Developing Effective Lines of Communications
1. Access to the Chief Compliance Officer
The Chief Compliance Officer will make every attempt to be available for any Workforce Members of Broward Health that needs assistance in determining potential compliance issues. In addition, the Chief Compliance Officer is available by appointment, telephone call, email or contacting the compliance hotline. As an advocate of compliance related issues and conduct, the Chief Compliance Officer works and communicates closely with the chain of command to ensure the organization is operating with the state and federal laws.
Judy Ringholz, RN, JD, CHC
Chief Compliance Officer
Broward Health Corporate Compliance
2. Methods of Reporting
Effective and timely communication is the foundation of an effective compliance program. The prompt identification of potential compliance issues related to fraud, waste and abuse will allow Broward Health to provide quality services to its patients by instituting timely corrective actions. Any suspected conduct of wrongdoing can be reported via any of the following mechanisms:
It is Broward Health’s expectation that all Workforce Members should be able to communicate their concerns freely by any mechanism in which they feel comfortable or choose to report. Broward Health shall maintain a Compliance hotline that Workforce Members, patients and third parties may call to report potential violations. Broward Health will treat any such reports with utmost discretion consistent with the fair and rigorous enforcement of the Compliance Program. All employees have a duty to report if they witness and/or aware of any activity that does not comply with Code of Conduct, Internal Policies and Procedures and/or State and Federal rules and regulations.
The Chief Compliance Officer will maintain a database of the reported compliance concerns. This database will record the compliance issues reported. The database will be used to manage the development and resolution of action plans to address the underlying issues to improve compliance program effectiveness. Access will be limited to those persons at Broward Health with specific responsibility for compliance issues and confidential to the extent allowable by State and Federal law.
A. Reporting Suspected Violations
The Corporate Compliance and Ethics Department in conjunction with General Counsel and other departments will coordinate activities to report programs fraud, waste and abuse to the appropriate government agencies and respond to all inquiries from law enforcement agencies, including but not limited to, providing administrative, financial and medical records as requested.
B. Reporting to the Compliance Committee and Board of Commissioners
The Chief Compliance Officer will report compliance issues to the Chair of the Board of Commissioners and the Compliance Committee Members immediately if an urgent matter arises. Periodic reporting of Compliance issues and activities will occur at least quarterly to the Compliance Committee as well as the Board of Commissioners. The report will include at minimum; hotline activity, results of any audits/reviews and any identified risks to the organization.