The Compliance Department of Community Health Systems presents

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The Compliance Department ofCommunity Health
Systemspresents

• General Compliance Training and the Code of
  Conduct

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CHS is committed to operating with the highest
standards of integrity and behavior.

• Wayne T. Smith, Chairman, President and CEO

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The CHS Compliance Program

• The Code of Conduct
• Corporate Compliance Officer
• Written Policies and Procedures
• Training and Education
• Auditing and Monitoring
• Confidential Disclosure Program
• Periodic Reports to the CHS Board of Directors

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What is the Code of Conduct?

• The Code of Conduct (the Code) is designed to
  provide all CHS employees and affiliates with
  guidance to perform their daily activities in
  accordance with all federal, state and local
  laws, rules and regulations.
• The Code is an integral part of the CHS
  Compliance Program, and reflects our commitment
  to achieve our goals within the framework of the
  law, through a high standard of business ethics
  and compliance.
• The Code is a collection of policy statements.
  Most sections of the Code of Conduct refer to
  more detailed policies covered in various
  department policy manuals.

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Compliance with the Code of Conduct

• The Code of Conduct is a mandatory policy of the
  Company. All colleagues will sign a form
  indicating they have received a copy of the Code,
  have read it, and understand it. In addition,
  all colleagues will reaffirm these actions on an
  annual basis.
• Compliance with the Code of Conduct and other
  policies will be considered in annual employee
  evaluations and decisions regarding promotion and
  compensation for all CHS employees.
• The Code of Conduct is a unilateral statement of
  policy by CHS. Nothing in the Code is intended
  to create enforceable employee contract rights.

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The Code of Conduct and You

• Every CHS colleague is required to comply with
  the Code of Conduct.
• Each individual is expected to perform his/her
  daily activities with the highest ethical
  standards and in compliance with laws.
• All CHS colleagues are required to notify the
  Ethics and Compliance Officer (the facility ECO),
  the Corporate Compliance Officer, or the
  Confidential Disclosure Program Hotline of any
  suspected or known violations of law, the Code of
  Conduct, or Compliance Policy.

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Examples of Topics in the Code of Conduct

• Patient Privacy
• Confidential Information
• Coding and Billing
• Financial Reporting
• False Claims Act Laws

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Confidentiality of Patient Information

• When a patient enters a CHS facility, a large
  amount of personal, medical, and insurance data
  is collected and used to satisfy varying
  information needs, including the ability to make
  decisions about a patients care.
• CHS CONSIDERS PATIENT INFORMATION HIGHLY
  CONFIDENTIAL
• CHS colleagues must never disclose or release
  patient information in a manner that violates the
  privacy rights of a patient. Patient information
  may only be discussed or released in accordance
  with state and federal release of information
  laws. CHS colleagues should not access or use any
  patient information unless it is necessary to
  perform his/her job.

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Confidential InformationRecords Documents

• Inside information is non-public information and
  is confidential. This includes acquisition
  plans, financial data, marketing plans, or other
  business material that an employee may become
  aware of in the normal course of business. Use of
  inside information for personal gain (or for the
  gain of friends or family members) is strictly
  prohibited.
• In case of termination, you may not take, retain,
  copy or direct any other person to take, retain,
  or copy without prior written permission, any
  documents or confidential information of any kind
  belonging to the Company.
• Disposal or destruction of CHS records and files
  is not discretionary with any of us, including
  the originator of the record. Legal and
  regulatory guidelines require retention of
  various types of records. Each facility has
  policies governing accuracy, retention, and
  disposal of documents and records.

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Electronic Media

• CHS colleagues should be familiar with all
  Information Systems Polices and Procedures
  applicable to the use of electronic media.
• CHS colleagues should not share passwords.
• Personal laptops should not be used for protected
  health information.
• Cell phones should not be used to take pictures
  of patients.

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Identity Theft Prevention Program

• Identity theft occurs when someone uses a
  persons name and sometimes other parts of their
  identity such as insurance information without
  the persons knowledge or consent to obtain
  medical services or goods. This includes the use
  of the persons identity information to make
  false claims for medical services or goods.
• CHS takes Medical Identity Theft seriously
  because in addition to causing financial
  problems, identity theft can lead to
  inappropriate medical care when incorrect
  information is included in a patients medical
  record. CHS employees will take necessary steps
  to detect, prevent, or mitigate the misuse of a
  patients identity to commit identity theft.

