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Compass SM Booklet How we conduct ourselves reflects who we are as a company.

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Compass SM Booklet How we conduct ourselves reflects who we are as a company. A message from Dr. Bob Lufrano, our Chairman and CEO Dear Colleagues: Throughout our history, Blue Cross and Blue Shield of
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Compass SM Booklet How we conduct ourselves reflects who we are as a company. A message from Dr. Bob Lufrano, our Chairman and CEO Dear Colleagues: Throughout our history, Blue Cross and Blue Shield of Florida has maintained a solid commitment to ethics and compliance with all laws. The way we conduct business is guided by our strong values and demanding ethical standards for honesty, fairness and integrity. Living this commitment through our behaviors in our daily work provides significant benefits for the company, for our customers and for you. The Compass Program SM was specifically developed to educate anyone representing our organization employees, temporaries, contractors, board members on the legal requirements and ethical rules which apply to BCBSF s business, including federal and state laws and regulations, as well as related accreditation requirements. The Compass Program remains the cornerstone of our commitment to ethics and compliance, so please familiarize yourself with the information contained in this booklet. The information presented provides a comprehensive foundation for understanding the compliance issues we face and the ethical standards under which we operate. Because laws and regulations change rapidly, we strongly encourage you to read the booklet carefully, as it has been significantly updated. Having a good understanding and embracing the principles of the Compass Program are critical to our company s success. If we exemplify the highest standards of ethical behavior, we can all play a role in adding value to the organization and our customers while supporting our Mission of providing health care solutions that improve the lives of all Floridians. Thank you for a job well done and for your commitment to Blue Cross and Blue Shield of Florida and the more than 8.8 million Floridians we serve. Cordially, Chairman and Chief Executive Officer 2 BCBSF COMPASS PROGRAM SM OUR COMPANY... 5 Introduction... 5 Corporate Values... 5 Compliance and Ethics... 5 Our Ethical Decision Making Framework... 6 Management and Individual Responsibility... 6 We Won t Tolerate Retaliation... 7 CONFLICTS OF INTEREST... 8 Conflicts of Interest... 8 BUSINESS WITH GOVERNMENT EMPLOYEES AND LOBBYISTS... 9 Government and Competitive Information... 9 Government Business: Submitting Data, Documents and Other Information to the Government... 9 Gratuities and Government Employees... 9 LOBBYING...10 Florida Lobbying Expenditures General Guidelines to Follow Before Offering Any Gift or Gratuity to Any Government Employees Employment of Government Officials or Employees GIFTS, ENTERTAINMENT AND BUSINESS AND TRAVEL EXPENSES...12 Receipt of Gifts Bribes, Kickbacks, Gifts, Gratuities and Entertainment in Business Travel MARKET ALLOCATION AND OTHER AGREEMENTS...14 Receipt of Kickbacks and/or Rebates Other Improper Payments Antitrust Insider Trading and Self-Dealing Restraining Trade Price Fixing Use of Size, Market Position or Purchasing Power Communications with Competitors and Participation in Surveys Advertising Mergers and Acquisitions State Antitrust and Unfair Competition Laws FINANCIAL INTEGRITY AND ACCURATE COMPANY RECORDS...18 Accurate Record Keeping Responses to Auditors Fraud, Waste and Abuse Procurement of Goods and Services INTERACTIONS WITH THE PUBLIC...20 Political Activity and Contributions Charitable Activity and Contributions Specific Guidelines Regarding Direct Requests for Information SAFEGUARDING INFORMATION...22 Information Reporting of Privacy Disclosures Confidential, Proprietary and Private Information Statement Regarding Confidential and Proprietary Information THE COMPASS SM HELPLINE 1 (800) , X Reporting of Security Incidents Retention of Records COMPUTER DATA AND PROGRAMS...27 Computer Software Corporate Information Security USER-ID COMPANY, EMPLOYEE AND COMMUNITY RELATIONSHIPS...28 Employee Data Verification of Employment Loans to Officers and Directors Equal Employment Opportunities Standard of Conduct Use of Corporate Assets Internet and Usage Solicitation and/or Distribution of Literature Substance Abuse Weapons or Firearms Work Related Charges or Indictments Arrests on Company Property or While on Company Business Safety and Health Corporate Contracting ATTACHMENTS...33 CORPORATE COMPLIANCE AND ETHICS PROGRAM DESCRIPTION...33 POLICY REPOSITORY BCBSF COMPASS PROGRAM SM OUR COMPANY Introduction Blue Cross and Blue Shield of Florida and its subsidiary companies, (referred to hereafter as BCBSF or the company) has a long-standing and deep commitment to conducting business ethically, with integrity and in compliance with applicable law. On Nov. 12, 1993, the BCBSF board of directors