My philosophy is simple…ethics and honesty are important and these traits shall be integrated into the day to day lives of all Ensemble Associates.
Every Associate on our team is expected to follow a set of principles that we call the Ensemble Difference. These principles help our Associates to not only understand what we expect as an employer, but also what kind of behavior to expect from our leadership team in support of their role.
We are committed to conducting business activities in full compliance with all applicable Federal and State laws, rules, and regulations, and payor requirements with an emphasis on preventing fraud and abuse and we count on you to let us know if an activity causes you concern.
Judson Ivy, CEO | Ensemble Health Partners
Purpose of the Ensemble Compliance Program
We developed our Compliance Program to provide guidelines, education, and tools to help all of us meet our commitment to fulfill our ethical, professional, and legal obligations and to foster a culture that enables others who work with us to do the same.
The Compliance Program helps us better understand and obey health care laws and rules and provides a means for Associates to ask questions and report concerns, even anonymously.
It also enables each of us to put our Core Values — The Ensemble Difference — into action.
The Ensemble Compliance Program
We have hired a team of experienced compliance professionals with over 50 years of combined HIPAA, revenue cycle, and general compliance experience working for and with hospital systems, physician practices, and revenue cycle organizations.
Our compliance team works closely with leaders from all functional areas of the company to develop, implement, and continuously enhance our Compliance Program so it is integrated into the daily job responsibilities of all Associates – so it becomes part of our DNA!
Oversight of the Ensemble Compliance Program
Oversight of the day to day activities of our Compliance Program is provided by our Chief Compliance Officer who reports to the CEO and has a direct reporting line to our Board of Directors. The CCO works closely with two groups of leaders within Ensemble to design, maintain, implement, and enforce the Compliance Program. The first group is the Compliance Advisory Group (“CAG”) which consists of leaders from each of the functional areas of our business. The primary role of the CAG is to assist the CCO in ensuring that the Compliance Program (e.g. standards of conduct, policies, procedures, training, risk assessment, auditing and monitoring) is tailored to our business. The second group that the CCO works closely with is the Executive Compliance Committee (“ECC”) which consists of our most senior executives. The primary role of the ECC is to work closely with the CCO and other Company leaders to promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law and takes reasonable steps to ensure that the Compliance Program is reasonably designed, implemented, and enforced so that the program is generally effective in preventing and detecting misconduct.
Written Standards and Procedures
We have developed written standards of conduct and policies and procedures that incorporate the culture of compliance into our day-to-day operations, guide our Associates in conducting business professionally and properly, include a clearly delineated commitment to the Compliance Program, address awareness, prevention and detection of specific fraud and abuse risk areas, provide guidance to Associates on how to communicate compliance issues to appropriate compliance personnel, describe how potential compliance issues are investigated and resolved by the organization, and prohibits retaliation for good faith participation in the Compliance Program. Our standards of conduct are memorialized in our Core Values in Action Booklet and referred to as our “Code of Responsibility.”
Compliance training is at the very heart of our Compliance Program and is the proverbial “means to an end” inasmuch as it is a central mechanism that is used to communicate and educate all Associates on our commitment to professional, legal, and ethical conduct, as well as our risks, expectations, compliance resources, and their compliance responsibilities. While there are various forms of compliance training that occur throughout a year, all new Associates receive general compliance training upon hire and all existing Associates annually receive at least one hour of general compliance training highlighting our Compliance Program and emphasizing our commitment to compliance with state and federal fraud and abuse statutes, regulations, and payer policies. At the completion of general compliance training, all Associates are required to attest to their knowledge of and commitment to the standards of conduct and Compliance Program. In addition, all Associates involved in the coding and billing process are required to attend additional training sessions tailored to their job responsibilities.
Auditing and Monitoring
The use of audits and/or other risk evaluation techniques to identify and prioritize risks, monitor compliance, and assist in the reduction of identified problem areas is a core element of our Compliance Program. Annually, the Compliance and Internal Audit teams collaborate with the Compliance Advisory Group and other Associates to conduct a comprehensive self-administered risk assessment that identifies and ranks the various compliance and business risks most likely to occur. Utilizing the data from the Risk Assessment, each year, the Compliance and Internal Audit teams develop a Compliance Work Plan and an Internal Audit Work Plan identifying auditing and monitoring activity to be performed throughout the year.
Reporting Concerns and Seeking Guidance
At Ensemble, each of us has a duty to speak up to ensure that Ensemble remains a model of responsible and ethical practices. At the same time, we recognize that it is not always easy or comfortable to talk about suspected misconduct. Consequently, we have contracted with an independent outside entity to operate a toll-free Compliance Hotline and Web-Based Portal that are available 24 hours a day, seven days a week to provide Associates with a mechanism to report, anonymously if desired, suspected violations of Ensemble’s Compliance Program.
Equally important to our Associates reporting concerns about suspected violations of the Compliance Program is what we do with the information that is reported. Through the Compliance Program, we have established a process for the independent investigation of reports of suspected violations of our Compliance Program by qualified personnel. This process is memorialized in a Compliance Investigations policy that is publicized to all Associates to inform them about the process that occurs when they report suspected misconduct. In addition, we have developed a Non-Retaliation policy to inform our Associates of the existing protections against any form of retaliation including discharge, demotion, suspension threats, harassment, or discrimination for making a good faith report of suspected misconduct and the consequences of retaliating against an Associate that makes a good faith report of suspected misconduct.
Corrective and Disciplinary Action
An effective Compliance Program depends on setting standards of behavior and conduct through adequate written guidance and training and then exercising consistent enforcement, corrective action, and discipline for violations of the Compliance Program. We have developed a Corrective and Disciplinary Action policy that sets guidelines for uniform corrective/disciplinary actions for violations of our Compliance Program consistent with the Human Resources policies and procedures.