Corporate Compliance Program
Wheaton Franciscan Healthcare’s Corporate Compliance Program helps our organization, its associates and contractors abide by all applicable laws, regulations and policies. The program is consistent with Wheaton’s Mission, Vision and Values. Our goal is to do business with individuals who abide by similar principles.
We value the vital contribution our vendor representatives make to the quality care we provide. We ask that you become familiar with a few of our most relevant compliance principles to better enable you, your company and our organization to conduct business in a mutually satisfactory manner.
If you have any questions about our compliance program, please contact Sarah Kleaveland Kupczak, Vice President Corporate Compliance, at 414-465-3508.
Our Value of Integrity
Wheaton is committed to the highest ethical and legal business practices and complies with the laws and regulations that pertain to our operations. We also are committed to quality care as we continue the healing ministry of Jesus in our organization. We reflect ethical business practices in all we do, and we expect our vendor representatives to share in this commitment throughout their relationship with us.
We hope that if you would like to acknowledge the mission of our organization that you contact our foundations to learn how you may help.
Wheaton requires all associates, including physicians, to remain free from any actual or potential conflicts of interests, including even the appearance of a conflict. Gifts given to associates may create a potential conflict of interest.
In an effort to help our associates remain free from conflicts, we request that our vendor representatives refrain from making any offerings to our associates that might violate (or be perceived as violating) the following policies.
Our associates may not:
- Solicit gifts from vendor representatives other than for our foundations
- Accept a gift during the course of negotiations
- Accept cash or cash equivalents (such as gift certificates)
Our associates may:
- Accept a nominal, non-cash gift to a department or group as long as such items are not lavish (no more than $50 per person per year) and does not happen during negotiations
- Accept a meal during a business meeting as long as it is no more than $100 in value
- Attend one social event a year as long as the value is less than $300 ($600 including one guest)
Stipends and other cash awards received for presentations or consulting efforts developed or presented by a Wheaton associate during normal working hours in their role as a Wheaton associate must be endorsed over or paid directly to our organization.
Expectations of Vendor Representatives
When working in conjunction with our organization, vendor representatives are expected to:
- Operate in compliance with all applicable legal requirements and Wheaton’s vendor certification process.
- Never pursue any business opportunity or relationships that would compromise our ethical standards or violate a law, regulation or corporate policy
- Respect the rights and dignity of our employees and patients
- Protect the physical and intellectual property of Wheaton and any organizational assets against loss, theft, destruction, misappropriation, and misuse
- Not use for personal gain any information obtained as a vendor representative, including confidential or proprietary information
- Not offer or accept any bribes, kickbacks or inducements in connection with performing duties for any of our organizations
- Maintain the confidentially of patient information
- Report a suspected violation of any law, regulation or policy.
For Vendors Who Are Our HIPAA Business Associates
Please be aware that CMS has issued a final rule modifying the HIPAA Privacy and Security rules as required by the Health Information Technology for Economic and Clinical Health Act (HITECH). Under the HIPAA rules, as modified, business associate will now be directly liable under HIPAA for compliance with the HIPAA security rule and certain provisions of the HIPAA privacy rule such as:
- Failure to meet the minimum necessary standard
- Inappropriate use or disclosure of protected health information
These requirements will now flow to our business associate’s subcontractors. We encourage all of our vendors who are business associates to become familiar with the modified HIPAA rules and reach out to your compliance professional and/or your legal counsel with questions that you may have.
As a result of these changes, we will need to modify our business associate agreements in the next year.
Reporting Suspected Violations
The corporate compliance program fosters an environment in which employees and affiliates, including vendor representatives are encouraged to report concerns about business practices. A toll-free Compliance Line is available as a reporting mechanism whereby employees, medical staff, vendor representatives, and others associated with Wheaton can report, without fear or retaliation, suspected violations or issues of non-compliance. Callers may remain anonymous, if they so desire.
To report a violation, please call the Compliance Line at 1-800-707-2198.