December 1999
We asked the following questions related to clinical ethics
What committees does your organization have?
100% - Bioethics/Clinical Ethics Committee
88% - Institutional Review Board (IRB)
88% - Corporate Compliance Committee
How often does the Bioethics/Clinical Ethics Committee meet?
50% - 4 to 6 Times per Year
50% - 7 to 12 Times per Year
0% - As Necessary
0% - 3 Times per Year or Less
0% - More Than 12 Times per Year
How often does the Institutional Review Board (IRB) meet?
50% - 4 to 6 Times per Year
25% - As Necessary
25% - 7 to 12 Times per Year
0% - 3 Times per Year or Less
0% - More Than 12 Times per Year
How often does the Corporate Compliance Committee meet?
44.5% - 4 to 6 Times per Year
44.5% - 7 to 12 Times per Year
11.0% - 3 Times per Year or Less
0% - As Necessary
0% - More Than 12 Times per Year
Indicate the percentage of Bioethics (Clinical Ethics) Committee members who fall into the following categories:
33.6% - Physician
19.1% - Nursing
10.5% - Clergy/Pastoral Care
6.6% - Senior Executive
6.0% - Social Work
6.0% - Attorney
6.0% - Supervisor/Manager
4.6% - Community at Large
4.6%- Other
2.0% - Board Member
1.0% - Finance
What percentage - if any - of the Bioethics Committee members also serve as members of the Corporate Compliance Committee?
0% - 90 to 100%
0% - 80 to 89%
0% - 70 to 79%
0% - 60 to 69%
0% - 50 to 59%
0% - 40 to 49%
14.3% - 30 to 39%
28.6% - 20 to 29%
28.6% - 10 to 19%
28.6% - 0 to 9%
How many case consultations, if any, has the Bioethics (Clinical Ethics) Committee conducted in the last 2 years?
0% - 0
0% - 1 to 2
0% - 3 to 5
20% - 6 to 9
20% - 10 t0 15
20% - 16 to 20
40% - More than 20
Is your Bioethics (Clinical Ethics) Committee directly involved in any aspect of your Compliance (Integrity) program?
YES / NO
Training: 12.5% / 87.5%
Reporting Process: 0% / 100%
Audit: 0% / 100%
Code of Conduct: 12.5% / 87.5%
Review/Develop Policies: 25.0% / 75.0%
To whom does your Bioethics (Clinical Ethics) Committee report?
71.4% - Medical Staff/Medical Executive Committee
14.3% - Governing Body
14.3% - Senior Management
0% - Compliance Office
0% - Reports/Minutes not Generated
What percentage of your Bioethics (Clinical Ethics) Committee's time is devoted to the following?
43.0% - Case review/consultation
21.4% - Policy development/review
17.9% - Education
12.7% - Other
3% - Compliance issues
2% - Review of IRB protocols

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October 1999
We asked questions related to the Compliance Officer position including the structure, reporting lines, staff and pay for the position.
22.7% - Corporate Compliance Officer
22.7% - Director of Corporate Compliance
18.2% - Compliance Officer
4.5% - Corporate Ethics and Compliance Officer
4.5% - Corporate Integrity Officer
4.5% - Ethics Officer
4.5% - Integrity-Compliance Officer
4.5% - Officer of Compliance and Ethics
4.5% - Regional Compliance Officer
4.5% - System Integrity Officer
4.5% - Vice President, Corporate Compliance
What is your compliance-related title?
Do you have any other job responsibilities besides Compliance Officer? 14% - Internal Audit and Corporate Compliance
9% - Director of Risk Management
9% - Tax Management Department
9% - New Business Development
9% - CFO
50% - No
Do you work in a hospital/healthcare facility, a healthcare system, an MCO, a supplier to healthcare providers such as a pharmaceutical or DME? 4.5% - Healthcare System
31.8% - Hospital
4.5% - Long Term Care Management Co.
4.5% - Medicare Contractor
4.5% - Pharmaceutical Company
How many beds does your hospital/healthcare facility have? Average: 409 beds

400 SNFs, DME, Portable Radiology;

1 Hospices Hospital, Home Health, Physician Practices, Childcare Center for Associates, Retirement Home, Skilled Nursing Facility, Satellite Psychiatric Facilities, DME, Postsecondary R.N. School

6 Acute Care Hospitals, Psychiatric Hospital and Community Mental Health Center, 2 Ambulance Companies, Nursing Home, Comprehensive Rehabilitation Center, Cancer Treatment Center and Treatment Network, Outpatient Diagnostic and Treatment Network, Insurance Company, Physician Practice Management Company, Home Health Company, 6 Joint Venture Companies

13 Hospitals, HMO

3 Hospitals, O/P Rehab Facility, Ambulatory Surgery Center, Home Health Care Agency, Physician Practices

35 Hospital and Long Term Care Facilities

Hospital, Rehab Hospital Unit, Home Care, Hospice, Home Infusion, Nursing Home, Ambulance Services, DME, 9 Retail Pharmacies, Ambulatory Surgery and Recovery Center, Retirement Center

2 Hospitals, Home Health, SNF, Nursing Home, Outreach Lab, Rural Health Center, 4 Hospital-Owned Physician Practices, CORF

8 Hospitals, Home Health, Hospice, Ambulatory Center

150+ SNFs and ALFs

Home Health, Personal Care Home, Hospice, Nursing Home

How many hospitals or other facilities/locations are in your healthcare system, and what type of facilities/locations?

