Broward Health is committed to complying with all of the Federal and State laws and regulations surrounding health care. In 1999, to support this commitment, we established a Corporate Compliance Program.

Our program is focused on preventing, detecting and correcting any fraud, waste or abuse within our hospitals and facilities in connection with Federal health care programs as well as other payors. The Corporate Compliance Program is modeled after the United States Sentencing Commission Guidelines which contain seven elements of an effective program. The seven major components of our Corporate Compliance program include:

1. High-level oversight provided by our Corporate Compliance Officer
2. Written standards and policies;
3. Training and Education;
4. Auditing and monitoring;
5. Open lines of communication through our Compliance Hotline;
6. Response to detected deficiencies; and
7. Disciplinary action as warranted.

All employees receive Compliance Training upon hire and annual training during the time of their annual performance appraisal. In addition, employees may receive specific training based on their job role and responsibility. Vendor training is also available.

All reported/identified issues are investigated and the appropriate corrective actions are taken which may include external reporting to regulatory agencies, returning/recouping identified overpayments and developing additional internal controls. In addition the following elements may be included in each corrective action plan:

1. Identification of the issue;
2. Revisions to policies and procedures, if necessary;
3. Training on those policies and procedures, or retraining on established policies and procedures;
4. Monitoring to ensure compliance; and
5. Appropriate disciplinary action in the event of non-compliance.