Corporate Compliance Program
Policy Manual Section
Board of Directors
Policy 1100: Conflict of InterestPolicy 1603: BOD/Staff Compliance InvestigationPolicy 1604: Confidentiality & Release of PHIPolicy 1700: Rights & ResponsibilitiesPolicy 1800: Confidential, Proprietary & Personnel Information
Original Policy Date
05/26/2005; 04/26/2007; 08/27/2009; 05/27/10; 08/25/2011
Review Date(s)(No revisions)
Replaces Policy Number
Note: While no prior official “policy” exists, the HealthPlus Board of Directors approved an M+C Compliance Program in December 1999.
I. Policy Purpose/Statement of Intent/Background
II. Policy Statement
A. HealthPlus staff shall follow all rules and regulations and will implement, by way of staff procedures, rules, and guidelines, a Corporate Compliance Program that minimally contains the following elements:
B. HealthPlus staff through administrative procedures, rules, and guidelines will establish rules of conduct for all employees. These rules will, at a minimum:
1. Be communicated to employees.2. Require adherence to the HealthPlus Distinguishing & Fundamental Values.3. Require that employees:a. comply with applicable laws and regulations, and report all known and suspected instances of illegal and unethical activity through a designated process;b. maintain the confidentiality of the information they receive; andc. avoid conflicts of interest.C. The HealthPlus Compliance Official in consultation with the Senior Director of Administrative Services , shall report to the CEO, Board Chair, and Governance Committee Chair any compliance issue that is a substantial financial or regulatory risk to the business operations of HealthPlus of Michigan or its subsidiaries.
HealthPlus staff is responsible for establishing, publishing, and maintaining procedures and work rules to implement this policy.
Approved by the Board of Directors
 2010 Federal Sentencing Guidelines http://ftp.ussc.gov/2010guid/8b2_1.htm
Effective Compliance & Ethics Program (effective 11/1/2010)