Broward Health’s Code of Conduct provides an overview of our guiding principles of how we conduct business and comply with the law. It addresses behaviors that our Workforce Members must follow. The Code of Conduct will be reviewed on a yearly basis. Our Code of Conduct reinforces Broward Health’s commitment to:
Our Code of Conduct also applies to vendors and their representatives. Vendors must follow all laws, including the Anti-Kickback statute, HIPAA, and others. They must be approved and follow certain rules when on site at Broward Health facilities, avoid conflicts of interest, and communicate properly during the bid process.
To learn more about vendor registration, please visit vendor.browardhealth.org.
The Chief Compliance Officer is responsible for developing written policies and procedures governing the Compliance Program. These policies demonstrate the organization’s commitment to compliance and address key risk areas.
Reports or reasonable indications of fraud, waste or abuse, violations of Broward Health's compliance program, violations of Broward Health's Code of Conduct, or violations of applicable laws and regulations are promptly investigated. The purpose of the investigation shall be to identify those situations involving fraud, waste, abuse, relevant violations and unacceptable conduct; also, to identify individuals who may have knowingly or inadvertently caused or participated in such instances. The results of an investigation may identify the need for further training and education; to facilitate corrective action; and to implement procedures necessary to ensure future compliance.
Because of the many situations or problems which are possible, the process or method of investigation is at the discretion of the Compliance Officer and will be determined on a case-by-case basis, with consultation from the Office of General Counsel, and in coordination with the President/CEO of Broward Health as appropriate.
When there is information of potential compliance violations or misconduct, the Chief Compliance Officer has the responsibility of conducting an investigation. An internal investigation may include interviews and a review of medical records, billing, and other relevant documents.
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