Information about St. Luke's Corporate Compliance Program for Contractors and Agents
Through its Compliance Program, St. Luke's strives to comply with all legal and regulatory requirements, prevent and detect any unlawful and/or unethical conduct by its employees, contractors and agents, and avoid unlawful or unethical business practices. St. Luke's requires contractors and agents to adopt and abide by these policies in connection with the services they provide.
St. Luke's Code of Ethics is the basis for the Compliance Program.
The Governing Board of St. Luke's Hospital and Regional Trauma Center has adopted this Statement of Organizational Ethics to establish expectations for conduct. It is the intent of the Board of Directors to set forth specific principles that all individuals, acting on behalf of the Hospital, will adhere to while conducting such activities:
- We treat all patients, employees, physicians, and visitors with respect, dignity, and courtesy.
- We represent the Hospital's services and capabilities accurately and fairly to the public.
- We adhere to comparable standards of care throughout the organization.
- We provide necessary services within the capabilities of the Hospital and will seek to avoid unnecessary or non-effective care within the parameters of patients' rights and existing policies.
- We provide patients information about their rights and attempt to maximize those rights through advocacy procedures and complaint/grievance processes.
- We adhere to local, state, and federal laws.
The plan of care and provision of patient care will be based upon the physician's judgment, needs of the patient, policies, protocols and standards, and not based upon the patient's ability to pay or other issues not related directly to patient care (i.e., culture, race, gender).
We maintain the confidentiality of all patient information consistent with applicable state and federal laws.
Respect for the Patient
We treat all patients with dignity, respect, and courtesy. The organization recognizes patients' rights as an integral part of patient care. If patients are unable to represent themselves, their designees will be involved as their representatives with respect to care decisions.
Resolution of Conflict
We recognize the Hospital is made up of a diverse workforce and those participating in patient care decisions may experience conflicts related to those decisions. No matter whom the conflict involves, the intent is to have a fair and objective outcome. When parties cannot reach consensus, or mutual satisfaction is not achieved, it is St. Luke's policy to involve the Administrator On-Call and/or the Bio-Medical Ethics Consultation Team to act as intermediary and oversee resolution.
Recognition of Conflicts of Interest
There is the possibility for Conflicts of Interest to exist at all levels of decision-making within the Hospital organization. It is our policy to request disclosure of potential conflicts of interest so that important decisions will not be unduly influenced. A disclosure form is to be completed annually by employees who have substantial authority in resource allocation, Department Directors, and Administrative Staff. Resolution will be handled through the chain of command or at the Board of Directors level, if indicated.
Fair Billing Practices
Patient and third party payers will be billed only for those services actually provided to the patient. We accept responsibility for reporting illegal or unethical conduct to the proper authorities. The Customer Service and Complaint Resolution Policy will be followed by the Business Office and other involved departments when complaints are received. Patients will be assisted by appropriate staff in understanding what care was delivered and how charges were incurred. Attempts will be made to resolve issues to the satisfaction of patients. If resolution is not accomplished through the patient complaint process, patients will be advised and assisted with the grievance process as outlined in the policy.
St Luke's Compliance Policies
St. Luke's has established a number of policies and procedures to avoid circumstances that could result 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.
Any employee or contractor who knows or suspects a violation of the Corporate Compliance Program, federal, state or local law, must report their concerns to St. Luke's Compliance Officer, a St. Luke's Department Director, Vice President, or the President/CEO. The Compliance Officer (CO) may be reached in person or by phone at 218-249-5357. The President/CEO may be reached in person or by phone at 218-249-5484.
If the appropriate hospital representative is not available or the employee or contractor chooses, for whatever reason, to not discuss their concerns with them, two anonymous methods for reporting concerns have been established. Written reports may be sent the Compliance Officer at St. Luke's Hospital, 915 East 1st Street, Duluth, MN 55805. A Compliance Hotline has been established at 218-249-6025. Confidentiality regarding the issues raised through a hotline call will be protected up to the limits of the law and to the extent reasonably possible.
The Compliance Officer (CO) is responsible for ensuring that a timely, independent investigation on compliance issues brought to his or her attention is completed.
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).
- St. Luke's Compliance Program, described above, identifies and prevents circumstances that might result in submission of false claims. All employees, contractors and agents are required to report concerns to a member of St. Luke's Management, or directly to the Compliance Department. Entities may, but are not required, to notify the government of their concerns.
- Civil penalties for submitting false claims are $5,000 to $10,000 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.