Your article "A compliance program" (Oct. 5, p. 116) discusses how HHS' model hospital compliance program rules out CFOs, chief counsels and other key managers as ethics and compliance officers. We were interviewed for the story and want to explain that our permitting handpicked chief financial officers to perform the role of ethics and compliance officers predated the issuance of HHS' Model Compliance Plan for Hospitals. Our corporate ethics and compliance committee discussed this at some length and concluded that the particular CFOs had been working diligently in this role. It seemed that disqualifying them from such service was not prudent management.
As corporate ethics and compliance officer, I report directly to the chief executive officer and a newly established board of directors committee; mine is a peer position to the financial and legal functions. At a corporate level we follow HHS' office of inspector general's guidance precisely.
Flowing our ethics and compliance program into each of our hospitals and other facilities is a major undertaking. We are completing a significant guidebook for our local ECOs, providing them with detailed information on how to perform each of their tasks. We also require a compliance committee in each of our hospitals. We meet with and hold workshops for these ECOs.
We are optimistic that we will have someone in each hospital who is fully trained to provide dynamic leadership in ethics and compliance. We also have placed our ethics and compliance materials on our Web site, www.columbia-hca.com/ethic.
Senior Vice President, Ethics, Compliance and Corporate Responsibility
Columbia/HCA Healthcare Corp.