The Chinese Community Health Plan (CCHP) Standards of Conduct state the overarching principles and values by which CCHP operates, and define the underlying framework for CCHP’s compliance policies and procedures. They set forth standards and expectations by which all employees, consultants/contractors, members of CCHP’s governing board, and CCHP’s first-tier, downstream, or related entities (FDRs) conduct themselves in an ethical manner; that issues of actual or potential fraud, waste, and abuse (FWA), and issues of noncompliance are reported through appropriate mechanisms; and that those reported issues will be earnestly addressed and corrected.
CCHP Compliance
CCHP Standards of Conduct
Privacy and HIPAA
As a Covered Entity (CE), CCHP and its workforce, First-Tier, Downstream and Related Entities (FDRs), and its Board of Trustees must abide by applicable Privacy and Security Laws, including subsequent modifications to HIPAA Regulations, i.e., the HITECH Act and the Omnibus Final Rule. To report actual or potential HIPAA breaches to CCHP, please call CCHP’s Compliance Hotline number immediately: 1-415-955-8810 and/or email the Compliance Department at CCHPComplianceDepartment@cchphealthplan.com or the Chief Compliance Officer at janet.eisenberg@cchphealthplan.com
Fraud, Waste, and Abuse (FWA) and General Compliance
Every year billions of dollars are improperly spent because of FWA. It affects everyone—including you. Combating FWA is everyone’s responsibility! Every CCHP employee, each member of the Board of Trustees, consultant, contractor, and FDR (First-tier, downstream, and related entity) must be trained on FWA laws and are required to report all actual or potential FWA incidents to the CCHP Chief Compliance Officer (CCO). The CCHP CCO is required to conduct an investigation of all reported FWA incidents to the CCHP Board of Trustees and to State and/or Federal Enforcement Agencies.
To report actual or potential FWA to CCHP, please call the Compliance Hotline number 1-415-955-8810. Calls to this number are confidential.
Retaliation for good faith reporting of FWA, compliance concerns, complaints or incidents of harassment or discrimination, or perceived harassment or discrimination, or for participating in any investigation of such complaints, incidents or reports is a violation of the CCHP Standards of Conduct and is strictly prohibited.
Compliance Program Requirement
The Centers for Medicare & Medicaid Services (CMS) requires CCHP to implement and maintain an effective compliance program. CCHP’s compliance program:
- Articulates and demonstrates CCHP’s commitment to legal and ethical conduct.
- Provides guidance to CCHP’s workforce, governing board, and contractors/consultants on how to handle compliance questions and concerns.
- Provides guidance to CCHP’s workforce, governing board, and contractors/consultants on how to identify and report compliance violations.
CCHP Ethics and Compliance Hotline
If you suspect violations of CCHP’s Standards of Conduct, healthcare Fraud, Waste, and Abuse (FWA) laws, HIPAA/HITECH Act laws (Privacy or Security), or potential noncompliant incidents, you may do any one or more of the following:
- Call the CCHP Ethics and Compliance Hotline at 1-415-955-8810, 24/7.
All calls to this number are confidential. - Report the incident to:
• CCHP’s Chief Compliance Officer
Janet F. Eisenberg, MS, CFE.
Email: janet.eisenberg@cchphealthplan.com
Phone: 1-628-228-3393
• CCHP’s Compliance Department mailbox
Email: CCHPComplianceDept@cchphealthplan.com
Retaliation for good faith reporting of FWA, compliance concerns, complaints or incidents of harassment or discrimination, or perceived harassment or discrimination, or for participating in any investigation of such complaints, incidents or reports is a violation of the CCHP Standards of Conduct and is strictly prohibited.