St. Luke’s Episcopal Health System is committed to high ethical standards and compliance with all governing laws and regulations. To that end, the Department of Corporate Compliance has been established to provide a framework to promote and assist employees, physicians, vendors/contractors, volunteers, in adhering to all applicable laws and regulations pertaining to the activities of St. Luke’s.
The Department of Corporate Compliance focuses its activities on the seven elements of an effective compliance program noted within the Federal Sentencing Guidelines. These elements include 1) Implementing written policies, 2) Designating a compliance officer, 3) Conducting training and education, 4) Developing lines of communication, 5) Monitoring and auditing, 6) Enforcing standards; and 7) Undertaking corrective action.
Commitment to Integrity
The St. Luke's Integrity Guidelines promotes ethical conduct within the workplace and enhances commitment to St. Luke’s core values (Integrity, Excellence, Goal Orientation, Valuing People and Stewardship). You may access the Integrity Guidelines by selecting the link below:
Compliance Policies
St. Luke's has established various policies and procedures to assist in the avoidance of circumstances that could result in unlawful or unethical conduct, including the submission of false claims. St. Luke's business practices and policies strive to result in accurate claims made for medically necessary services provided to our patients.
Deficit Reduction Act of 2005 (DRA)
This Act was signed into law on February 8, 2006. One example of how the DRA seeks to reduce the national deficit is through an increased emphasis on detecting and preventing fraud, waste, and abuse within the Medicaid programs. Section 6032 of the DRA requires entities that receive or pay annual Medicaid payments of $5 million or more to establish written policies and disseminate these policies to all employees as well as the employees of contractors and agents.
The links noted below provide detailed information regarding the Federal and State False Claims Acts as well as St. Luke's policies pertaining to False Claims and Whistleblower Protection.
Information on the Federal False Claims Act
- Congress enacted the False Claims Act (FCA) to prevent and detect fraud, waste, and abuse in government spending.
- The FCA prohibits a party from knowingly filing a false or fraudulent claim for payment by the government (or government funded program like Medicare or Medicaid).
- The St. Luke's Department of Corporate Compliance assists in identifying and preventing circumstances that might result in submission of false claims. As described below, all employees, contractors and agents are required to report concerns. Entities may, but are not required, to notify the government of their concerns.
- Civil penalties for submitting false claims are $5,500 to $11,000 per claim plus treble damages.
- Criminal penalties are up to $25,000 and/or five years imprisonment
- The FCA provides that an individual who is aware that the government is being defrauded can share that information with the government. If the government recovers money, the individual generally receives a portion of the recovered funds.
- Employees who share information with the government will not be discharged, demoted, or otherwise disciplined because of their participation in a false claims action
Reporting Issues of Concern
Adhering to the core value of integrity requires the active support of all employees and contractors. Any employee or contractor who knows or suspects a violation of the Corporate Compliance Program, federal, state or local law, must report their concerns. As described within the Integrity Guidelines noted above, the Department of Corporate Compliance has established various methods for reporting an issue of concern.
These reporting options are for both St. Luke’s employees and contractors (where applicable) and include the following:
1. Discuss issue with your supervisor, manager, or executive (St. Luke’s Employees)
2. Contacting Employee Relations (St. Luke’s Employees)
3. Call to the Corporate Integrity Hotline at 1-800-826-6762
4. Contacting the Corporate Compliance Officer (832-355-2146)
5. Contacting Internal Audit (832-355-2196)
6. E-mail the Compliance Department (compliance@sleh.com)
7. Submit Written Issue to:
St. Luke's Episcopal Health System
Department of Corporate Compliance
3100 Main MC 3-121
Houston, TX 77002
8. Online Reporting - www.slehshotline.com
Regardless of the reporting option used, all issues can be reported anonymously. All reported issues of concern are promptly documented and investigated. Strict confidentiality is maintained throughout the review of the reported issue.
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