To follow are brief descriptions of major publications and organizations focusing on ethical behavior or corporate responsibility/compliance that have been identified by the Alliance for Advancing Nonprofit Healthcare.
PUBLICATIONS
Independent Sector Guide on Good Nonprofit Governance and Ethical Practice
Overall, the Alliance is pleased with and supportive of this Guide, issued in October 2007. It is consistent with most of the Alliance’s own guidelines on nonprofit health care governance, adopted by the Alliance Board in May 2005. The only Alliance suggestions previously submitted that were not incorporated in some manner were the following:
- The Board plans for the succession of the Board chair, other Board positions, the position of Chief Executive Officer (CEO), and other key executive positions
- The number of other public or private company boards on which a director may serve is determined by policy or case-by-case review
- While all major decisions should be determined by the Board as a whole, larger nonprofit organizations have standing committees, with charters and composed of independent directors, responsible for audit, compensation, and governance and nominations. These committees have the sole authority to select, direct, retain and terminate independent consultants
- For purposes of preserving the Board’s independence as well as ensuring clear and candid communication among directors and with the CEO, at least several times a year, on a prescheduled basis, directors meet in executive session without the presence of management
- Board and individual director evaluations should be preformed annually, recognizing that the depth of the evaluations may vary from year to year (The Independent Sector Guide calls for such evaluations at least every three years)
Corporate Responsibility and Corporate Compliance: A Resource for Health Care Boards of Directors
This 5-page document, developed and issued in 2003 by the Office of the Inspector General (OIG) of DHHS and the American Health Lawyers Association, contains questions and general discussion related to the development and operation of a corporate compliance program to prevent fraud and abuse. It is available at www.oig.hhs.gov/fraud/docs/complianceguidance/040203CorpRespRsceGuide.pdf.
Evaluating and Improving a Compliance Program: A Resource for Health Care Board Members, Health Care Executives and Compliance Officers
This 35-page document was issued in 2003 by the Health Care Compliance Association, one of the organizations described in the next section. It is available on its website, www.hcca-info.org , in the Evaluation Improvement component of the Compliance Information section.. The document provides rather extensive guidance to healthcare organizations related to the establishment, operation and evaluation of a corporate compliance program. It does not attempt to discuss all of the specific laws, regulations and standards with which healthcare organizations must comply. Rather, it presents relevant basic issues and guidance on implementation, roles of the compliance officer, management and board, and on evaluation and measurement of results in each of the following areas: policies and procedures, ongoing education and training, open lines of communication, ongoing monitoring and auditing, enforcement and discipline, and investigation, response and prevention.
ACHE Code of Ethics
This 2-page code, amended on November 10, 2003 by the Board of Governors of the American College of Healthcare Executives, is available on the College’s website, www.ache.org. Also available in this website’s Ethics section are: a “tool kit” for ethical decision-making processes; ethics policy statements; an ethics self-assessment tool; and an extensive bibliography.
Creating a Workable Company Code of Ethics
This guide, first published in 1990 by the Ethics Resource Center, described in the next section, has just been updated and incorporates information on the U.S. federal sentencing guidelines, the Sarbanes-Oxley Act of 2002, and the modified Securities and Exchange Commission guidelines. It is available for purchase on the Center’s website, www.ethics.org, under the Publications section. Also available for purchase on the Center’s website are the results of its 2003 telephone survey of American worker views on ethics in the workplace.
Annual Survey: Profile of Health Care Compliance Officers
This report is published annually by the Health Care Compliance Association (also described in the next section), and is available on HCCA’s website, www.hcca-info.org. Data on compensation, type and size of organization, work priorities, and other information concerning corporate compliance professionals are provided in this report.
Individual Organization Statements of Ethical Practices or Codes of Conduct
There are numerous examples of individual organization policies/guidelines related to various types of ethical conduct/corporate responsibility readily available on the Internet through search engines. The examples vary in depth, from very general guidance (e.g., Better Business Bureau), to fairly detailed (e.g., Nortel Networks), with many in between (e.g., Cleveland Clinic).
Journals on Ethics
The following journals have been identified: Business Ethics Magazine, Business Ethics Quarterly, Ethikos, Ethix, Journal of Business Ethics, Journal of Business Ethics and Organization Studies (Finland), Corporate Conduct Quarterly, Online Journal of Ethics, Teaching Business Ethics, Cambridge Quarterly of Healthcare Ethics, HEC Forum, Journal of Law, Medicine & Ethics, and the Kennedy Institute of Ethics Journal.
Books Related to Ethics
One website, www.meansbusiness.com, enables one to search by topic for passages or “concept extracts” from books. Searching under “Ethics”, 50 were identified.
The E-Center for Business Ethics ( www.e-businessethics.com), discussed in the next section, recommends 28 books.
