Compliance for Me 2012

1. Compliance for Me 2012

2. Objectives After reviewing this training and successful passing of the quiz, you will be able to: • Understand your responsibilities in maintaining a culture of compliance in the workplace • Learn where compliance policies and documents are located for easy reference • Fulfill training requirements established by Federal and State laws

3. Exploring Questions & Answers • What is Compliance? • What are my responsibilities as an employee? • Where do I find assistance when needed? • Where are resources located? Your Text Here

4. What is Compliance? Optima Health demonstrates compliance when our business is conducted legally and ethically, using the highest clinical and business ethics for our members and employees while complying with all the laws that govern our day-to-day operations.

5. Integrity 1st attribute

6. Integrity Code of Compliance Use the Code of Compliance as a guide to help you in your daily work. • The Code provides general compliance guidelines that are explained in the company’s policies and procedures. • Located on Wavenet/Optima Health/Related Links. • Training is provided at time of hire and yearly • Your annual signature is an agreement to comply with the Code of Compliance and to report any suspected or possible violations to the appropriate resource(s).

7. Integrity Conflict of Interest A conflict of interest exists when there is a conflict between a person’s private or personal interests and his/her responsibility as an employee. You must avoid entering into relationships or activities that could interfere or appear to interfere with your judgment in making sound business decisions for Optima Health. Examples of conflict of interest: • Investments, employment or other business relationship with a competitor or customer of Optima. • Gifts (money, favors, discounts, meals or travel) from vendors or competitors to you and your family in excess of $25.

8. IntegrityGifts Our success in the marketplace results from providing superior services at competitive prices. Our company does not seek to gain improper advantage by offering business courtesies, such as entertainment, meals, transportation, or lodging to our customers. • Gifts (money, favors, discounts, meals or travel) from vendors or competitors to you and your family in excess of $25. • Gifts to Physicians may not exceed the federal limit for the year. All gifts must be approved by a Senior Leader and logged on the shared drive. • Gifts to Government employees must be less than $20. • Gifts to non-government employees must be less than $25.

9. Integrity Member’s Gifts & Prizes • The Legal and/or Compliance Department must approve all activities that includes selling, offering or promising of any gift, raffle, prize, giveaway or other incentives to members. • Gifts and incentives to Medicaid members may not exceed $15. Gifts to Federal Employee members gifts may not exceed $5. Amounts for gifts to Commercial members must be approved prior to offering. • This includes gifts, rewards, or incentives for Wellness Programs, HRAs, Disease Management, etc.

10. Behavior 2nd attribute

11. Behavior Use of Resources Use of company equipment such as stamp machines, long distance service, copier, video equipment, etc. is not permitted for personal use, except in emergencies or when extenuating circumstances warrant it. Any improper financial gain to an employee through misconduct involving Optima Health property, including theft of property, embezzlement of money or the use of money belonging to Optima Health for anything other than an authorized purpose is a serious violation and may lead to prosecution.

12. Behavior Social Media • Employees are expected to portray a positive image of Optima, refrain from spreading rumors and gossip, and not share confidential or proprietary information on the internet. • Optima employees will be held accountable for any internet postings, personal or business-related as outlined in the Statement of Employee Responsibility & Confidentiality, and HIPAA regulations. • Prohibited Personal Internet Activities: • Cannot use Optima logo. • No photos or videos from Optima posted. • No negative postings about Optima employees, Physicians, members, vendors, partners or competitors. • No member information posted.

13. Attitude 3rd attribute

14. Attitude Confidentiality Employees have a responsibility to not talk about internal company information, our members, employees and/or business associates to anyone outside the company. This responsibility includes any nonpublic business plans, financial, personnel or technological information. This confidentiality restriction applies even after employment ends.

15. Attitude Team Spirit Team spirit is defined as the spirit of a group that makes the members want the group to succeed. You are part of the team and you can make a valuable contribution every day. Let’s keep the spirit going!

16. Leadership 4th attribute

17. Leadership Policies & Procedures Policies reflect the rules governing the implementation of the company’s procedures and processes. Optima has a “Policy Template” for all Departments to use for all policies and procedures. The purpose of a standard template is to provide a consistent, logical framework, making it easy for regulators to identify which process is associated with a regulation and assist employees to do their jobs. The policy and procedure format should be used during policy reviews and at the time new policies are developed. The template can be found on SAL, under the badge in the Compliance folder.

18. Leadership Compliance Advice When seeking advice from the Compliance Department on regulations, issues, problems, etc: 1. Your question: Be very specific when describing the situation, and provide details, which may affect the answer. 2. Compliance Response: The Compliance Department gives conservative interpretations of regulations, not legal advice. Confidentiality is maintained as much as possible. 3. Your Responsibility: The Business Owner and Senior Leadership must decide how to use the information to make the best business decisions. Decisions should be documented for future reference.

19. Leadership Reporting Reporting concerns so they are properly addressed is everyone’s responsibility. If a concern is identified but not reported, there is the potential for that concern to remain “undetected” and this can place employees, members and the organization at risk in any number of ways. Compliance will carefully assess all facts without bias and evaluate the process or system to determine the necessary response, this ensures that the regulations and standards are handled consistently and fairly. This process assists in creating a safe reporting environment and a just and ethical culture.

20. Leadership Reporting Violations If you feel there is a situation or problem that needs to be reported - ask yourself the following questions: • Is this behavior in compliance with the Code of Compliance, Optima Health policies, Federal & State laws and/or regulations? • Is this situation uncomfortable? • What would the general public think? Report your concerns to your supervisor, your supervisor’s supervisor, HR, the Compliance Officer, a Compliance Committee Member, the two different Hotlines or the FWA email.

21. Leadership Hotline Reporting If you choose to utilize the Hotline for reporting your concern or problem, the Hotline: • Allows you to receive clarification on ethical issues and any areas of the Code of Compliance; • Is available for reporting concerns or potential violations; and • Guarantees that all calls are confidential and may be made anonymously. Call: Sentara Integrity Hotline 1-800-981-6667 Optima FWA Hotline 1-86-826-5277 or Email: www.compliancealert@sentara.com

22. Leadership Record/Documentation Management • All employees must take great care to guarantee that all Optima Health records and transactions are complete, accurate, timely and in compliance with policies and procedures. • Marketing documents for commercial products must be approved and filed through the Compliance Department according to the regulations of the Bureau of Insurance. • All Commercial, Medicare and Medicaid documentation, records and transactions must be kept on file and retrievable for a period of ten (10) years. • If you have any questions about document destruction, please contact Compliance.

23. Leadership Contracts Contract Management for your Department/Unit is the responsibility of the Manager/Director/VP (Business Owner). • Guidelines for drafting, approving, executing, tracking, and storing of contracts or letters of agreement are posted on the shared drive/everyone. • All contract documentation including attachments and addendums (Business Associate Agreement, etc.) must be submitted for review and approval by the Legal Department. • The Business Owner is responsible for maintenance and storage of all contracts.

24. Leadership Responsibility • We are all expected to do the jobs we were hired to do and that means we need to stay informed about appropriate standards to properly carry out our duties. • Being a leader, maintaining your integrity, demonstrating good behavior and having a positive attitude helps contribute to creating a just and ethical culture within Optima.

25. Compliance is Everyone’s Responsibility

26. This is the end of the 2nd Module of the 2012 Optima Health Compliance Course. Please begin Quiz #2