Compliance Program

An essential way that Providence keeps its promise and meets its mission is through a strong compliance program. The Providence Compliance Program (the “Program”) applies to Providence St. Joseph Health and its Affiliates (collectively known as "PSJH") and their workforce members (caregivers, volunteers, trainees, interns, apprentices, students), independent contractors, vendors and all other individuals working at the ministry, whether they are paid by or under the direct control of the facility); employees of affiliated organizations (collectively, "workforce members"); members of the PSJH System Board; Community Boards; and Foundation Boards. The Providence Compliance Program also applies to our health plans that, because of the unique requirements of Medicare Advantage/Part C and Medicare Part D, have established additional focused compliance programs addressing those requirements.

Additionally, the Providence Compliance Plan extends to the oversight of downstream contractors, vendors, and subcontractors as applicable.

Healthcare compliance is complex and ever-changing. Our commitment remains/is to “do the right thing right” as the organization and healthcare landscape evolve. Consequently, the terms integrity and compliance are used frequently when describing the Program. Integrity refers to conduct that meets our ethical and organizational standards regardless of whether a law requires such conduct. To act with integrity is to engage in conduct that aligns with our standards, values, and expectations. Compliance means acting in accordance with applicable laws, regulations, policies, procedures, and other explicit standards.

The Program supports our workforce members in fulfilling their legal, professional, and ethical obligations. Ongoing guidance from the United States Department of Health and Human Services (HHS) Office of the Inspector General (OIG) publications (e.g., Compliance Program Guidance for Hospitals, Compliance Program Guidance for Laboratories, Compliance Program Guidance for Nursing Facilities, etc.), and other state and federal laws and regulations are incorporated into the Program. In addition, the Program is guided by the recommendations of the United States Sentencing Commission’s Federal Sentencing Guidelines, the Deficit Reduction Act of 2005, the Affordable Care Act, and the Foreign Corrupt Practices Act, among other standards and guidelines.

The Program provides support to our health care, insurance, and educational operations through a collaborative partnership with those we serve. The Program is intended to provide added assurance that our organization:

• Complies in all material respects with international, federal, state, and local laws, policies, and procedures that are applicable to its operations
• Satisfies conditions of participation in health care programs funded by state and federal governments, the terms of its contractual arrangements, and applicable requirements and waivers associated with the Centers for Medicare and Medicaid Services’ (CMS) models
• Detects and deters criminal conduct or other forms of misconduct by our workforce members and/or agents who work on our behalf
• Promotes self-monitoring and provides for, in appropriate circumstances, voluntary disclosure of violation of law and regulation
• Establishes monitoring and auditing to assure that there is an active detection mechanism in place to dynamically review the risks and behaviors of the organization
• Maintains a disclosure mechanism (through a toll-free Integrity Hotline at 888-294-8455) for reporting integrity, compliance, or legal concerns
• Reviews, investigates, and acts on allegations of violations and misconduct, and
• Supports the mission, values, and vision of Providence.