Compliance Program

TeamHealth has a comprehensive ethics and compliance program that expresses our corporate commitment to comply with federal, state and local laws. The establishment of written standards, creation of an awareness of this commitment and standards through the provision of training and education for physicians, non-physicians and staff members of our company, the development of a risk assessment process, the maintenance of a monitoring program for misconduct, the implementation of an anonymous reporting system, and the enforcement of standards of conduct.

TeamHealth's Compliance Program

TeamHealth has established a comprehensive compliance program that is consistent with the following OIG program guidlines with modifications to fit our unique environment.

• OIG Compliance Program Guidance for Hospitals
• OIG Supplemental Compliance Program Guidance for Hospitals
• Program Guidance for Third-Party Medical Billing Companies
• Program Guidance for Individual and Small Physician Practices

Our Compliance Program, established by the Board, is one of the key components supporting our commitment to high standards of corporate conduct. The compliance program is a tool to strengthen the company's efforts to detect and prevent violations of law or company policy. While a compliance program does not assure that improper conduct will be eliminated, it is the expectation of TeamHealth that associates will comply with the Code of Conduct and the policies established in support thereof. In the event that TeamHealth becomes aware of diversion from policy, we will investigate, take disciplinary action and implement corrective actions to prevent future occurrences when appropriate.

Under the leadership of the Chief Compliance Officer, the Compliance Program is multi-layered and dynamic. It presents a supportive structure to management, physicians and staff; applies to employees, contractors and vendors; and showcases the commitment of senior management. Our policies have taken into consideration the nature of our business as a provider of outsourced physician services in emergency medicine, hospital medicine, anesthesia, urgent care and pediatrics.

 

Overview of TeamHealth's Compliance Program

Written Standards
TeamHealth's Code of Conduct is our written statement of ethical practices that direct our daily operations. The Code of Conduct establishes our expectations of management, employees and contractors to act in accordance with applicable laws and company policy. It sets forth the framework for action within the company.

TeamHealth's records management, retention and destruction procedures support the maintenance of complete, accurate and high-quality records. Our records are retained in accordance with all applicable laws, regulations and policies.

Federal and State False Claims Act Education Policy

Program Structure
Chief Compliance Officer: TeamHealth has designated a Chief Compliance Officer who is charged with the responsibility of day-to-day direction, development, implementation and monitoring of the compliance program. The Chief Compliance Officer reports to the CEO and the Board and has the ability to exercise independent judgment and to effect change within the organization as necessary.

Executive Compliance Committee: TeamHealth has established an Executive Compliance Committee to ensure that the corporate culture of high ethics is continually emphasized. The committee structure provides a forum for communication, discussion of topics essential to an effective compliance program and assurance that policies address the needs of the company.

Education and Training
A key component of our Compliance Program is the education of all TeamHealth corporate officers, managers, employees and vendors who work with protected health information and independent contractors. All new affected persons are trained as hired or contracted. Currently affiliated affected persons are trained annually regarding their legal and ethical obligations under applicable federal healthcare program law, TeamHealth's Code of Conduct, HIPAA and compliance policies. TeamHealth regularly reviews and updates its training programs, as well as identifies new risks for inclusion in the training program.

Communication
TeamHealth fosters an open line of communication between personnel and management. All persons seeking answers to questions or reporting potential violations of law, should know with whom to speak for thoughtful answers without fear of retaliation. In addition, TeamHealth expects that employees and affected contractors will inform the company of any known or suspected offense. In support of this, TeamHealth has developed an open-door culture, policies and orientation programs. It is expected that when comfortable doing so, the concerned party should report concerns to his or her supervisor. For those instances where the individual is not comfortable with this avenue, the company has established an anonymous reporting system entitled "The Hotline." The Hotline number is 888.315.2362. No matter which avenue is pursued, TeamHealth emphasizes that raised concerns will be treated with respect and confidentiality.  

Risk Assessment, Auditing and Monitoring
Risk Assessment: On an annual basis, TeamHealth identifies internal areas of risk to the company. In addition, OIG guidance annually identifies potential risk areas for hospitals, third-party billing and physician practices. These risk areas include, among others, data integrity relating to government reimbursement, kickbacks and other illegal remuneration and violations of HIPAA and EMTALA. A composite list is developed, and identified risks are reviewed for pertinence. These are included, in whole or in part, in TeamHealth's Auditing and Monitoring program.

Auditing and Monitoring: The TeamHealth auditing and monitoring program, in addition to risk assessment, includes the monitoring of the company's adherence to its policies. Our auditing and monitoring program may be conducted using prospective, concurrent, or retrospective time frames. The outcomes of the auditing and monitoring program are communicated to TeamHealth's Board, senior management and the Executive Compliance Committee. The extent and frequency of the program varies in relationship to several factors, including changes in management staff, business practices, regulations and other variables. Throughout the year, ongoing assessment within our compliance programs may identify new risk areas that are included in the auditing and monitoring program on an as-needed basis.

Ineligible Persons
TeamHealth does not contract with, employ or bill for services rendered by an individual or entity who has been excluded or deemed ineligible to participate in federal healthcare programs, suspended or debarred from federal government contracts, or convicted of a criminal offense related to the provision of healthcare items or services and has not been reinstated in a federal healthcare program after a period of exclusion, suspension, debarment or ineligibility, provided that we are aware of such criminal offense.

Disciplinary Action and Prevention
All violators of the company's Code of Conduct policies and procedures will be subject to disciplinary action. The exact nature of discipline will depend on the nature, severity and frequency of the violation. To support this process, the associate will received appropriate disciplinary action. Depending on the offense, we may take immediate action up to and including termination without interval progressive disciplinary process.

After a violation has been detected, the organization will take all reasonable steps to correct the area of concern, including any necessary modifications to TeamHealth's compliance program to prevent and detect violations of law, in order to prevent recurrences.

Responding to Government Investigations
TeamHealth will always cooperate with legitimate government investigations and reasonable requests for information from government agencies. TeamHealth's associates will be responsive to requests for information during such investigations. However, no interview or discussion will take place in a patient care area or an area frequented by visitors. To ensure correct information is shared and because of our concern for patient confidentiality, the associate will contact TeamHealth's Chief Compliance Officer for direction.

Program Effectiveness
TeamHealth's compliance program is a dynamic program that addresses risks posed by complex laws as well as human factors. It adapts modifications in response to regulatory change, internal findings and corrective actions, among other variables. TeamHealth monitors and measures our program effectiveness through an assessment of our effort and outcomes.

• Effort. TeamHealth's commitment to its compliance program is demonstrated by its provision of appropriate financial support, personnel and resources to accomplish the mission of its compliance program.
• Outcomes. TeamHealth's compliance program produces measurable outcomes within each of the integrated program components. The program design, implementation, coordination, results and corrective actions are demonstrated to the Board on a quarterly basis.