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Compliance Program Effectiveness

This Compliance Plan is intended to be flexible and readily adaptable to changes in regulatory requirements and in the healthcare system as a whole. This plan shall be reviewed annually and modified, as necessary.

The Chief Compliance Officer shall monitor the ongoing activities of this Compliance Plan through effective training regarding compliance issues, investigation and enforcement of compliance reports and complaints as well as periodic audits. The Chief Compliance Officer will provide updates on the monitoring results to the ECG as well as the Compliance Committee of the NBHD Board of Commissioners.

Compliance Program Elements

  • Written Policies and Procedures
  • Designation of a Compliance Officer and Executive Compliance Group
    • Chief Compliance Officer
    • Executive Compliance Group
  • Conducting Effective Training and Education
    • Initial Compliance Training
    • Annual Compliance Training
    • Chief Compliance Officer and Corporate Compliance Staff
  • Developing Effective Lines of Communication
    • Access to the Chief Compliance Officer
    • Methods of Reporting
  • Enforcing Standards through Well-Publicized Guidelines
    • Non-Retaliation
    • Progressive Discipline
    • District Performance Management Policy
  • Auditing and Monitoring
    • Compliance Auditing
    • Monitoring
  • Responding to Detected Offenses and Developing Corrective Action Initiatives
    • Prevention and Detection
    • Investigations and Reporting
    • Corrective Actions
    • Overpayments



To permit the rendering of impartial and unbiased judgment essential to the proper conduct of Broward Health’s Corporate Compliance and Ethics Program, the Chief Compliance Officer and staff will be independent of the activities they review. In performing the Compliance function, the Corporate Compliance and Ethics Department cannot have any direct responsibility for or authority over, any of the activities reviewed.