Integrity is fundamental to the VUMC Credo. VUMC is committed to doing the right thing and maintaining a comprehensive compliance program. Our program seeks to prevent and detect errors before they become significant violations of our regulatory requirements. Through appropriate oversight and training, we ensure everyone at VUMC understands their compliance obligations. You can read about VUMC's Compliance Program Plan here.
The Office of Compliance & Corporate Integrity (OCCI) is crucial to the coordination of the VUMC compliance program. Our mission is to promote practices that align with our Credo and Code of Conduct. We ensure VUMC:
- Oversees compliance risks through rigorous governance, including the Compliance & Corporate Integrity Committee (CCI).
- Develops appropriate policies to support ethical business practices.
- Educates workforce members annually and upon hire.
- Maintains confidential reporting channels for compliance concerns, including our 24/7 Integrity Line (Hotline).
- Conducts routine monitoring and exclusion screenings to continually improve our clinical documentation and confirm VUMC compliance controls are effective.
- Responds promptly when we detect errors or are audited by external agencies.
- Takes consistent corrective action when we discover compliance issues.
These principles are based on independent guidance from Health and Human Services' Office of Inspector General, or OIG. You can read more about OIG's "Seven Elements of an Effective Compliance Program" here.
- Screens all vendors and workforce members against sanction lists for exclusion from health care programs. VUMC does not employ or do business with excluded individuals.
- Administers VUMC's PolicyTech system so that policy committees can efficiently process and communicate important policies.
- Conducts annual regulatory risk assessments to identify new or changing billing or research compliance priorities.
- Imbeds our Compliance Officers in clinical and research operations to provide real-time guidance and decision support.
OCCI takes pride in our program, but VUMC's everyday compliance is up to you. It is everyone's responsibility to ensure we model our Credo and Code of Conduct each and every day. This means everyone must seek out, be aware of, and follow the policies and business requirements in your area. Everyone must speak up about potential unethical, illegal, or unsafe activities at VUMC.
We make integrity a priority in everything we do.