STERLING

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STERLING
HEALTHCARE
Corporate Compliance Training
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Corporate Compliance

• Welcome!
• Sterling is proud of its long-standing tradition
  of delivering exceptional patient care and
  quality service to its many hospital clients.
  This includes conducting business according to
  the highest ethical standards and in compliance
  with all relevant legal and regulatory
  requirements.
• As part of our association with Sterling
  Healthcare as an employee or a contracted
  healthcare professional you and I are expected
  to do the right thing by conducting all
  business activities in a professional and ethical
  manner.
• Our Compliance Program has been instituted to
  provide regulatory and ethical guidance to
  everyone associated with Sterling, and to
  establish a culture that promotes prevention,
  detection, and resolution of instances of conduct
  that do not conform to laws and business
  policies.
• Your commitment to practice lawful and ethical
  conduct, and to serve others with your special
  talents and abilities is critical to the success
  of Sterling, its employees, clients, and
  stakeholders.
• Eugene F. Dauchert, Jr.
• Chief Executive Officer

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Corporate Compliance

• Service
• Integrity
• Lawful
• Values
• Ethics
• Respect
• ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ?
• Sterlings SILVER Standards

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Corporate Compliance

• Why a Corporate Compliance Program?
• Recommended by the Office of Inspector General
  (OIG) to help prevent fraud and abuse in Federal
  healthcare programs.
• Assists in establishing a culture within the
  organization that promotes prevention, detection
  and resolution of activities that do not conform
  to laws and ethical and business policies.
• Considered a plus in the event violations or
  offenses are discovered penalties (fines) may be
  reduced in the presence of an effective
  compliance program.
• Ethics and compliance programs are now considered
  good business practice in all industries.
• A compliance program does not make money, but
  it can save money for the organization (by
  reducing or eliminating potential fines).

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Corporate Compliance

• Sterlings Compliance Program
• Modeled from the OIGs Compliance Program
  Guidance for healthcare organizations.
• Implemented under the guidance and supervision of
  the Corporate Compliance Officer who is appointed
  by Sterlings CEO with advice and consent of the
  Board of Directors.
• Multidisciplinary Compliance Committee,
  representing all subsidiaries and key operating
  areas of Sterling, supports the Compliance
  Officer in the programs implementation and
  maintenance.
• On-going reporting of compliance activities to
  Sterlings Executive Committee and Board of
  Directors.

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Corporate Compliance

• Mary Ellen Haynes, our Compliance
• Officer, is committed to
• Ensuring that the Compliance Program at Sterling
  includes
• documented compliance standards
• education and training for all workforce members
• clear pathways for reporting violations
• enforcement of standards with clear disciplinary
  guidelines and
• evaluation for effectiveness through ongoing
  auditing and monitoring activities.
• Serving as a resource to you on any compliance
  matter that raises a question or concern for you.

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Corporate Compliance

• Compliance Standards
• Code of Conduct the core instrument on which
  Compliance training is based, it summarizes the
  standards of ethical and professional conduct
  that are expected of everyone associated with
  Sterling.
• Compliance Policies/Procedures define the
  structure and operation of the Compliance
  Program, provide detailed procedures for carrying
  out the Program, and identify and address
  specific areas of risk to Sterling.
• Availability the Code will be provided to all
  employees upon hire. The Code and
  Policies/Procedures will remain posted on the
  Sterling Intranet for instant reference. Contact
  the Compliance Officer for copies of any of the
  compliance material.

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Corporate Compliance

• Real integrity is doing the right thing,
• knowing that nobodys going to know
• whether you did it or not.
• - Oprah Winfrey

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Corporate Compliance
If you suspect illegal or non-compliant activity,
what should you do?

• You have a responsibility to report any activity
  that you either know or suspect is in violation
  of any law or policy.
• If you do not report serious violations or
  illegal activity that you knew about, you could
  be subject to disciplinary action, even if you
  were not directly involved in the activity.
• When you report in good faith, your identity
  will be kept confidential to the extent permitted
  by law.
• No disciplinary action or retaliation will be
  taken against you when you report a perceived
  concern or violation in good faith.