adopted policies governing the conduct of the company s directors, officers and employees. This board resolution led to the establishment of the Compass Program SM, BCBSF s compliance and ethics program. The Compass Program SM is designed to educate all BCBSF directors, officers, employees, temporaries, contractors, consultants and representatives of BCBSF (referred to hereafter as employees) on the applicable legal requirements (including federal and state laws/regulations) and ethical rules which apply to BCBSF s business, raise awareness of questionable conduct, monitor compliance and provide effective mechanisms for reporting suspected violations. Corporate Values The board of directors adopted a company-wide Beliefs and Values Statement in July We have adopted this statement as our corporate mission. A mission sets forth the purpose of an organization; it answers the question Why are we here? Paraphrased, our mission is to be a community-driven, customer-focused organization: Committed to the public good; Advancing the health and well-being of Floridians; Working for an excellent, efficient health system; Providing affordable products and services; and Helping the state find solutions for the uninsured and underinsured. As an independent, policyholder-owned Blue Plan, we have a unique role in advancing the health and well being of Florida's citizens. We will go beyond the traditional role of an insurer by promoting health and wellness programs for the general public through community giving and volunteerism. We are committed to the following values: Customers, are our reason for being Employees, our most valued resource for our customers; Performance-based Open, honest, ethical, respectful Diverse and culturally competent Participative, team based, individual excellence Learning organization, continuous improvement, speed to market; Relationship-based Balance: family, health, work Compliance and Ethics BCBSF conducts business ethically, honestly and in compliance with the law. Sometimes we cannot rely solely on laws to help us determine right and wrong. Laws do not cover some situations, and sometimes laws will permit actions that don t promote the level of honesty, fairness or integrity that the company promotes. BCBSF expects you will always conduct yourself in a manner that promotes the safety and welfare of employees and our customers and, encourages a cooperative professional work environment, protects personal rights and corporate property and demonstrates the highest standard of ethics. It is your responsibility to THE COMPASS SM HELPLINE 1 (800) , X make yourself familiar with this booklet and with the policies and procedures of BCBSF. Remember that this booklet is a guide and the policies and procedures of BCBSF take precedent. Our Ethical Decision Making Framework There may be times when you have questions or concerns about whether an action or situation is inappropriate. Asking yourself the following questions might help you resolve the issue or decide what further action you should take. If you need help applying the framework please contact the Corporate Ethics and Compliance Office. What doesn t feel right about this situation? o Is this a compliance issue? Is this against a company policy/procedure or the law? o Is it an ethical issue or situation? Does this situation raise questions about honesty, fairness or integrity? Does this situation violate a professional code of ethics (i.e. Certified Compliance Professional, Certified Internal Auditor, Certified Public Accountant, Registered Nurse, Medical Doctor, etc.)? Who is affected by this situation? o Are our customers affected? o How will I be affected? Could I feel a sense of pride if I shared this situation with my family or my colleagues? o How is the company affected? If this situation was made public, could it be viewed as the wrong decision? What do others think about this situation? o To whom can I turn for advice? o Are there any alternatives that do not pose a question of ethics? Management and Individual Responsibility No BCBSF employee should ever be expected, encouraged or allowed to violate any law, and no employee should ever believe that breaking the law in an attempt to help BCBSF is an indication of loyalty. To the contrary, the greatest loyalty that an employee can demonstrate to BCBSF is unfailing attention and adherence to the laws of the land. As an employee, you have the right and the responsibility to question or challenge situations in which you suspect something unethical or illegal is occurring or has occurred. You also have the obligation to report these items. The company is committed to reviewing your concerns and addressing them as appropriate. Issues that are found to have merit lead to measures such as change in business processes, coaching, suspension, demotion, termination of employment or legal action. The company won t know about a situation unless you tell someone. If you are aware of issues and don t report them, it could result in the same measures listed above. If you do report suspected misconduct, you have an obligation