ComplianceNotice of Privacy Practices
Welcome from Wayne McNulty, Chief Compliance Officer
Thank you for visiting the Nuvance Health™ Corporate Compliance Office (“Compliance”) page.
The Compliance team maintains Nuvance Health’s Corporate Compliance Program (the “Program”). We designed the Program to:
- Detect, deter, and reduce incidents of illegal, unprofessional and unethical conduct, fraud, waste and abuse
- Enhance Nuvance Health’s operations and the quality of healthcare delivery
- Reduce healthcare costs
The Purpose of the ProgramThe team uses the Program to establish an organizational culture throughout Nuvance Health that promotes the prevention, detection and resolution of conduct that fails to comply with:
- Applicable Federal and State administrative, civil and criminal law
- Requirements of Federal healthcare programs and private payors
- Nuvance Health’s standards of ethical and business conduct and the policies and procedures that support those standards
The Program covers the following risk areas and more:
- Billings, payments and mandatory reporting of overpayments
- Medical necessity
- Quality of care
- Privacy and security of patient and employee information (e.g., HIPAA privacy and security)
- Human subject research protections
As part of its mission to implement an effective and comprehensive Program, Compliance operates an internal audit division. This division provides independent, objective assurance and consultative services that add value and improve Nuvance Health’s operations.
The internal activity brings a systematic, disciplined approach to evaluating and improving governance, risk management and control processes.
Open Lines of Communication Promote Compliance
The Program establishes open lines of communication through initiatives including:
- Training and education programs
- Confidential and anonymous helpline
- Internal audit activities
- HIPAA privacy and security program
We use information gathered to provide guidance on the management and operation of all Nuvance Health facilities, units and entities in a legally compliant and ethical manner. Compliance shares its findings with:
- Nuvance Health Board of Directors
- Senior management and administrators
- Physicians, clinicians and allied health professionals
- Support staff and other personnel
Mandatory Compliance and Reporting
We take pride in carrying out our patient care activities, business functions and community relations in a responsible way, governed by our:
- Reason for Being and values
- Code of Conduct Connecticut
- Code of Conduct New York
- Nuvance Health Compliance and Ethics Program Charter
- Medicare Part C and D Communication and Training
- Other internal policies and procedures
Workforce members, business affiliates and agents (“Covered Individuals”) who violate organizational policies and procedures will be subject to progressive disciplinary action. These actions may include termination of employment, contract or other affiliation with Nuvance Health.
Nuvance Health expects covered Individuals to promptly report to Compliance any known unethical, unprofessional, illegal, improper or unsafe conduct they become aware of.
Confidential and Anonymous Reporting of Compliance Issues and Concerns
We invite covered Individuals to report compliance issues, concerns and Program violations anonymously and confidentially by:
Calling the 24-hour Nuvance Health confidential and anonymous Compliance Hotline:
- (844) YES-WeComply (844) 937-9326) (for covered individuals at legacy Health Quest)
- (844) 395-9331 (for covered individuals at legacy WCHN)
- Submitting comments online at: nuvancehealth.ethicspoint.com
- Covered Individuals may also confidentially report compliance issues, concerns and Program violations in person, by U.S. mail or interoffice mail, telephone, fax or email.
Nuvance Health protects whistleblowers and strictly prohibits retribution, harassment, intimidation or any other form of retaliation. We extend this protection to Covered Individuals or other persons or entities that, in good faith, make a compliance report or complaint or have otherwise participated in the Program. Read the whistleblower protection policy.
Connecticut (legacy WCHN)
New York (legacy Health Quest)
- Policies and Procedures
- Corporate Compliance Manual
- Communication Regarding the Deficit Reduction Act of 2005
- Vendor Code of Conduct
Patient Rights and Responsibilities
Our Compliance Leadership