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General
Each director or manager of an affected department
is responsible for: Implementing and maintaining compliance
standards and policies and procedures and manuals specific to their departments
providing training to all his or her employees in compliance standards, policies,
procedures, laws and regulations applicable to employees of the department;
3) enforcing this Program, the Code of Ethical Conduct, medical Center policies
and procedures, and applicable laws and regulations; 4) investigating reports
or reasonable indications of violations of this Program, the Code of Ethical
Conduct, Medical Center policies or procedures; 5) reporting to the Compliance
Officer any reports or reasonable indication of violations of applicable
law or regulation by any member of the department; 6) initiating and/or implementing
corrective or disciplinary action in the event of violation of the Compliance
Program, the Code of Ethical Conduct, Medical Center policies, procedures
and applicable laws and regulations; and 7) taking all measures reasonably necessary
to ensure compliance with this Program and applicable laws and regulations.
Department Compliance Manuals
Contents
The compliance standards for each
affected department shall contain a statement of
compliance policy for that department and shall define and assign responsibility
for updating the compliance standards, the department
compliance manual, training and education, record keeping and the completion
of audit work plans requested by the Compliance Officer.
The department compliance manuals may contain such other matters
as the director or manager deems necessary or appropriate
so long as it does not conflict with this Program.
Resource.
The department compliance manuals
shall be a resource for the employees of each
affected department to enhance the ability of employees to perform their
jobs in compliance with this Program and applicable laws and regulations.
Employees should be encouraged to periodically
review their departmental compliance manuals and to discuss any compliance
issue with their supervisor or director or manager.
Directors and managers are encouraged to involve their employees in the
preparation of such department manuals.
Approval
Department compliance manuals
must be approved by the Compliance Officer. The
Compliance Officer may assist in the preparation and maintenance
of any such manual upon request.
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