The Johns Hopkins Health System Corporate Compliance Department assists and advises all employees - directors, officers, hospital staff, and associated or affiliated contract workers - on how to prevent, detect, and correct employee violations of the Federal, State, or local laws, or institution policy and procedure violations.
Founded in 1998, the Compliance program is designed to:
- Protect our organization, employees, and patients.
- Preserve the level of integrity for which Hopkins is known.
- Maintain effective internal controls that promote adherence to legal and ethical standards.
- Promote the prevention, detection, and resolution of illegal or unethical conduct.
- Promote the continued effort to do the right thing.
Have compliance questions? First check out our compliance documents below. You can reach the Compliance Department by calling 1-844-SPEAK2US, or contact a Corporate Compliance Department representative (see below) for additional information.
The Johns Hopkins Health System Corporate Compliance Department was founded to prevent, detect, and correct employee violations of the federal, state, or local laws, or institution policy and procedure violations.
The Johns Hopkins Health System Corporation (JHHSC) and all of its affiliates take health care fraud and abuse very seriously. JHHSC is committed to following all applicable laws and regulations, in particular those that address health care fraud, waste, abuse, and disrupt the proper billing of Medicare, Medicaid and other government-funded health care programs. This includes the Federal False Claims Act and State law or other related enforcement policies.
Since 1998, it has been our primary responsibility to provide the JHHS entities with oversight support, audits, ongoing monitoring, and institutional training for any matter related to facility billing for services provided.
A large majority of our work centers on compliance with the necessary regulatory requirements and conditions for participating in government-funded insurance programs. In order for us to participate in these programs (such as Medicare and Medicaid), we must comply with medical record and patient consent documentation standards, facility and practitioner licensing processes, coding and billing claims for payment claims, among other things.
Failure to comply with these regulations, conditions and standards can result in civil and criminal sanctions, monetary penalties, and elimination from those programs.
There are a number of federal and state law enforcement agencies funded solely to investigate and prosecute people or entities that commit “health care fraud” and to recover non-fraudulent overpayments. Some of these agencies include the Office of Inspector General (OIG), the Department of Justice (DOJ) and state Medicaid Fraud Control Units (MFCU).
The OIG, for example, can investigate an allegation of healthcare-related fraud on its own, and audit a hospital’s billing patterns to a Federal payor such as Medicare. The OIG or DOJ may investigate a healthcare fraud investigation based on information from a “whistleblower” (typically an employee who provides inside information to investigate and prosecute the case against the organization).
These suits would be brought under the Federal False Claims Act (FCA), and is in fact one of the most powerful weapons in the government’s arsenal. The types of “frauds” usually alleged under the FCA include, among others, billing for services not rendered and billing for services considered not “medically necessary” or in excess of those provided and kickbacks in return for influencing the provision of health care services.
- Conflict of Interest and Conflict of Commitment (CC0007)
- Corporate Compliance Plan
- Corporate Compliance Plan (CC0010)
- Federal and State False Claims Acts and Whistleblower Protections: Education and Commitment (CC0006)
- Issue Reporting Policy
- JHHS Trustees & Officer Conflict of Interest Policy (CC0012)
- Physician Non-Monetary Compensation for JHACH, HCGH, SIbley, and Suburban (CC0001)
- Physician Non-Monetary Compensation Policy for The Johns Hopkins Hospital and Johns Hopkins Bayview Medical Center (CC0005)
- Physician Contracting Policy (CC0008)
- Physician Personal Service Arrangement Payment Policy (CC0002)
- Policy on Johns Hopkins Health System Compliance Department Audit Ratings (CC0004)
- Sunshine Act Policy
- Trustee Investment in Companies Closely Engaged with Johns Hopkins (CC0011)
- Johns Hopkins Health System and SOM Infusion Guideline (updated September 2020)
Johns Hopkins Health System
The Johns Hopkins Hospital
Johns Hopkins Bayview Medical Center
Johns Hopkins Howard County Medical Center
Johns Hopkins All Children's Hospital
Johns Hopkins Health Plans
Johns Hopkins Home Care Group
Sibley Memorial Hospital