Policies, Procedures and Code of Conduct
These guidelines ensure that everyone understands their roles, responsibilities, and the standards we uphold in patient care and organizational integrity.
1. Code of Conduct
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:
- Provide quality patient care
- Treat others with respect
- Comply with applicable laws, regulations and policies
- Abide by privacy regulations
- Submit complete, accurate and truthful claims for reimbursement
- Prohibit both making and accepting payments for referrals of patients and/or business
- Avoiding conflicts of interest
Vendor Code of Conduct and Compliance Requirements
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.
2. Policies and Procedures
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.
3. Violations and Investigations
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.
Click Here to Submit an Online Report Hotline: 888-511-1370
Certain Policies to Know
- GA-001-015 Conflict of interest
- GA-004-245 Compliance education and training
- GA-016-006 Physician recruiting agreements
- GA-033-002 Post acute care referrals
- GA-004-012 Gifts, gratuities and business courtesies
- GA-006-055 Honoraria and expense reimbursement
- GA-004-442 Referral source contracting requirements
- GA-004-410 Fair market value and commercial reasonableness
- GA-034-004 Approval process for contract PO25 purchase orders
- GA-004-001 Compliance office and human resource protocol
- GA-004-002 Compliance office and general counsel protocol
- GA-004-004 Duty to report
- GA-004-007 Compliance with Federal Anti-Kickback Statute and Stark Law
- GA-004-115 Notification to Affected Individuals of a Breach of Unsecured PHI
- GA-004-135 Record, Retention, Storage and Disposal
- GA-004-013 Medical Director- Program Director Arrangements
- GA-004-493 Overpayments
- GA-004-500 Call Coverage Policy
- GA-001-020 Review, Approval, and Administration of Contracts
- GA-510-001 Tracking and Monitoring of Medical Office Buildings
- GA-004-443 Tracking and Monitoring Activities
- GA-004-234 Open Lines Of Communication
- GA-004-238 Enforcement and Discipline
- GA-004-285 Deficit Reduction Act
- GA-004-290 Sanction Screening
- GA-004-305 Non-Retaliation or Retribution
- GA-004-345 Compliance Audit and Monitoring
- GA-016-007 Complimentary Local Transportation Assistance
- GA-004-441 Physician and Non-Physician Financial Arrangement Review- Approval- Tracking and Monitoring
- GA-004-160 Sanctions for Non-Compliance with Information Privacy and Security Policies
- GA-004-405 Non-Monetary Compensation to Physicians and Immediate Family Members