What conduct must I report?
As UK HealthCare employees, you are obligated to promptly report any conduct that you are aware of, that you in good faith believe is illegal, unethical, or abusive or otherwise violates the intent of the Corporate Compliance Program. Potential issues or areas of concern include, but are not limited to:
- Patient Care
- Patient Referrals and Referral Sources
- Vendor and Supplier Relationships
- Operational, Business and Financial Integrity
- Soliciting, Receiving, Providing or Offering Illegal Compensation
- Conflicts of Interest, Duty of Loyalty and Duty of Care
- False Statements, Claims and Representations
- Research and Scientific Integrity
- Coding and Billing Practices
- Confidentiality of Medical Information
- Responding to Governmental Officials and Regulatory Agencies
- Abuse of Controlled Substances
- Drug and Device Misuse
- Theft or Embezzlement
To whom should I direct questions and/or report my concerns?
If you become aware of conduct that you believe to be reportable under the Corporate Compliance Program, or if you simply have questions regarding past, present or future conduct, several resources are available to assist you. Ideally, you should discuss your concerns with your supervisor first. If, for whatever reason, you do not feel comfortable talking to your supervisor, you can raise the issue directly with a higher authority within your department or unit or contact UK HealthCare's Compliance Officer, either directly or through the Comply-Line.
It always is better to raise a question before behaving in a manner that may be improper, but it is never too late. So if you are in doubt about an issue or have a concern, just ask. You never will be penalized for raising an issue or voicing a concern when you do so in good faith. Remember it is your right to raise questions and your duty to report suspected misconduct. Likewise it is UK HealthCare's duty to react appropriately to your questions and concerns.
The Corporate Compliance Officer may be reached directly at 859-323-8002 or by e-mail. If you prefer, you may call UK HealthCare's toll-free Comply-Line at 877-898-6072. Any compliance issue may be reported anonymously. The issues you raise will be addressed promptly and professionally.
Additionally, you can make a report online by clicking here.
What is the comply-line?
The Comply-Line is a toll-free phone number that is staffed 24 hours a day, seven days a week, every day of the year by an independent contractor. The contractor is professionally trained to take your calls about possible misconduct, or to arrange for you to receive answers to any questions you may have about compliance issues. You may call UK HealthCare's toll-free Comply-Line at 877-898-6072 . Any compliance issue may be reported anonymously. The issues you raise will be addressed promptly and professionally.
What happens when someone calls the comply-line?
- The call is received by the contractor on a dedicated line reserved for UK HealthCare
- The individual answering the line will make handwritten notes as you describe your concern. He/she will ask additional questions to ensure your concerns are reflected with as much detail as possible
- You will be instructed on how and when to call back so you can check on the status of your concern, if you choose to do so
- Promptly after the call, the contractor generates a report and forwards a copy to UK HealthCare's Compliance Officer for follow-up
Do I have to give my name when I call?
No. You will be asked to identify yourself, however if you feel uncomfortable providing your name, you always are permitted to remain anonymous.
When deciding whether to give your name, please remember three things:
- Anonymous reports normally are much more difficult to investigate, so failing to identify yourself could hamper UK HealthCare's ability to investigate your concern fully
- No action will be taken against you for reporting possible misconduct, as long as the report is made in good faith. This is true regardless of whether your report indeed turns out to be correct
- Even when you do identify yourself, your identity will be protected up to the limits of the law and to the extent reasonably possible
Are calls to the comply-line ever recorded or traced?
No. Call tracking, tracing or recording devices or similar methods are never used.
What if someone makes a false report about me?
Under UK HealthCare's Compliance Program, all reports are investigated fully. Therefore, it is possible that you could be questioned about conduct which either never occurred or which did occur but was completely appropriate. However, be assured that the process is impartial and that no disciplinary action of any kind will be taken until there is credible evidence the allegation is true.
Any disciplinary action taken will be in accordance with existing University policies and procedures. Remember that any employee who knowingly and with malice makes a false allegation or deliberately abuses compliance-related procedures will be subject to disciplinary action, which may include termination.