Federal Sentencing Guidelines

Transcription

1 Federal Sentencing Guidelines Presented by: Paulette Wunsch, VP and Chief Integrity and Compliance Officer In the pursuit of health 1

2 Overview Our Company Mission, Vision and Values Innovation Overview of Compliance Program Objectives Purpose Compass Organization Culture Alignment with the U.S. Federal Sentencing Guidelines Seven Elements Some of Florida Blue s Best Practices 2 In the pursuit of health 2

3 Our Company Headquarter 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 members, which represents a 30 percent share of the overall Florida health insurance market Commercial membership retention rate of 91.6 percent for year-end 2011 Ratings Standard & Poor s (A+) A.M. Best (A) Moody s (A2) 3 In the pursuit of health 3

4 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 4 In the pursuit of health 4

5 Our Company: Innovation Retail model to market, sell and service our customers Nearly 56,000 Floridians visited our store locations 5 In the pursuit of health 5

6 Overview of Compliance Program: Objectives Promoting Preventing and Detecting Enforcing Promoting an organizational culture of compliance Preventing and detecting non-compliance, illegal and/or unethical behavior Enforcing compliance with legal requirements and ethical rules 6 In the pursuit of health 6

7 Overview of Compliance Program: Purpose We will have a corporate culture of the highest integrity and ethical business conduct demonstrating our deep commitment to compliance with all laws and regulations applicable to Florida Blue and its subsidiaries. Strengthening compliance as a core competency will provide Florida Blue with a competitive advantage in the market place. 7 In the pursuit of health 7

8 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 8 In the pursuit of health 8

9 Overview of Compliance Program: Organization Board Audit and Compliance Committee Chief Integrity & Compliance Officer General Counsel Director Director Ethics and Integrity Section Director/ Privacy Officer Government Programs and Products Section Commercial Programs and Products Section Privacy Section Compliance Requirements Analysis 9 In the pursuit of health 9

10 Employee Commitment to Compliance: Culture Every employee at Florida Blue has a mandatory goal on their evaluation form called Commitment to Compliance Employee demonstrates knowledge of and compliance with current regulations, laws and the Compass Program requirements Has a high standard of personal ethical conduct and appropriately addresses observed questionable behavior/conduct and is receptive to communications about mistakes and process failures that need to be remedied Each employee champions compliance in their own work by engaging compliance and ensuring that their processes are looked at from the stand point of compliance, risk and the needs of the customer 10 In the pursuit of health 10

11 Alignment with Seven Elements Seven Elements of Effective Compliance U.S. Sentencing Commission Promotion Prevention & Detection Enforcement Defined Policies, Procedures & Controls Centralized Standards Board Oversight High Level Officer with Independent Oversight Organizational Structure Effective Lines of Communication Communication Plans Accessible Reporting Capabilities Open Access Audit and Reporting Standardized Auditing & Reporting Monitor Investigate and Track Trend Analysis Ensure Uniform Enforcement Disciplinary Actions Company and HR Policies Compass Booklet Compliance Officer Report to Audit and Compliance Committee Training, Education and Employee Engagement 24 Hour Helpline/Web (anonymous reporting capability) Open Door Policy Master Audit Plan Real Time Oversight Oversight and Analysis Forensic Tools Reward Compliance Penalize non-compliance Coaching Corrective action Termination CULTURE OF COMPLIANCE *A Compliance Program s objective is to prevent, detect and correct non-compliance with the laws and regulations as well as fraud, waste and abuse. 11 In the pursuit of health 11

12 Alignment with Seven Elements: Florida Blue Components The compliance program contains the essential components required for an effective compliance program under the Federal Sentencing Guidelines. Component Florida Blue Compass Program Established Corporate Compliance Standards Core values include honesty, integrity, courage and fairness in all business dealings. Courage to speak up when mistakes occur or unethical behavior is observed. Florida Blue Compass Code of Ethical Business Conduct can easily be located on both our internal and external websites. Enterprise Policies and Procedures: Protection of Company Assets and Information, Business Relationships and Transactions, Work Environment and Employee Relations Organizational Structure Independent Compliance Officer with direct reporting and open unrestricted access to Audit and Compliance Committee of the Board (executive session) Compliance officer with open unrestricted access to CEO and senior leadership part of senior leadership and at the table Effective governance committees Communication of Compliance Philosophy and Education and Training Tone at the top Computer-based training Reinforcement through continuous, varied and engaging messaging In-person sessions with Compliance Officer and compliance department staff External communication around philosophy 12 In the pursuit of health 12

13 Alignment with Seven Elements: Florida Blue Components Component Florida Blue Compass Program Reporting of Wrongdoing 24 hour Compass Helpline (capabilities: anonymous reporting, ability to pose questions back and to access website remotely.) Fraud hotline readily identifiable on the company s Internet website along with an online reporting option Compliance Officer with open door policy Self-reporting and disclosure to regulatory authorities Audit and Reporting Master audit plan Targeted audits Peer audits and self assessment of the compliance program Pre-payment and post-payment review and audits to detect fraud, waste and abuse Monitor, Investigate and Track Repeatable processes to monitor adherence to requirements, understand issues and analyze trends Use of software tools and system for more real time monitoring of key compliance metrics Forensic tools to monitor data being transmitted inside and outside the company Data analysis to prevent, detect and correct fraud, waste and abuse Appropriate Incentives and Uniform Enforcement Reward: commitment to compliance as an employee goal Recognition: openly recognizes good ethical behavior by spotlighting Compliance Champions Discipline: coaching, corrective action process, fair administration of program 13 In the pursuit of health 13

14 Some of Florida Blue s Best Practices Use technology to: Enhance personal outreach by company officers Strengthen employee engagement in the Compass Program Interactive code of conduct Compliance Week Automate training and tracking systems Ensure continuous improvement and learning Program recognition: Using Technology to Improve Compliance Program Performance, 2011 The Compass Program and Code of Ethical Business Conduct, 2012 Compass Program Training and Communication, In the pursuit of health 14

15 Some of Florida Blue s Best Practices: Personal Outreach from the Top Video message from the CEO to kick-off the Code of Conduct training 15 In the pursuit of health 15

16 Some of Florida Blue s Best Practices: Personal Outreach from the Top Compliance Officer monthly memo to all employees 16 In the pursuit of health 16

17 Some of Florida Blue s Best Practices: Use of Technology to Engage Employees Added humor to convey compliance messages through comedic video vignettes 17 In the pursuit of health 17

18 Some of Florida Blue s Best Practices: Use of Technology to Engage Employees Ethics-related cartoon strip along with article published in the company s online newsletter. 18 In the pursuit of health 18

19 Some of Florida Blue s Best Practices: Use of Technology to Engage Employees Daily online newsletter 19 In the pursuit of health 19

20 Some of Florida Blue s Best Practices: Use of Technology to Engage Employees TV slides rotated on the Intranet home page and closed circuit television 20 In the pursuit of health 20

21 Some of Florida Blue s Best Practices: Interactive Code Web-based, interactive version available internally to employees on the company s Intranet 21 In the pursuit of health 21

22 Some of Florida Blue s Best Practices: Interactive Code Direct linkage to company policies, procedures and other compliance resources 22 In the pursuit of health 22

23 Some of Florida Blue s Best Practices: Compliance Week Compliance Blues 23 In the pursuit of health 23