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Radial
Radial

About Us

A national leader in innovative blood health solutions

Corporate Compliance Program

Versiti and its Affiliates are committed to the highest standards of ethical and professional conduct and maintain a Compliance Program in accordance with Compliance Program Guidance published by the Office of Inspector General (OIG), U.S. Department of Health and Human Services (HHS). The key components of our Compliance Program, developed by senior leadership and approved by our Board of Directors, are described in detail below.

Compliance Program

  • Leadership and Structure

    Compliance is a key focus at every level of our organization. Our Board of Directors, Board Committees, Senior Leadership and Staff collaborate extensively to ensure that every individual has the information and resources necessary to achieve our commitment to the highest standards of ethical and professional practice.

    Corporate Compliance

  • Written Policies and Procedures

    Versiti and its Affiliates maintain a written Code of Conduct and supporting policies and procedures. These policies and procedures provide clear guidance for Versiti representatives and our business partners.

    Each Versiti representative must acknowledge receipt of Versiti's Code of Conduct and confirm that they understand and will follow the standards. In addition, Versiti employees are asked to confirm that they understand and comply with the Code of Conduct annually.

    Versiti's Code of Conduct and the supporting policies and procedures may change from time to time and Versiti representatives are responsible for knowing and complying with the current laws, rules, regulations, standards, policies and procedures that govern their work.

  • Education and Training

    A critical element of our Compliance Program is the education and training we provide with respect to each individual’s ethical and legal obligations, including obligations regarding participation in federal and state health care programs. Versiti is committed to effectively communicating our policies and procedures and other requirements to all Versiti personnel. Versiti regularly reviews and updates its educational offerings, and identifies specific needs for targeted education.

    Compliance training enables employees to perform with integrity by understanding the legal and regulatory implications of their actions. Versiti provides risk-specific training to appropriate employees, reinforced with guidance from compliance staff and resource guides to ensure compliance.

  • Effective Internal Communication

    Versiti is committed to fostering an environment of openness and transparency in which all Versiti personnel and our business partners feel comfortable asking questions, expressing concerns, and confidentially reporting suspected violations, without any fear of retaliation. Our goal is to ensure that each individual knows who to turn to for a meaningful response and are assured that their concerns will be promptly evaluated and addressed. In addition, we welcome input from our business partners.

    In order to encourage open lines of communication, there are multiple ways that individuals can seek additional information or report concerns or potential violations. Versiti employees are encouraged to talk with their immediate supervisors or managers. However, there may be circumstances in which an employee needs other resources. Employees, volunteers and our business partners may contact any of the following:

    • any manager, supervisor or Vice President
    • any Human Resources representative
    • Compliance Officer
    • Corporate Counsel
    • President & Chief Executive Officer
       

    Versiti's Whistleblower Helpline is also available to our employees, their families, suppliers and customers as another channel to seek guidance or report concerns. Persons calling the Ethics and Compliance Helpline may choose to remain anonymous.

  • Auditing and Monitoring

    Versiti monitors compliance with applicable laws and policies through a number of mechanisms. Versiti’s Quality Support Services (QSS) department provides ongoing oversight and auditing of our performance related to regulatory requirements published by federal and state agencies, such as the Food and Drug Administration (FDA) and the Centers for Medicare and Medicaid Services (CMS). In addition, our QSS staff evaluates our ongoing compliance with applicable accreditation standards.

    Versiti’s Corporate Compliance Officer and the Corporate Compliance Committee oversees implementation of the Compliance Program and promptly addresses compliance concerns communicated internally or through our confidential Whistleblower Hotline.

    The Versiti Board of Directors Audit and Compliance Committee develops and oversees an annual internal auditing plan. In accordance with OIG Guidance, the nature of our reviews, as well as the extent and frequency of our compliance monitoring and auditing, varies according to a number of factors, including new regulatory requirements, changes in business practices and other considerations. We engage an internal auditing consultant to perform risk-based assessments and assist us identifying areas of concern related to our business processes and procedures, systems, and internal controls. Our internal auditing consultant also assists us with the planning and execution of internal reviews.

    In addition to our internal auditing plan, Versiti engages independent external auditors to provide independent analysis of our financial statements and assess whether such statements conform with generally accepted accounting principles and accurately represent the financial position of our organization.

  • Enforcement and Discipline

    Versiti is committed to maintaining a workforce dedicated to our mission and our commitment to the highest standards of professional and ethical conduct. Accordingly, Versiti carefully evaluates each applicant will not knowingly employ or do business with persons or organizations that have been excluded, debarred, suspended or are otherwise ineligible to participate in Federal healthcare programs.

    Each Versiti representative is accountable for his or her compliance with applicable laws and Versiti policies. Versiti representatives who fail to meet their obligations are subject to corrective or disciplinary action, up to and including termination of employment. Although each situation is evaluated on a case-by-case basis, Versiti consistently undertakes appropriate disciplinary action to address inappropriate conduct and deter future violations.

  • Responding to Concerns and Corrective Action Initiatives

    Violations of law or our policies and procedures and other misconduct undermines our ability to pursue our charitable mission by threatening our reputation of integrity and excellence. Our Compliance Program is designed to ensure that we respond promptly to indications of suspected non-compliance with applicable law or our policies. We thoroughly investigate all potential violations and routinely assess root causes. In particular, we actively evaluate whether compliance issues result from gaps in our policies, practices, education and training, or internal controls. After careful analysis of compliance concerns, we design and implement effective corrective action plans.

If you have any questions or concerns about our Compliance Program, or need additional information about compliance at Versiti, please contact our Compliance Officer:

Compliance Officer
Maureen Kwiecinski
414-937-6418
Maureen.Kwiecinski@versiti.org

Anonymous Hotline Contact Information

Telephone

Call 213-443-1186
The Fulcrum telephone hotline is answered by Fulcrum professional personnel from 10:00 a.m. to 8:00 p.m. Central Time. Outside these hours, the phone will be answered by an automated voice mail system.

Internet

Web-based reporting form is available at www.fulcrum.com/bcw

Email

Send an email to Fulcrum at whistle@fulcrum.com

U.S. Mail

Send a written report via U.S. Mail to Fulcrum at:
Fulcrum Inquiry
Whistleblower Department
888 S. Figueroa Street, Suite 2000
Los Angeles, CA 90017

Facsimile

Send a written report via facsimile to: Fulcrum Inquiry

Please click here to review our Whistleblower Policy.

Leadership and Structure

Compliance is a key focus at every level of our organization. Our Board of Directors, Board Committees, Senior Leadership and Staff collaborate extensively to ensure that every individual has the information and resources necessary to achieve our commitment to the highest standards of ethical and professional practice.

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