At PSA Healthcare, we are firmly committed to the highest standards of ethics, integrity, professionalism and compliance. Our compliance and ethics program includes auditing and monitoring, enhanced lines of communication between the chief compliance officer and employees, consistency in the standards we set for ethics and compliance and increased awareness of these standards through a robust training and education program. In everything we do, our actions and decisions are aligned with our purpose, mission and values. We are committed to doing the right thing every time — without exception.
Compliance and Ethics Program
Our compliance and ethics program was developed to help ensure we conduct our business in compliance with all applicable federal and state laws, rules and regulations and to reduce the risk of misconduct. According to the Office of the Inspector General (OIG), an effective compliance program should have a strong foundation that includes the following seven elements:
- Written policies, procedures and standards of conduct.
- Designated compliance officer and compliance committee.
- Effective training and education.
- Effective lines of communication: reporting (Hotline) and investigations.
- Internal auditing and monitoring.
- Well-publicized enforcement and disciplinary guidelines.
- Prompt response to detected issues followed by corrective action.
To follow the OIG guidelines, we have developed a compliance and ethics program that consists of the following elements:
- Development, distribution, routine review and updates of the PSA Healthcare Code of Conduct and Ethics, as well as policies and procedures that promote PSA’s commitment to compliance and ethics, while addressing specific areas of risk to the organization.
- Designation of a chief compliance officer, who is responsible for overseeing and monitoring the compliance and ethics program, and a compliance committee that advises the chief compliance officer and assists in the execution of the compliance and ethics program.
- Regular and effective training and education, which addresses the various components of the compliance and ethics program and effectively communicates PSA’s standards and procedures.
- Development of a confidential and anonymous compliance hotline, the Integrity Hotline, 1-800-408-4442, for employees to communicate with the chief compliance officer to report potential violations or ask questions.
- A system to respond to allegations of improper activities and to consistently enforce appropriate disciplinary action for non-compliance.
- Performance of regular compliance audits and evaluation techniques, to monitor compliance with relevant healthcare standards and regulations.
- Immediate response to and the investigation of possible violations of the Code of Conduct and Ethics, compliance policies and procedures and applicable laws, rules or regulations, as well as appropriate corrective action initiatives and consistent discipline for any violations that have occurred.
In addition, we have also established extensive policies and guidelines related to privacy and security and the Health Insurance Portability and Accountability Act (HIPAA) for our patients, employees and business associates.
PSA’s Integrity Hotline provides a confidential and anonymous line of communication for employees, contractors and third parties to communicate with the PSA compliance department. Individuals may contact Integrity Hotline 24 hours a day, seven days a week, at 1-800-408-4442. Calls go directly to a secure voice mail account that is monitored each business day by a designated member of the PSA compliance team.
PSA makes every effort to maintain, within the limits of the law and within the bounds of an appropriate investigation, the confidentiality of the identity of any individual who uses the Integrity Hotline. There will be no retribution or discipline for anyone who reports a possible violation in good faith.
The success of our corporate compliance and ethics program relies on high-level oversight from our board of directors and senior management, as well as buy-in, support and accountability from employees. Listed below are the committees and individuals who support our compliance and ethics program.
- Our Board of Directors provides guidance regarding the direction of the Company’s compliance and ethics program. In addition, the committee receives regular reports on the status of the compliance and ethics program. Our Chief Compliance Officer has a direct reporting line to the audit committee.
- The senior management compliance committee monitors the compliance and ethics program and is comprised of members of senior management and other key leaders within PSA. The compliance committee receives reports on the various audits and investigations performed by the compliance department.
- Our chief compliance officer oversees the compliance and ethics program and evaluates compliance issues/concerns within the organization. The chief compliance officer helps ensure that the board of directors, management and employees are in compliance with the rules and regulations of regulatory agencies, that company policies and procedures are being followed and that behavior in the organization meets the company’s code of conduct and ethics.
- Each employee has a shared responsibility and commitment to our mission of healthcare service to our patients. Compliance and ethics are the responsibility of every PSA employee, and every employee is required to always do the right thing, without exception, and to make all clinical decisions based solely on the needs of the patient.
PSA is pleased to share compliance resources with others in the healthcare industry. The following information may be helpful to healthcare organizations focused on compliance issues.