to cooperate in investigating the matter. BCBSF is committed to providing ways you can report situations without fear of reprisal. You should first discuss the situation with your immediate supervisor. Give your supervisor the opportunity to address the situation. If the situation is not handled to your satisfaction or you are not comfortable talking to your supervisor, try talking to your manager. If you still are not satisfied or are uncomfortable talking to your manager you may contact the Corporate Compliance and Ethics Office. Please contact: 6 BCBSF COMPASS PROGRAM SM Edward J. Garcia, Corporate Compliance Officer ((904) , (58750), Pauline Rosenberg, Director for Corporate Compliance and Ethics and Privacy Official (904) , (55025), Jean Butler, Senior Manager for Corporate Compliance and Ethics (904) , (57115), or Karen Gray, Senior Manager for Corporate Compliance and Ethics (904) , (54264) You may also contact the Legal Affairs Division or an Employee Relations Consultant. If you wish to remain anonymous, you may contact the Corporate Compliance and Ethics Office through the Compass SM Helpline x56300 (internally x56300) or you can access EthicsPoint from home using the link on the Employee Internet Web site. We understand many people prefer their communication with the Corporate Compliance and Ethics Office remain confidential. Although we will try to protect your confidentiality, we cannot guarantee it. Sometimes it is impossible to investigate situations without involving you. We believe it is better to come forward than to let the situation continue. BCBSF has a nonretaliation policy to protect you. If you choose to make an anonymous report, you should provide enough information about the situation to allow the company to properly investigate it. It can hamper our investigation if we do not have enough information to investigate the report. It also prevents us from notifying you when we have completed our investigation and taken appropriate action. Here is a guide to help you in the event you choose to make an anonymous report. Describe the situation in detail and include the business area and people involved. Identify dates when events occurred. Let us know if you observed this directly or someone told you about it. Tell us how the situation occurred (Was a procedure not followed? Was someone told to do something inappropriate?) Describe any relevant documents that could help. The company will make every attempt to investigate situations reported. If you don t provide enough information in your anonymous report, it may limit our ability to review it that could in turn, result in our inability to take action. We must be able to substantiate allegations before taking action on a situation. We Won t Tolerate Retaliation Reporting situations that may violate the compliance program is vital to the success of the Compass Program SM. BCBSF will not tolerate retaliation for reports of suspected wrongdoing if you act in good faith. Allegations of retaliation will be investigated. Retaliation for good faith reports of suspected wrongdoing will result in corrective action up to and including termination. If you suspect you or someone you know has been retaliated against for raising a situation, immediately contact the Corporate Compliance and Ethics Office or an Employee Relations Consultant. Keep in mind acting in bad faith, such as intentionally reporting a false allegation, violates the Compass Program SM and is subject to disciplinary action, up to and including termination. THE COMPASS SM HELPLINE 1 (800) , X I am a customer service representative and have an opportunity to moonlight in the billing department of a large physician group. Can I take the job? Generally, it is acceptable to do this, but you will need to check with Corporate Compliance & Ethics Office or Legal Affairs Division. There are certain guidelines that should to be followed. My spouse works for a vendor providing services to BCBSF. Should I report this? Yes. You should disclose this on your Conflict of Interest Form. CONFLICTS OF INTEREST Conflicts of Interest As a BCBSF employee, you may be confronted with a situation where a spouse or significant other, another member of your immediate family, or someone close to you is a competitor, supplier, or provider of medical services or products to BCBSF or employed by a business partner, competitor, provider or supplier to BCBSF. The closeness of the relationship might lead an employee to inadvertently compromise BCBSF s interests. A situation, however harmless it may appear to you, could raise suspicion among other employees or outsiders that might affect working relationships. The very appearance of a conflict of interest can create problems regardless of the behavior or intentions of the BCBSF employee. Upon being hired and in the annual Conflict of Interest Disclosure Statement, you will be asked to disclose any instances that may be a conflict or create the appearance of conflict. Additionally, you have an ongoing duty to inform the company of any situation that may create a conflict of interest