Compliance Program Training
for First Tier, Downstream and
Related Entities
This is an audio presentation
Compliance Program Training
for First Tier, Downstream and
Related Entities
Compliance Program Training
Agenda
• What is the Compliance Program?
• What does this mean to me?
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Prime's Compliance
Department and Program
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Compliance Program Training
Our Mission
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Compliance Program Training
Do business with integrity and in
accordance with all applicable
laws and regulations
Implement any policy and
procedure changes needed to
prevent recurrences of a violation
Prevent unethical
or unlawful
behavior
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Halt any such
behavior as
soon as
reasonably
possible after its
discovery
Use disciplinary action as
necessary
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Compliance Program Training
Prime’s Compliance Program includes the following
components:
 Written Standards
 Compliance Officer and Committee
 Delegation of Authority
 Communication of Standards (Training)
 Monitoring, Auditing and Reporting
 Enforcement and Discipline
 Response and Prevention
 Fraud, Waste & Abuse
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Compliance Program Training
Compliance Officers and Compliance Committees
•
Prime has a Chief Compliance Officer who reports directly to the Audit and
Finance Committee of the Board of Directors and the CEO
> The Chief Compliance Officer chairs the Compliance Committee which consists of
Prime’s executives.
> The Compliance Committee meets regularly and oversees a number of areas,
including, but not limited to, implementation of Compliance Training, Corrective
Action Plans and coverage gaps as reported from our internal audit team.
> The Chief Compliance Officer also oversees the Compliance Department and the
Compliance Program.
•
Prime has a Government Programs Compliance Officer who reports directly
to the Chief Compliance Officer.
> The Government Programs Compliance Officer chairs the Government Programs
Compliance Committee which consists of individuals from within a cross-functional
group of departments within Prime.
> The Government Programs Compliance Committee meets regularly and develops
strategies to promote compliance, reviews significant compliance risks and ensures
proper communication of compliance issues, among other functions.
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Compliance Program Training
Prime’s Compliance Department
• Audit (Compliance Audit and Pharmacy Audit)
• Government Programs Compliance
• Regulatory Response
• Licensing
• Privacy
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Compliance Program Training
Prime’s active Compliance Program
• Non-Retaliation
> Prime prohibits retaliation against anyone for reporting
concerns.
• Investigations into Compliance Issues
> All reports of improper behavior are fully investigated.
• Corrective Actions
> You are expected to perform all
assigned tasks and responsibilities
to meet your job expectations and
standards.
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Compliance Program Training
Reporting violations of the Code and the Compliance
Program
•
•
•
•
•
•
Supervisor
•
Anonymous reporting on the
website: http://www.lighthouseservices.com/prime
•
Anonymous email:
reports@lighthouse-services.com
Human Resources Manager
Legal Department
Compliance Department
Compliance Officer
Anonymous 24 Hour Hotline:
1.800.474.8651
REMEMBER: You can report Compliance Concerns without
fear of retaliation or retribution
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Compliance Program Training
Thank you
• Thank you for taking Prime’s Compliance Program training.
• Please make sure you are familiar with the various requirements in
the Compliance Program.
> Questions? Please contact the Compliance Department.
> 612.777.5457
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