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Infirmary Health System, Inc.
Corporate Compliance Plan

Download: Corporate Compliance Plan

Plan Purpose:
Infirmary Health System ("IHS") acknowledges the risks that are involved when fraud, abuse and waste occur in the healthcare environment. In an effort to detect and minimize these risks within the System, IHS has adopted this Corporate Compliance Plan (the "Plan"). This Plan has been developed based on guidance provided by federal healthcare authorities.

This Corporate Compliance Plan is endorsed by the IHS Board of Directors. On behalf of the Board, the System President and Chief Executive Officer is responsible for approving this Plan. The Compliance Officer is responsible for administration and maintenance of the Plan. This Corporate Compliance Plan applies to all persons or entities who are employed by or conduct business with IHS. Infirmary Health System is committed to the enforcement of all components within this Plan. That commitment and responsibility must be shared by all individuals who maintain a relationship with IHS.

This Plan serves as an "umbrella" Plan for all entities within the System. However, to ensure effective implementation of compliance in specialized areas, detailed plans will be separately developed by Infirmary Medical Clinics, P.C. and Lab Services. Each Compliance Plan adopted will be considered a "living" document and must fit within the framework of this Plan. As needed, all plans will be updated periodically to include the most current information regarding compliance in the healthcare industry. IHS employees have access to this Plan and any other compliance material in the IHS Personnel Policy Manual.

The IHS Corporate Compliance Plan includes the elements outlined in the Health and Human Services, Office of Inspector General's Model Plan, the 2005 OIG Supplemental Compliance Guidance, Federal Sentencing Guidelines issued in 2004, and the Deficit Reduction Act of 2005. The elements are:

- High-level Oversight of Compliance Responsibilities
- Compliance Standards and Policies
- Due Care in Retaining Trustworthy Individuals Throughout IHS
- Education and Training
- Monitoring, Auditing and Reporting
- Enforcement and Discipline
- Response and Prevention
- Risk Assessment
- Federal and State False Claims Acts