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Corporate Compliance

• Reporting Options
• Talk to your supervisor. Your supervisor is
  responsible for addressing and responding to your
  questions and concerns in a timely manner.
• Contact other Sterling management. If you feel
  uncomfortable talking to your supervisor, or your
  supervisor is involved in the activity you are
  reporting, consider contacting other Sterling
  management.
• Contact the Compliance Officer. You may contact
  the Compliance Officer in a variety of ways.
• Call the Compliance Hotline at 800-826-6762. You
  may report anonymously 24 hrs./day, 7 days/wk.,
  365 days/yr.

Lines of communication for reporting known or
suspected violations are ALWAYS open!
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Corporate Compliance

• Contacting Our Compliance Officer
• By telephone or voice mail to our Compliance
  Line 866-625-8048 (toll-free)
• To our Compliance E-mail Box compliance_at_sterling
  healthcare.com
• By direct e-mail MaryEllen.Haynes_at_sterlinghealth
  care.com
• By telephone or voice mail directly
  919-768-4612
• or toll-free at 800-476-4587, ext. 4612
• By personal meeting (use the email address or
  phone numbers above to schedule)
• By letter addressed to
• Mary Ellen Haynes
• Corporate Compliance Officer
• Sterling Healthcare
• 1000 Park Forty Plaza, Suite 500
• Durham, NC 27713

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Corporate Compliance

• Calling Our Compliance Hotline
• Our Compliance Hotline is available 24 hours per
  day, 7 days a week, 365 days per year for
  reporting illegal activity or compliance
  concerns. (This includes issues related to Fraud
  Abuse, Human Resources, and Privacy
  Security.)
• The Hotline is a highly confidential means of
  reporting and you may report anonymously no
  attempt will be made to identify you.

• Our Hotline is administered by an independent
  third party, National Hotline Services calls are
  answered by live operators who ask questions to
  prepare a report.
• Reports are transmitted to the Compliance Officer
  via a secure method.
• Callers are given a report number and a callback
  date when they may call back to the Hotline for a
  status.
• The Compliance Officer will provide a response to
  the Hotline that will be read to the caller at
  the time of callback.

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Corporate Compliance

• Do The Right Thing
• DO NOT close your ears and eyes to illegal or
  non-compliant activity within the Sterling
  organization.
• HELP preserve Sterlings lawful and ethical
  business practices by reporting any known or
  suspected violations.

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Corporate Compliance

• Responding to Reported Concerns/Violations
• All reports, including Hotline calls, will be
  investigated promptly and with the utmost
  integrity under the supervision of the Compliance
  Officer.
• All reports of compliance concerns/violations are
  kept strictly confidential.
• No report or call will go unaddressed!

• If the investigation determines that a violation
  has occurred, resolution of the matter may
  include
• Development/implementation of an action plan.
• Institution of disciplinary action, based on the
  severity of the violation and in accordance with
  Sterlings Progressive Discipline Policy.
• The Compliance Officer will collaborate with
  applicable administrative personnel to ensure
  that determined disciplinary actions are
  instituted.

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Corporate Compliance

• Upon the conduct of each
• depends the fate of all.
• - Alexander the Great

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Corporate Compliance

• Your Responsibilities Toward Others
• Follow The Rules. You have a personal duty and
  responsibility to comply with all legal and
  ethical requirements, all applicable professional
  standards, and all policies and procedures that
  apply to you and the Sterling organization.
• Be Honest. You are expected to be honest in all
  aspects of your role with Sterling. Lying,
  cheating, stealing, falsifying records, and
  unauthorized access to, or disclosure of,
  confidential information will not be tolerated.
• Respect Everyone. You are to treat everyone you
  come in contact with in your role at Sterling
  with the utmost courtesy and respect. No form of
  harassment or discrimination will be tolerated.
• Protect Privacy Confidentiality. You are not
  to access or disclose any confidential or
  proprietary information unless you are authorized
  to do so, or your job requires it. This includes
  confidential information about Sterling, its
  employees, financial status, internal operations,
  etc., as well as information about patients or
  Sterling health plan participants. Any
  authorized disclosure of information should be
  limited to the minimum necessary to accomplish
  the task.