ORGANIZATIONS
Council on Ethical Organizations and its Health Ethics Trust Division
The membership of this group, established in 1980, consists of only healthcare organizations, and includes some notable nonprofits (BCBS FEP, North Carolina BCBS, Michigan BCBS, Illinois BCBS, Kaiser Permanente, Adventist Healthcare, Holy Cross Health, Partners Healthcare, Summa Health System) as well as investor-owned healthcare organizations (United HealthCare, Wellpoint Health Networks, Baxter International).
It seeks to assist primarily ethics/compliance professionals, providing educational programs (e.g., best practices, train-the-trainer), a newsletter (Pastin Report) and a certification program. It also conducts survey research. See www.corporateethics.com.
The Ethics Resource Center
This is a nonprofit educational organization, established in 1977 with the broad goal of inspiring both individuals and organizations, both in the U.S. and internationally, to act ethically. Its website is www.ethics.org. The Center reports that its mission has been streamlined to focus on evaluation, research and character improvement.
It provides articles, book lists, research reports and guides, speeches, videos, links to other ethic-related websites, consulting services, educational programs and a speakers bureau. These services appear to be oriented primarily toward ethics/compliance professionals.
It also has a Fellows Program, begun in 1997, consisting of 55 select leaders with strong expertise and interests in ethics. This program has published four reports, the most recent on Employee Confidentiality and Non-Retributory Reporting Systems, and has four more underway, including reports on Value-based Leadership and Ethical Role Modeling.
Ethics Officer Association
This is a nonprofit professional association, founded in 1992 exclusively for managers of ethics and compliance programs in both investor-owned and nonprofit organizations in a wide variety of industries. Currently there are close to 900 organizations represented in its membership. See www.eoa.org. It provides educational programs for its members, articles, books, salary survey information, and a job center. It does not appear to offer a certification program for its members, and its research appears to be restricted to salary surveys.
Health Care Compliance Association
This professional association’s mission is to “champion ethical practice and compliance standards within the health care community and to provide the necessary resources for compliance professionals and others who share these principles”. It claims to serve all segments of the health care industry, although its corporate members appear to be primarily law, accounting and other consulting firms. It provides educational programs, a speaker’s bureau, a journal, a newsletter, and a certification program. It states that it does not lobby and does not focus on bio-ethical issues. See www.hcca-info.org.
E-Center for Business Ethics
This is a web-based service (www.e-businessethics.com) of the Colorado State University College of Business. It provides three case studies and links to ethics-related articles, case studies, articles, and books. It also provides a ten-week online certification program apparently aimed at ethics/compliance professionals.
American Hospital Association
The AHA offers a compliance website through www.hospitalconnect.com, offering a regulatory standards manual exclusively for its members. Other publications and information on educational programs are also offered on that site.
Annual National Congress on Health Care Compliance
The ownership of this forum is unclear. It appears to be a commercial venture begun in 1998 for primarily healthcare compliance professionals. Sponsors include several consulting firms and a wide variety of healthcare-related journals and newsletters. See www.compliancecongress.com.
Colleges and Universities
There appear to be a significant number of institutions of higher learning with research and/or educational focused specifically on ethics or corporate compliance. In addition to Colorado State University as noted above, several other schools appear to be active in this subject matter: Bentley College (MA) , University of St. Thomas (TX), Loyola Marymount (CA), Georgetown, Iowa State, and the Wharton School.
EthicsPoint
This consulting firm, whose website is www.ethicspoint.com, provides code-of-conduct training, whistleblower hotline reporting, and case management services. It has a specific program tailored to nonprofit organizations.
Midi Compliance & Ethics Learning Solutions
This e-business firm provides online interactive training for employees and managers on more than 100 ethics and human resource topics, organized into more than 25 courses. Its website is www.eyeonintegrity.com.
In addition to the foregoing, the following organizations focused on Organizational Governance have been providing or can be expected to be providing at least some educational programs and/or other tools related to ethics or corporate responsibility/compliance:
Governance Institute
This organization, established in 1986, offers educational programs, research reports, books, audio and visual tools, self assessment guides, and other resources to hospital and healthcare system governance and management leaders. See www.governanceinstitute.com.
BoardSource
Founded in 1987, this group changed its name in January 2002 from the National Center for Nonprofit Boards. It purports to have 16,000 individual members, with a staff of over 30 and a budget near $10 million. It does not appear to have any healthcare representation on its current board. It provides educational forums, and has a bookstore on its website (www.boardsource.org).
Center for Healthcare Governance
This is a joint venture of the AHA and several consultants who are educational and governance experts.
It provides educational programs, Trustee magazine,other publications, and consulting assistance. See www.americangovernance.com.
Selected State-level Organizations
Several state hospital associations, most notably in New Jersey, New York, Washington, and Arkansas, have specific centers devoted to governance research and/or education. At least one private health insurance organization, Blue Cross and Blue Shield of Florida, has established a center for ethics (in this case, based at the University of North Florida).
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