Internal Investigation of Improper Conduct Presented by: Tammy Holton, Compliance Specialist
Blue Cross and Blue Shield of Florida
Our Company •
Headquarters in Jacksonville, Florida
•
2012: Changed from Blue Cross Blue Shield of Florida to “Florida Blue”
•
One of Florida’s largest employers with approximately 6,500 of its nearly 7,500 employees located in the state (balance are in Pennsylvania and Texas)
•
Serve more than 4 million health care members, which represents a 30 percent share of the overall Florida health insurance market
Blue Cross and Blue Shield of Florida
Confidential and Proprietary
Florida Blue is an Independent Licensee of the Blue Cross and Blue Shield Association.
2
Our Company: Mission, Vision and Values Our Mission
To help people and communities achieve better health Our Vision
A leading innovator enabling healthy communities Our Values
Blue Cross and Blue Shield of Florida
Confidential and Proprietary
Florida Blue is an Independent Licensee of the Blue Cross and Blue Shield Association.
3
Overview of Compliance Program: Compass • Compass Program – Compliance – Ethics – Values • Code of Ethical Business Conduct – Supportive component of the Compass Program – Outlines company expectations – Highlights requirements for behavior in the workplace – Offers legal and ethical insight – Supports company policies and procedures – Provides instructions on how to report violations
Blue Cross and Blue Shield of Florida
Confidential and Proprietary
Florida Blue is an Independent Licensee of the Blue Cross and Blue Shield Association.
4
Approach
Proac&ve Means
Self-‐repor&ng capabili&es
Probing Research
Inves&ga&on Components
Blue Cross and Blue Shield of Florida
Confidential and Proprietary
Florida Blue is an Independent Licensee of the Blue Cross and Blue Shield Association.
5
Approach: Proactive Means
Communicate and Educate
Monitoring
Policies and Procedures
Scan for Risk
Code of Conduct Block Data
Ar&cles Compliance Officer Memos
Highlight trends or issues
Website Inform and Educate
Posters
Blue Cross and Blue Shield of Florida
Confidential and Proprietary
Florida Blue is an Independent Licensee of the Blue Cross and Blue Shield Association.
6
Approach: Self-Reporting Capabilities
Intake Helpline Electronic Mailbox Secure Website In Person
Blue Cross and Blue Shield of Florida
Confidential and Proprietary
Florida Blue is an Independent Licensee of the Blue Cross and Blue Shield Association.
7
Approach: Probing Research
Inves&gate Inquire Proac&ve Monitoring Documenta&on Repor&ng Highlight Trends or Issues Inform and Educate
Blue Cross and Blue Shield of Florida
Confidential and Proprietary
Florida Blue is an Independent Licensee of the Blue Cross and Blue Shield Association.
8
Proactive Communication: Example of a news ar&cle posted online, via the company’s Intranet, in response to compliance trends iden&fied through repor&ng and inves&ga&on:
Blue Cross and Blue Shield of Florida
Confidential and Proprietary
Florida Blue is an Independent Licensee of the Blue Cross and Blue Shield Association.
9
Proactive Communication: Example of a compliance officer message sent to all employees, via email, in response to compliance trends iden&fied through repor&ng and inves&ga&on:
Blue Cross and Blue Shield of Florida
Confidential and Proprietary
Florida Blue is an Independent Licensee of the Blue Cross and Blue Shield Association.
10
Self-Reporting Web-‐based portal that allows employees to report compliance and ethics issues anonymously:
Blue Cross and Blue Shield of Florida
Confidential and Proprietary
Florida Blue is an Independent Licensee of the Blue Cross and Blue Shield Association.
11
Monitoring Tools: Examples of repor&ng and monitoring data available using several different forensic tools and methods:
Blue Cross and Blue Shield of Florida
Confidential and Proprietary
Florida Blue is an Independent Licensee of the Blue Cross and Blue Shield Association.
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Thank you !
Blue Cross and Blue Shield of Florida