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Corporate Compliance
Dont Solicit Gifts or Gratuities

• Neither you nor members of your family are to
• seek or solicit gifts or other personal favors
  from
• any current or potential customer, vendor or
  supplier of
• Sterling.
• Acceptance of cash gifts is strictly prohibited.
• Any gift received that is valued at more than
  100 must be reported to the Compliance Officer
  on the Gifts Gratuities Disclosure Form.
• This reporting requirement includes gifts
  received in connection with normal business
  activities (such as meals, golf/fishing outings,
  tickets to sporting events or concerts, gift
  baskets, etc.)
• Everyone must avoid accepting gifts that may
  create a conflict of interest or make it
  difficult to objectively carry out their job
  responsibilities.

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Corporate Compliance

• Your Responsibilities Toward Others
• Provide High Quality Care Services. Delivering
  exceptional patient care and quality service to
  our many hospital clients is Sterlings primary
  focus. As an employee or an associate of
  Sterling, you are expected to uphold these
  quality standards which include

• Performing all job responsibilities with the
  highest level of integrity and quality.
• Treating all customers, clients and each other
  with dignity and respect.
• Addressing any deficiency or error promptly,
  taking appropriate action, and following to
  resolution.
• Ensuring that all Sterling workforce members are
  fully competent to perform job responsibilities,
  and no previous actions have resulted in
  healthcare convictions or debarment from
  government programs.
• Providing medical care that ensures medical
  expertise and experience, that is medically
  appropriate, that offers human dignity and
  prohibits discrimination against patients.

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Corporate Compliance

• Your Responsibilities Toward Others
• Responding to Government Investigations.
  Sterling desires to cooperate fully with any
  government investigation into our business and/or
  ethical practices. However, to ensure Sterling
  provides the appropriate response, if you are
  approached by a government agent, refer the agent
  to your supervisor.

The Compliance Officer and General Counsel should
be notified immediately of this type of activity,
and particularly prior to release of any
documents or other items. Guidance will be
provided to ensure that Sterling responds
cooperatively, but also protects its legitimate
business interests.
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Corporate Compliance

• Financial Business Standards
• Keep Accurate Timely Records. You are expected
  to ensure that all records for which you are
  responsible are accurate and completed on a
  timely basis. Failure to accurately record
  material information, or the recording of false
  or misleading information is not acceptable under
  any circumstances and could result in your
  immediate termination.

• Protect Company Assets. Sterlings assets are
  solely for use in conducting authorized company
  business. Company assets include computers,
  software, office supplies, as well as other types
  of property such as cash, company records and
  patient information. Employees who improperly
  use company property, funds, or information, or
  assist in the inappropriate use will be subject
  to disciplinary action.

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Corporate Compliance

• Financial Business Standards
• Ensure Accurate Billing Coding Practices.
  Sterling is committed to ensuring that its
  billing and reimbursement practices comply with
  all laws, rules and guidelines so that bills
  presented to patients and payors are accurate and
  compliant. This includes
• Billing only for services that are medically
  necessary, actually provided, and properly
  documented in the patients medical record.
• Not knowingly submitting for reimbursement a
  claim we know to be false, fraudulent or
  fictitious.
• Assigning diagnostic, procedural or billing codes
  that accurately reflect the services that were
  provided upcoding, unbundling, or any other
  means of artificially enhancing reimbursement is
  unlawful and strictly prohibited.
• Regularly reviewing records for credit balances
  and promptly refunding any overpayments.
• Maintaining records in a secure manner for the
  period of time required by law. Premature
  destruction or alteration of any document in
  response to, or in anticipation of a request by
  any government agency or court is strictly
  prohibited.
• Responding to questions and complaints related to
  patient bills in a direct and honest manner.
• All workforce members whose responsibilities
  include involvement in patient registration,
  submission of charges, diagnostic or procedural
  coding of charges, or billing of charges must
  follow all laws, rules and guidelines.
• Sterling is committed to providing appropriate
  training and guidance toward this end.

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Corporate Compliance

• Avoid Conflicts of Interest
• As part of your association with Sterling, you
  are expected to avoid situations
• that may influence your ability to be objective
  in your decision making, affect
• your job performance, or result in personal
  financial gain.

• Examples include
• Serving as an officer/employee of an organization
  that is a competitor of Sterling.
• Hiring Sterling vendors/contractors to perform
  personal work without administrative approval.
• Endorsing/giving a testimonial for a vendor,
  supplier, contractor without administrative
  approval.
• Misusing confidential information for personal
  gain.
• Promoting a business in which you have a direct
  or indirect interest on company time.
• Everyone must ensure that their activities and
  the
• transactions they enter into do not violate
  federal anti-
• kickback statutes. Any financial arrangements
  must
• reflect the fair market value of goods/services
  provided.

