KADLEC MEDICAL CENTER HOUSE-WIDE Section: 1500 POLICY AND PROCEDURES TITLE: ROLES AND RESPONSIBILITIES OF COMPLIANCE COMMITTEE ADMINISTRATIVE APPROVAL: POLICY: X PROCEDURE: GUIDELINE: STANDARD: NO. 1504 EFFECTIVE DATE: PENDING PAGE 1 OF 3 SUPERSEDES: 11/98 REVISION INITIATED: COMMITTEE APPROVAL/REVIEW: Compliance Committee 06/02 DEVELOPMENT TEAM/AUTHOR(S): AUDIT REVIEW: Randy Stanper ,Attny/04/02, Jennie Martin, Compliance Officer /05/02, Compliance Committee/06/02 The Board of Directors of the Hospital has established the Compliance Committee to oversee and administer the Compliance Program. The Compliance Committee, acting through and with the assistance of the Compliance Officer, has the following responsibilities: The Compliance Committee is established to advise the Compliance Officer, assist in identifying areas of risk, and monitoring the ongoing effectiveness of the Compliance Program. Regular review of Compliance Program policies to ensure they adequately address legal requirements and address identified risk areas Analyze the effectiveness of compliance education and training programs Review compliance log for adequate and timely resolution of issues and/or inquiries Assist in identifying areas of potential violations and establishing periodic monitoring /audit programs Assist in development of policies addressing remediation of identified problems Provide a forum for the discussion of ethical issues related to hospital business functions The Compliance Committee will be chaired by the Compliance Officer and will consist of members appointed by Hospital administration. The Compliance Committee will be composed of employees representing the following areas or functions: Patient Financial Services Risk Management Clinical Ancillary Area Physician Recruiter Emergency Department Finance Materials Management Quality Care Management Human Resources Information Systems Medical Records The Compliance Committee shall meet periodically to review and consider any inquiries conducted or supervised by the Compliance Officer. Prior to such meetings, the Compliance Officer shall submit to each Compliance Committee member an agenda enumerating matters to be reviewed by the Compliance Committee. The President and CEO or the Compliance Officer may call special meetings of the Compliance Committee. All submissions to the Compliance Committee by the Compliance Officer shall be marked “Confidential.” Minutes will be recorded of all meetings and will KADLEC MEDICAL CENTER POLICIES & PROCEDURES TITLE: ROLES AND RESPONSIBILITIES OF DATE: NO. 1504 Page 2 of 2 COMPLIANCE COMMITTEE be maintained in the office of the Compliance Officer. The Compliance Officer shall communicate the Compliance Committee’s actions and recommendations to appropriate Hospital officers, employees, and representatives. The Compliance Committee, acting through the Compliance Officer, is empowered to investigate, evaluate, and report facts, and make recommendations to the President and CEO and the Board of Directors of possible responses or initiatives, including disciplinary or other adverse action for misconduct by Hospital employees. The Compliance Committee shall review and evaluate the information developed and recommendations made by the Compliance Officer and other members of the Compliance Committee. The Compliance Committee will report to and consult with the President and CEO and the Ethics Committee and Governance Committee of the Board of Directors. In conducting investigations (including Hotline complaints), the Compliance Committee shall respect the confidentiality of privileged records and information and shall comply with applicable confidentiality laws and ethical standards. All files of inquiries shall be marked “Confidential” and maintained by the Compliance Officer on a confidential basis. They shall not be disclosed except: (i) to members of the Compliance Committee; (ii) to legal counsel retained by the Compliance Officer and/or the Compliance Committee; (iii) to individuals or need to know and authorized by the Compliance Committee to receive such information; or (iv) as may be required by law or order of a court of competent jurisdiction.