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Identity Theft Prevention Program

• Some examples of Identity theft indicators
• Patients provide a photo ID that does not match
  the patient.
• Patients name does not match the registration
  forms they signed.
• Documents, identification card, insurance card,
  etc. appears to be forged or altered.
• Individual receives a bill and says that he or
  she did not receive services at the facility and
  it is identified that this is likely true.
• The patient or the patients representative
  admits during the visit that someone elses
  identity is being used.
• Anyone who states that they have information
  regarding a potential misuse of someones
  identity.
• Should you identify or be confronted with an
  identity theft situation please contact your
  immediate supervisor or your facility Ethics and
  Compliance Officer.
• An Identity Theft Prevention Program policy is
  available in the Compliance Manual on the CHS
  intranet.

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Coding Billing

• If you are responsible for coding or billing of
  services, you must not knowingly cause or permit
  false or fraudulent claims, and must adhere to
  all official coding billing guidelines.
• Furthermore, CHS colleagues shall not engage in
  any intentional deception or misrepresentation
  intended to influence any entitlement or payment
  under any federal healthcare benefit program.
• Claims must be submitted only for services
  ordered, appropriately documented, and actually
  provided.
• Audits will be performed on a regular basis to
  monitor the validity of claims submitted. When
  appropriate, the hospital or CHS will return
  overpayment amounts.

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Financial Reporting

• All accounts and financial records must be
  maintained in accordance with generally accepted
  accounting principles and all SEC rules and
  regulations.

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False Claims Act Laws

• The Federal False Claims Act (FCA) provides that
  civil monetary penalties and other damages may be
  imposed against any person or entity that
  knowingly presents or causes to be presented a
  false or fraudulent claim to a federal healthcare
  program for payment.
• The FCA includes certain whistleblower
  protections to protect an individual who files an
  action under the FCA.
• Many states have developed their own false claims
  act laws.
• Information on both the federal FCA and relevant
  state laws is available in the Compliance Manual
  on the CHS intranet.

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Compliance OfficerPrivacy Officer

• The CHS Corporate Compliance and Privacy Officer
  is Andi Bosshart.

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Written Policies and Procedures

• CHS has many written policies and procedures in
  the area of compliance. Your facility ECO can
  answer questions concerning those policy and
  procedures. It is your job to have an awareness
  of those policies and procedures.

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Training and Education

• CHS and each affiliated entity offer a variety of
  training programs. Training includes this lesson
  and in some instances specific lessons for
  certain job codes and descriptions. Some
  training will be required as part of your job.
  It is your duty to make sure you receive all
  required training and education.

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Auditing and Monitoring

• Auditing and Monitoring topics are selected
  annually by Compliance. Auditing and monitoring
  is routinely performed in an effort to prevent
  and detect inappropriate activities. The results
  of these activities are also used to determine
  future training topics.

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Confidential Disclosure Program

• CHS has established a Confidential Disclosure
  Program Hotline for all colleagues to report
  known or suspected violations of the Code of
  Conduct, written policy, or any federal, state
  or local laws, rules and regulations. This
  program may also be used for individuals who are
  uncertain whether an action is a violation and
  would like to communicate with the Compliance
  Officer on a confidential basis.
• Confidential Disclosure Program Hotlinenumber is
  1-800-495-9510

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• Retribution or retaliation against any person
  reporting suspected violations of the Code, law,
  or policy will not be tolerated.

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Reporting Violations

• Failure to report a known violation of the law,
  Code of Conduct, or any Compliance Policy could
  subject an individual to disciplinary action.
  Any colleague who attempts to divert or
  discourage reporting shall be subjected to severe
  discipline, up to and including discharge.

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Investigation of Violations

• Once contact is made via the Confidential
  Disclosure Program, a prompt, appropriate,
  confidential investigation will be undertaken.
• The Corporate Compliance Officer will coordinate
  findings from the investigation and recommend
  corrective and/or disciplinary actions.
• When appropriate, CHS will return any
  overpayment amounts, notifying the correct
  governmental agency of the overpayment situation.

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Human ResourcesGrievance Resolution

• If an individual is concerned about a personnel
  action that does not involve any violation of
  law, the Code of Conduct, or Compliance Policy,
  he/she may file a grievance at the CHS entity
  where he/she is employed. The facility Human
  Resources Department can provide a grievance
  resolution form and assistance in preparing and
  presenting a grievance. Information regarding
  employee grievances is held in strict confidence.
  Note that this process is separate from the
  Compliance Disclosure Program.

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Periodic Reporting

• The CHS Compliance Officer periodically reports
  the activities of the Compliance Program to the
  CHS Management Compliance Committee and to the
  CHS Board of Directors.

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Reporting Questions or Concerns

• Questions or concerns about potential compliance
  violations may be addressed to any of the
  following
• Your Supervisor or Department Head
• Any Supervisor or Department Head
• The Ethics and Compliance Officer
• The Confidential Disclosure Program Hotline at
  1-800-495-9510
• It is recommended to first report concerns
  through your local facility management.