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CHI St. Luke’s Health is committed to high ethical standards and compliance with all governing laws and regulations. To that end, the Corporate Responsibility program 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 CHI St. Luke’s Health.

The Corporate Responsibility program 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
Health care is a complex industry. Many of the laws and regulations that govern health care are difficult to understand and to apply consistently. 

Catholic Health Initiatives’ Our Values and Ethics at Work Reference Guide helps employees understand these laws and regulations. Employees can consult this reference guide, which describes CHI’s standards of conduct and how to apply them to daily work situations.

Corporate Responbilites Policies
CHI St. Luke's Health 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. CHI St. Luke's Health 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 CHI St. Luke's Health 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 CHI St. Luke's Health 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 Responsibility program, federal, state or local law, must report their concerns. As described within the Integrity Guidelines noted above, the Corporate Responsibility program has established various methods for reporting an issue of concern.

These reporting options are for both CHI St. Luke’s Health employees and contractors (where applicable) and include the following:

1.    Discuss issue with your supervisor, manager, or executive (CHI St. Luke’s Health Employees)
2.    Contacting Employee Relations (CHI St. Luke’s Health Employees)
3.    Call the Ethics at Work Line: 1-800-261-5607
4.    Contacting the Corporate Responsibility Officer (832-355-2146)
5.    Contacting Internal Audit (832-355-2196)
6.    E-mail the Corporate Responsibility Department (compliance@stlukeshealth.org)
7.    Submit Written Issue to:

CHI St. Luke's Health System
Corporate Responsibility Program
PO Box 20269 MC 3-121
Houston, TX 77225-0269

8.    Online Reporting - www.ethicspoint.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.