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Corporate Compliance

• Contributions Charitable Donations
• Sterling receives requests, from time to time, to
  make contributions or charitable donations in the
  communities which it serves. The requested
  donations are generally to support community
  health and awareness initiatives that involve our
  hospital clients.
• Sterling has established a Contributions
  Charitable Giving Committee that reviews all such
  requests. The Committee adheres to established
  guidelines and protocol when making decisions on
  requests for contributions and donations.
• The Committee will ensure that all contributions
  and charitable donations are ethical, consistent
  ,and in compliance with all Sterling policies and
  procedures, as well as all federal, state and
  local laws, particularly the federal Stark
  self-referral and anti-kickback statutes.
• All requests for contributions or charitable
  donations must be submitted to the Committee for
  review and a decision. A form is available for
  your use it is posted to the Intranet along with
  Compliance Policies and Procedures.

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Corporate Compliance

• There is no pillow so soft as a clear
  conscience.
• - Japanese Proverb

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Corporate Compliance

• Our Commitment to You
• Sterling is committed to ensuring that all
  employees and associates of the organization are
  aware of the conduct that is expected of them
  while performing their job responsibilities.
• Training and education on our Code of Conduct and
  associated policies and procedures will be
  provided on an on-going basis.

• It is critical that our Compliance Program
  effectively communicates compliance issues at all
  levels of the organization.
• To that end, we encourage you to bring
  suggestions, ideas, concerns and problems to our
  attention through the regular chain of command,
  or by contacting the Compliance Officer or the
  Hotline.

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Corporate Compliance

• The ETHICS QUICK TEST
• As you carry out your daily job responsibilities,
  you will make many decisions. Some will be
• very simple, others more complicated. Our Code
  of Conduct and Compliance Policies and
• Procedures, along with this training is intended
  to provide you with guidance for doing the right
• thing and conducting all your business
  activities in a professional and ethical manner.
• Additionally, the following ETHICS QUICK TEST may
  help you decide what you should do if
• you are confronted with an ethical situation and
  are unsure how to handle it.

• DOES this situation violate any laws,
  regulations, or policies/procedures?
• WHY does this situation make me feel
  uncomfortable?
• HOW would I feel if I did it?
• HOW would it look to my family and friends or it
  if was printed in the newspaper?
• IF you think it is wrong dont do it!
• ASK QUESTIONS! If you cannot get a satisfactory
  answer from your supervisor, call the Compliance
  Officer of the Hotline.

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Corporate Compliance

• Achieving Ethical Lawful Excellence at Sterling
• Compliance happens only when YOU make it happen!
• Each and every one of us plays an integral part
  in the effectiveness of our Compliance Program.

Snowflakes are one of natures most fragile
things, but just look at what they can do, when
they stick together.
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Corporate Compliance

• Insert Compliance Post-Test Here

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Corporate Compliance

• Certificate of Completion of Compliance Training
• I have completed the Corporate Compliance
  Training module and submitted my completed
  compliance post-test.
• I have received a copy of Sterlings Code of
  Conduct and will follow instructions for review
  of the Code, and completion and submission of the
  Statement of Understanding and Compliance.
• I agree to review and adhere to all compliance
  policies and procedures and direct any questions
  to the Compliance Officer.
• Name
• submit

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Corporate Compliance

• Certificate of Completion of Compliance Training
• I have completed the Corporate Compliance
  Training module and submitted my completed
  compliance post-test.
• I have received a copy of Sterlings Code of
  Conduct and will follow instructions for review
  of the Code, and completion and submission of the
  Statement of Understanding and Compliance.
• I agree to review and adhere to all compliance
  policies and procedures and direct any questions
  to the Compliance Officer.
• Name
• submit

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Corporate Compliance

• Certificate of Completion of Compliance Training
• I have completed the Corporate Compliance
  Training module and submitted my completed
  compliance post-test.
• I have received a copy of Sterlings Code of
  Conduct and will follow instructions for review
  of the Code, and completion and submission of the
  Statement of Understanding and Compliance.
• I agree to review and adhere to all compliance
  policies and procedures and direct any questions
  to the Compliance Officer.
• Name
• Date
• submit