27.3% - Compliance Office
22.7% - Corporate Compliance Department
9.5% - Internal Audit Department
4.5% - Compliance & Risk Management
4.5% - Compliance Department
4.5% - Corporate Compliance Office
4.5% - Corporate Ethics and Compliance Program
4.5% - Ethics and Compliance Office
4.5% - Ethics Office
4.5% - Integrity-Compliance Office
4.5% - Internal Audit and Corporate Integrity
4.5% - Risk Management
What is the name of your department?
Is your department part of another department? 13.6% - Legal Department
9.3% - Administration Department
4.5% - Finance Department
4.5% - Operations Review Department
4.5% - President's Office
63.6% - No
Do you have a corporate/main office where the compliance/ethics office is located? 54.5% - Yes
27.3% - No
18.2% - No, located within the hospital
How many years have you held this compliance-related position? Average: 2 years
How many people are on your staff (i.e., work for you in the compliance function?) Average: 2.2 people
18.2% - President/CEO
13.6% - CEO
13.6% - General Counsel
13.6% - President, CEO and Board of Directors
9.5% - CEO, Board, and CFO
4.5% - CEO and Board of Directors
4.5% - CEO and Finance Committee
4.5% - Chief Compliance Officer of Parent Company
4.5% - CFO,COO and Board of Trustees
4.5% - COO and Audit
4.5% - President, CEO and Board of Trustees
4.5% - Senior Vice President/COO
To whom do you report?
To whom does your supervisor report? 50.0% - Board of Directors
27.8% - CEO
11.1% - Board of Trustees
11.1% - President, CEO
35.0% - $81,000 to $95,000
25.0% - $66,000 to $80,000
20.0% - Over $110,000
10.0% - $51,000 to $65,000
10.0% - $96,000 to $110,000
What is your salary?

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September 1999
We asked the question: "Does your Organization have a Code of Conduct?" and gathered information related to that topic.
How long your code of conduct? Average is 24 pages
How often is your code revised? As needed ­ 41.7%
Annually ­ 25%
Just distributed, no revisions yet ­ 33.3%
In what format(s) is your code available to employees? Paper and intranet ­ 50%
Paper ­ 25%
Paper, in process of putting on intranet ­ 25%
How often is your code disseminated to employees? Annually ­ 25%
Annually at compliance training and at new hire orientation ­ 41.6%
Annually at compliance training, at new hire orientation, and each time it is revised ­ 16.7%
At initial compliance training ­ 16.7%
Are employees required to sign an acknowledgment that they have received and read the code? Yes ­ 91.7%
No ­ 8.3%
Is your code disseminated to vendors? Yes ­ 33.3%
No ­ 66.7%
Are vendors required to sign an acknowledgment that they have received and read the code? Yes ­ 71.5%
No ­ 28.5%
Does your organization test the reading level of its code? Yes ­ 16.7%
No ­ 83.3%
(30% said that it was written at 8th grade level, but not tested.)

 
Please list the major topics: Mission, Vision, Values
Background of Integrity Plan
Integrity-Compliance Office
Reporting Process
Fair Treatment of Employees
Wage
Gifts
Employee Responsibilities
Sexual Harassment
Reporting Violations
Hotline
Workplace Conduct
Suppliers and Physician Clients
Compliance & Discipline
Conflict of Interest
Antitrust Issues
Confidentiality
Use of Company Property
Clinical Laboratory
Research
Participation on Outside Boards of
Directors
Holding Public Office
Confidential and Proprietary Info
Legal Responsibilities
Records and Statements
Financial Reporting
Health, Safety & Env. Concerns
Marketing and Advertising
Relationships with Physicians and Vendors
Professional Discounts
3rd party Billers
Coding; Billing and Collections
Medicare and Medicaid
JCAHO/Other Accrediting Agencies
Quality of Care
Patient Rights
Fraud and Abuse
Safeguarding Assets and Safety
Research Ethics
Improper Use of Funds
Drugs, Alcohol and Firearms
Human Resources
Business Ethics and Integrity
Outside Investments
Copyright and License Agreements
Information Systems and Intellectual
Property
Gov't Invest


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