

63 FR 70138 (December 18, 1998)

65 FR 59434 (October 5, 2000)

PURPOSE :

To define the duties and responsibilities of the County of San Diego Health and Human

Services Agency Compliance Office staff.

BACKGROUND:

On September 10, 2002, the County of San Diego Health & Human Services Agency (“HHSA”) established the Compliance Program. The Compliance Program is structured on the guidance provided by the United States Department of Health and Human Services, Office of Inspector

General in 63 FR 8987 (February 23, 1998), 63 FR 70138 (December 18, 1998), and 65 FR

59434 (October 5, 2000) (et. al), as well as on the requirements of the Health Insurance

Portability and Accountability Act of 1996 (HIPAA). The Compliance Office is responsible for implementing a Compliance Program to ensure that HHSA services are provided in compliance with all applicable federal, state, and local laws and regulations.

POLICY :

1. Compliance Office staff shall support the effective operation of the HHSA Compliance

Program by providing support to the Compliance Officer in the development, implementation, and daily operation of the Compliance Program.

2. Compliance Office staff shall be appointed by the HHSA Director after consultation with the Compliance Officer.

3. The Compliance Officer shall be responsible for administering the Compliance Office and supervising the activities of the Compliance Office staff. (See attached Compliance

Office Organizational Chart.)

FUNCTIONS AND RESPONSIBILITIES:

Under the direction of the Compliance Officer, Compliance Office staff shall be responsible for:

1. Assisting the Compliance Officer and Compliance Committee with the development, implementation, review and evaluation of the HHSA Compliance Program.

2. Assisting the Compliance Officer with the day-to-day operations of the HHSA

Compliance Program and pursuing HHSA's compliance objectives.

County Of San Diego

Health and Human Services Agency

Chapter: Compliance

Topic: Infrastructure

Key Words: Compliance Office, staff, responsibilities, investigations

SUBJECT : Compliance Office Staff Responsibilities NO: HHSA-M-2.4

PAGE 2 of 3

DATE: August 1, 2003

3. As assigned by the Compliance Officer, serving as members of the HHSA Compliance

Committee.

4. Maintaining a working knowledge of relevant compliance issues, laws, and regulations through periodicals, seminars, training programs, and peer contact.

5. Assisting the Compliance Officer and Compliance Committee with the development, maintenance and revision of a Code of Conduct and Statement of Incompatible

Activities, and other compliance policies and procedures.

6. Coordinating on-going development and implementation of agency-wide compliance training and communication programs including, but not limited to, development and maintenance of employee reporting channels, including a compliance telephone hotline.

7. Assisting the Compliance Officer in coordinating and monitoring program-specific compliance training and communication efforts.

8. Assisting the Compliance Officer and Compliance Committee with identification of potential areas of HHSA compliance risk.

9. As directed by the Compliance Officer and County Counsel, coordinating and/or conducting compliance investigations of alleged violations of law, regulation and the

Code of Conduct and Statement of Incompatible Activities to ensure proper investigation, follow-up, and resolution, and ensuring appropriate documentation of any such investigations.

10. As directed by the Compliance Officer and County Counsel, responding appropriately if a violation is uncovered, including proper reporting of violations of law to the duly authorized law enforcement or regulatory agencies.

11. Assisting the Compliance Officer and Compliance Committee in establishing audit controls and measurements to ensure that correct processes are in place.

12. Assisting the Compliance Officer in activities related to the implementation of new laws, regulations or policies, including any necessary revisions to the existing Code of

Conduct and Statement of Incompatible Activities, and policies and procedures.

13. Other duties as assigned by the Compliance Officer.

County Of San Diego

Health and Human Services Agency

Chapter: Compliance

Topic: Infrastructure

Key Words: Compliance Office, staff, responsibilities, investigations

SUBJECT : Compliance Office Staff Responsibilities NO: HHSA-M-2.4

PAGE 3 of 3

DATE: August 1, 2003

QUESTIONS/INFORMATION:

Contact the Compliance Officer at (619) 515-4246.

ATTACHMENTS:

None

SUNSET DATE:

This policy will be reviewed for continuance by August 1, 2004.

Approved:

____________________________

Rodger G. Lum, Ph.D.

Director

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