Confidential Disclosure Program Sample Clauses
The Confidential Disclosure Program clause establishes a formal process for handling and protecting sensitive information shared between parties. Typically, it outlines the procedures for designating information as confidential, the obligations of recipients to safeguard such information, and the circumstances under which disclosures are permitted, such as to employees or affiliates with a need to know. This clause is essential for ensuring that proprietary or sensitive business information is not improperly disclosed or misused, thereby protecting the interests and competitive advantage of the disclosing party.
Confidential Disclosure Program. Sun has established a Confidential Disclosure Program, which includes two toll-free telephone lines, known as the "Sun Quality Line" and "Customer First Line" (collectively the "Confidential Disclosure Program"). The Sun Quality Line has been designed and implemented for employees, contractors, and vendors, while the Customer First Line has been designed for patients and families. Within 90 days of the Effective Date of this CIA, Sun shall review its Confidential Disclosure Program and ensure that it is in compliance with the requirements of this Section. The Confidential Disclosure Program shall enable any individual to disclose, to the Compliance Officer or some other person who is not in the disclosing individual's chain of command, any identified issues or questions associated with Sun's policies, practices, or procedures with respect to quality of care or a Federal health care program, believed by the individual to be inappropriate. Sun shall publicize the existence of the Confidential Disclosure Program, and, at a minimum shall post notice of it prominently in common gathering areas (e.g., lobbies, dining rooms, activity rooms, waiting rooms, employee break rooms and other locations where notices are typically posted) in each of its facilities and locations and shall publicize it in training and newsletters to employees. The Confidential Disclosure Program shall emphasize a non-retribution, non-retaliation policy, and shall include a reporting mechanism for anonymous, confidential communication. Upon receipt of a disclosure, the Compliance Officer, or his/her designee, shall gather the information in such a way as to elicit all relevant information from the disclosing individual. The Compliance Officer, or his/her designee, shall make an inquiry into the allegations set forth in every disclosure to ensure that he or she has obtained all of the information necessary to determine whether further review should be conducted. For any disclosure that is sufficiently specific so that the Compliance Officer, or his/her designee, determines further review is warranted, the Compliance Officer, or his/her designee, shall conduct such further review of the allegations and ensure that follow-up is conducted and that any inappropriate or improper practice is addressed. The Compliance Officer shall maintain a written record, which shall include the date of receipt of the allegation or complaint, a summary of each allegation or complaint received, the status of the ...
Confidential Disclosure Program. HCA has established a Confidential Disclosure Program. HCA provides a toll free "Ethics Line" to enable employees, contractors, agents or other individuals to disclose, to the EC Department or some other person who is not in the disclosing individual's chain of command, any identified issues or questions associated with HCA's Policies and Procedures, practices, or operations with respect to any Federal health care program, believed by the individual to be inappropriate. HCA shall continue to publicize the existence of the Ethics Line to all covered persons. HCA has established a Policy governing its handling of disclosures made through the Ethics Line. HCA shall continue to operate the Ethics Line through such Policy. HCA shall continue to forbid retribution or retaliation for disclosures and allow for anonymous, confidential disclosures. The EC Department shall maintain a confidential disclosure log, which shall include a record and summary of each allegation received, the status of the respective investigations, and any corrective action taken in response to the investigation.
