Program structure
Organizational structures — including necessary committees, responsible executives and facility ethics and compliance officers — are in place to support all of our ethics and compliance efforts.
The Ethics and Compliance program's foundation rests on the support of several committees and individuals both at the corporate level and within the facilities.
Corporate ethics and compliance officer
Wendy Warren serves as Senior Vice President and Chief Ethics and Compliance Officer for HCA Healthcare.
Ethics and compliance officers (ECOs)
We have developed ECO guides which provide information, resources, as well as tips on how to effectively oversee the ethics and compliance program in a hospital or ambulatory surgery center. In addition to the guides, facility ECOs are provided with comprehensive training and ongoing education regarding their responsibilities.
Responsible executives
Responsible executives are individuals within the corporate office who have been identified as the subject matter experts in particular areas of compliance risk, and who are responsible for those areas.
Area of Compliance Risk
- Abstraction
- Americans with Disabilities Act – Access to Services
- Americans with Disabilities Act – Physical Access
- Antitrust
- Artificial Intelligence & Machine Learning
- Aviation
- Behavioral Health
- Billing
- Case Management
- Clinical Investigation and Research
- Coding
- Collections
- Cost Reports
- Credentialing and Privileging
- Electronic Health Record
- Emergency Preparedness
- EMTALA
- Environment
- ERISA
- Financial Reporting
- Global Anti-Corruption
- Global Capability Network
- Government Contracts
- Graduate Medical Education
- Home Health and Hospice
- Hospital Epidemiology and Infection Prevention
- Imaging
- Information Security
- Insurance
- Intellectual Property
- International Business
- Labor and Employee Relations
- Laboratory
- Licensure, Accreditation and Certification
- Manufacturing Compliance
- Marketing and Advertising
- Medical Transportation
- Medicare Bundled Payment Programs
- Medicare Conditions of Participation
- Medicare Coverage Determinations
- Medicare Enrollment
- Occupational Safety
- Patient Safety
- Payer Contracts
- Payroll
- Pharmacy
- Physician and Provider Relations
- Physician Relationships
- Physician Services/Practices
- Political Activities
- Privacy
- Provider-based Entities
- Procurement
- Real Estate
- Records Management
- Rehabilitation Services
- Safety and Security
- Sarbanes-Oxley Act
- Securities Regulation
- Surgical Services
- Tax
Committees
Ethics and Compliance committees throughout HCA Healthcare provide direction and support to the Ethics and Compliance program.