Greater Oregon Behavioral Health Initiative Corporate Integrity Officer Tim Timmons recently discussed with Commissioners an ethics and compliance program underway with Lake County Mental Health.
The program, which Timmons noted is a mandate of the Affordable Health Care Act, calls for a court-integrated compliance program after sentences are handed down following a criminal event.
The essence of the program, Timmons said, is to identify and prevent misconduct, illegal and unethical activity from happening in an organization.
The roots of the program date back to 2004, in light of multiple scandals underway nationwide, Timmons said, prompting the need to ensure greater compliance of ethical practices within organizations.
“The foundation for the whole program is ethical conduct,” he said,
The program is built around a common standard for conduct, with a code developed from nonprofits and ensuring that Lake County Mental Health’s policy is on part and complementary to that of the County.
This code can be carried over to other County departments, such as public health, Timmons said.
An individual from the organization would be accountable to the County for ensuring proper protocol is performed as per the guidelines, serving as a compliance officer.
This program also verifies non-exclusion of payment by Medicare or Medicaid by conferring with a federal contractor list that names those ineligible due to a previous crime, which could be as innocuous as defaulting on a student loan.
Timmons noted accepting payment for such ineligible clients or paying a salary to an employee on this exclusion list puts the County at risk.
Other elements include a training program to ensure proper job training and data recording, implementation of a monitoring and auditing program; again, designed with accountability in mind.
A formal effectiveness review is a component that assures policy and procedures are not only in place but offer proof of identified issues.
A ‘whistleblower’ hotline is in place allowing staffers not comfortable with reporting to immediate supervisors on a suspected issue through confidential means with GOBHI. On a related note, a strong non-retaliation process is also a part of the Lake County Mental Health staff policy, Timmons said.