Confidential Disclosure Program. Medaphis will continue its Confidential Disclosure Program, which consists of a toll-free compliance "hotline" (1-888-COMPLYH), enabling employees, agents and contractors, if applicable, to disclose, to the Compliance Officer or another appropriate person who is not in the reporting individual's chain of command, any identified issues or questions associated with the policies, practices, or procedures with respect to Medicare, Medicaid, or any other Federal health care program, alleged by the individual to be inappropriate. The Confidential Disclosure Program shall emphasize a non-retribution, non-retaliation policy, and shall include a reporting mechanism for anonymous, confidential communication. Upon receipt of a complaint, the compliance officer or other responsible person shall gather the information in such a way as to elicit all relevant information from individuals reporting alleged misconduct. The Compliance Officer or designee shall make a preliminary good faith inquiry into the allegations set forth in every disclosure to ensure that he or she has obtained all of the information necessary to determine whether a further review should be conducted. For any disclosure that is sufficiently specific that it reasonably permits a determination of the appropriateness of the alleged improper practice, and provides opportunity for the taking of corrective action, the Compliance
Confidential Disclosure Program. Within one-hundred twenty (120) days after the effective date of this CIA, MIM shall implement (to the extent it has not already done so) the Confidential Disclosure Program described at Chapters 3 and 4 of its Compliance Manual, which program must include measures (E.G., a toll-free compliance telephone line) to enable Covered Persons or other individuals to disclose to the Compliance Officer or some other person who is not in the reporting individual's chain of command, any identified issues or questions associated with MIM's policies, practices or procedures with respect to the Federal health care program, believed by the individual to be inappropriate. As provided in MIM's Compliance Manual, all Covered Persons working for MIM are required to report suspected legal or compliance violations. In addition to describing the hotline in the MIM Compliance Manual, MIM shall publicize the existence of the hotline (E.G., in e-mails to employees and by posting the hotline number in prominent common areas).
(1) permits a determination of the appropriateness of the alleged improper practice, and (2) provides an opportunity for taking corrective action, MIM shall conduct an internal review of the allegations set forth in such a disclosure and ensure that proper follow-up is conducted. The Compliance Officer shall maintain a confidential disclosure log, which shall include a record and summary of each allegation received, the status of the respective investigations, and any corrective action taken in response to the investigation.
Confidential Disclosure Program. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day Beve▇▇▇ ▇▇▇ls meet any of the deadlines to submit the Implementation Report or the Annual Reports to the OIG.
3. A Stipulated Penalty of $2,000 (which shall begin to accrue on the date the failure to comply began) for each day Beve▇▇▇:
Confidential Disclosure Program. The State and local school districts shall establish a confidential disclosure mechanism enabling employees to disclose anonymously any practices or billing procedures, deemed by the employee to be inappropriate, to the State's Compliance Officer. The State shall make the confidential disclosure mechanism known to each employee as part of his or her training. The State and local school district shall, as part of the confidential disclosure program, require the internal review of any such credible disclosure and ensure that proper follow-up is conducted. The State shall include in its annual compliance report to CMS a summary of communications concerning inappropriate ▇▇▇▇▇▇▇▇ or any other inappropriate conduct under the confidential disclosure program, and the results of any internal review and follow-up of such disclosures.
Confidential Disclosure Program. For the duration of this CIA, -------------------------------- Fresenius shall maintain its "Compliance Action Line" or similar hotline however denominated (hereinafter referred to as the "Confidential Disclosure Program"). The Confidential Disclosure Program must include measures (e.g., a toll-free ---- compliance telephone line) to enable Covered Persons and other individuals to disclose, to the Compliance Officer or some other person who is not in the disclosing individual's chain of command, any identified issues or questions associated with Fresenius's policies, practices or procedures with respect to a Federal health care program, believed by the individual to be inappropriate (hereinafter "compliance disclosure"). Fresenius shall publicize the existence of the Confidential Disclosure Program to Covered Persons.
(1) permits a determination of the appropriateness of the alleged improper practice, and (2) provides an opportunity for taking corrective action, Fresenius shall conduct an internal review of the allegations set forth in such a compliance disclosure and ensure that proper follow-up is conducted. The Compliance Officer shall maintain a confidential compliance disclosure log, which shall include a record and summary of each allegation received, the status of the respective investigations, and any corrective action taken in response to the investigation.
Confidential Disclosure Program. LifePoint, pursuant to its Compliance Program, has established a confidential disclosure program which includes its Compliance Hotline, a toll-free telephone line, as a means to enable individuals to report instances of noncompliance and/or make inquiries on compliance issues. LifePoint shall continue to maintain a confidential disclosure program, including a mechanism such as the Compliance Hotline, which shall be available to all individuals for the purpose of reporting or inquiring on matters of compliance with the Compliance Program, this CIA, and Federal health care program requirements.
(1) permits a determination of the appropriateness of the alleged improper practice; and (2) provides an opportunity for taking corrective action, LifePoint shall continue to conduct an internal review of the allegations set forth in such a disclosure and ensure that proper follow-up is conducted.
Confidential Disclosure Program