or create the appearance of conflict. In the event there is a conflict situation, an employee may be required to take action to remove himself or herself of the conflicting interest or, if possible, to file a formal recusal from any participation in the conflicted matter or activity. If you are not sure whether a situation is a conflict of interest, contact your supervisor, the Legal Affairs Division, Employee Relations or the Corporate Compliance and Ethics Office. There are many situations that may be a conflict of interest or create the appearance of conflict. Here are just a few examples: You take a leadership or a financial position in an organization that competes with or is a potential competitor of BCBSF. You enter into a business relationship with another person or business providing services to BCBSF, its subsidiaries, or customers. You or a member of your family accepts gifts, excessive or unusual entertainment, or other favors from any person or firm that does business with, or is seeking to do business with, or is a competitor of BCBSF. In other words, avoid any situation in which, for example, your personal financial interest would be a conflict with your loyalty to the company. This does not apply to investments in mutual funds or other investment vehicles where you do not direct the investment decisions. 8 BCBSF COMPASS PROGRAM SM BUSINESS WITH GOVERNMENT EMPLOYEES AND LOBBYISTS Government and Competitive Information BCBSF employees are prohibited from attempting to obtain, from any source, government information that is procurement sensitive or any information of a competitor in a government procurement where there is reason to believe the release or receipt of such information is unauthorized. Federal Procurement Integrity law specifically prohibits persons from obtaining non-public contractor bid or proposal information or source selection information before the award of a federal agency procurement contract to which the information relates. This includes information submitted to a federal agency in connection with a bid or proposal on a federal contract as well as information prepared for use by a federal agency in evaluating a contract bid or proposal. Any BCBSF employee who has questions concerning the procurement integrity law should consult with Legal Affairs Division or the Corporate Compliance and Ethics Office. Government Business: Submitting Data, Documents and Other Information to the Government It is BCBSF s policy to deal honestly in all its relations with the government. The laws and regulations governing contracting with the United States government impose stringent rules. For example, it is a crime to make a false claim or false statement to a government official or to conceal or cover up any material fact in claims or other matters before the government. BCBSF employees must ensure the representations made to any government employee or in any document submitted to the government are accurate and not misleading. From time to time, BCBSF is required to produce or provide data, information and other documents, including contract performance data, for review by the Centers for Medicare and Medicaid Services (CMS) or other federal and state agencies. Many employees within BCBSF are responsible for generating, preparing, monitoring and auditing the accuracy of such information and data. All of us play an important role in ensuring all such information and data are prepared with care and diligence. BCBSF has a system of internal controls to assist employees responsible for these very important functions. It is key, however, employees raise questions with management when there is doubt or ambiguity regarding BCBSF s obligations or the obligations of its employees. It is company policy to seek clarification from the government and to document in writing the guidance provided by government officials on which the company has relied concerning BCBSF s obligations and reporting requirements. Questions concerning issues should be referred to the employee s supervisor, the Corporate Compliance and Ethics Office or Legal Affairs Division. Gratuities and Government Employees BCBSF employees must not offer things of value that could be considered a bribe, or give the impression of bribing any public employee by offering or promising anything of value with the intent to influence any official act or because of the public employee s official position. Public employees include all employees of any federal, state or local government entity, whether that entity regulates BCBSF or purchases coverage plans or other products or services from BCBSF. For example, school boards and public hospitals purchasing coverage plans/policies from BCBSF are government entities, as are the Center for Medicare and Medicaid Services (CMS), Office of Personnel Management (OPM) and other federal agencies. It is the policy of BCBSF to treat the government in a fair manner and in accordance with all applicable laws and regulations. BCBSF believes government decisions should be made on
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