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Existing Resources for Nonprofit Healthcare Organizations to Enhance their Ethical Business Practices and Corporate Responsibility
To follow are brief descriptions of major publications and organizations focusing on ethical behavior or corporate responsibility/compliance that have been identified by the Alliance for Advancing Nonprofit Healthcare.
"Corporate Responsibility Guidebook"
This document, prepared by a Washington, DC law firm, was published in November 2003 by the Coalition for Nonprofit Health Care, which is terminating its operations. The Alliance is seeking permission to make this resource available to the field. This document discusses the overall effects on governance/management relationships of recent investor-owned and nonprofit scandals, and provides five pages of recommendations on specific initiatives that should be taken by nonprofit healthcare organizations.
"Corporate Responsibility and Corporate Compliance: A Resource for Health Care Boards of Directors"
This document, recently developed and issued by Office of the Inspector General (OIG) of DHHS and the American Health Lawyers Association, contains five pages of questions and general discussion related to the development and operation of a corporate compliance program to prevent fraud and abuse. The document is available on the OIGs Website, www.oig.hhs.gov, under compliance guidance publications.
"Evaluating and Improving a Compliance Program: A Resource for Health Care Board Members, Health Care Executives and Compliance Officers"
This thirty-five page document was issued in April, 2003 by the Health Care Compliance Association, one of the organizations described in the next section. It is available on its website (www.hcca-info.org). The document provides rather extensive guidance to healthcare organizations related to the establishment, operation and evaluation of a corporate compliance program. It does not attempt to discuss all of the specific laws, regulations and standards with which healthcare organizations must comply. Rather, it presents relevant basic issues and guidance on implementation, roles of the compliance officer, management and board, and on evaluation and measurement of results in each of the following areas: policies and procedures, ongoing education and training, open lines of communication, ongoing monitoring and auditing, enforcement and discipline, and investigation, response and prevention.
"New Corporate Governance Guidelines-What They Mean for Nonprofit Healthcare Boards"
This four-page report, issued in August 2002 by the Governance Institute (described in the next section), discusses the applicability of new NYSE corporate governance standards for nonprofit healthcare organizations and is available on its website (www.governanceinstitute.com).
"Boards Under Fire: Are Not-for-Profit Institutions Being Held to a New Standard of Public Accountability?"
This 15-page report, co-published by the Volunteer Trustees Foundation and the Governance Institute, provides brief case studies of conflicts during the 1990s between state attorneys general and nonprofit hospitals in Florida, New York, New Hampshire and California related to closures, mergers, or reductions in services. The report contends that nonprofit institutions will be held to a new standard of public accountability that will require new governance structures as well as new processes for relating to both the community and management in order to meet legal obligations of duty to purpose, due care, and loyalty. This report is available on the website of the Volunteer Trustees of Not for Profit Hospitals
(www.volunteertrustees.org), another of the organizations described in the next section. (This organization also has available for purchase a report on state-by-state state legislation regulating conversions, a summary of the legal obligations of not-for-profit boards, and a guide to improve trustee understanding of the sale and conversion of not-for-profit hospitals to for-profit corporations and what trustees can do about it.)
"ACHE Code of Ethics"
This seven-page code, adopted by the Council of Regents of the American College of Healthcare Executives in March 2000, includes a grievance procedure for reporting and reviewing alleged violations of the code by College members. The code is available on the Colleges website, www.ache.org.
"Creating a Workable Company Code"
This guide, first published in 1990 by the Ethics Resource Center, described in the next section, has just been updated and incorporates information on the U.S. federal sentencing guidelines, the Sarbanes-Oxley Act of 2002, and the modified Securities and Exchange Commission guidelines. It is available for purchase on the Centers website, www.ethics.org. (This Center also just released the results of its third telephone survey of American worker views on ethics in the workplace.)
"Fifth Annual Survey: 2002 Profile of Health Care Compliance Officers"
This report, just released by the Health Care Compliance Association (also described in the next section), is available on HCCAs website, www.hcca-info.org. Compensation, type and size of organization, work priorities, and other information concerning corporate compliance professionals is provided in this report.
Individual Organization Statements of Ethical Practices or Codes of Conduct
There are numerous examples of individual organization policies/guidelines related to various types of ethical conduct/corporate responsibility readily available on the Internet. They vary in depth, from very general guidance (e.g., Better Business Bureau), to fairly detailed (e.g., Nortel Networks), with many in between (e.g., Cleveland Clinic).
Journals on Ethics
The following journals have been identified thus far: Business Ethics Magazine, Business Ethics Quarterly, Ethikos, Ethix, Journal of Business Ethics, and Journal of Business Ethics and Organization Studies (Finland), Inc. Onlines Ethics Corner, Corporate Conduct Quarterly, Online Journal of Ethics, and Teaching Business Ethics.
Books Related to Ethics
One website, www.meansbusiness.com, enables one to search by topic for passages or "concept extracts" from books. Searching under "ethics", nine were identified:
The E-Center for Business Ethics (www.ebusinessethics.com), discussed in the next section, recommends 28 other books.
Council on Ethical Organizations and its Health Ethics Trust Division
The membership of this group, established in 1980, consists of only healthcare organizations, and includes some notable nonprofits (BCBS FEP, North Carolina BCBS, Michigan BCBS, Illinois BCBS, Kaiser Permanente, Adventist Healthcare, Holy Cross Health, Partners Healthcare, Summa Health System) as well as investor-owned healthcare organizations (United HealthCare, Wellpoint Health Networks, Baxter International).
It seeks to assist primarily ethics/compliance professionals, providing educational programs (e.g., best practices, train-the-trainer), a newsletter (Pastin Report) and a certification program. It also conducts survey research. See www.corporateethics.com.
The Ethics Resource Center
This is a nonprofit educational organization, established in 1977 with the broad goal of inspiring both individuals and organizations, both in the U.S. and internationally, to act ethically. Its membership and board are not described on its Website (www.ethics.org).
It provides articles, book lists, research reports and guides, speeches, videos, links to other ethic-related websites, consulting services, educational programs and a speakers bureau. These services appear to be oriented primarily toward ethics/compliance professionals.
It also has a Fellows Program, begun in 1997, consisting of 55 select leaders with strong expertise and interests in ethics. This program has published four reports, the most recent on Employee Confidentiality and Non-Retributory Reporting Systems, and has four more underway, including reports on Value-based Leadership and Ethical Role Modeling.
Ethics Officer Association
This is a professional association, founded in 1992 exclusively for managers of ethics and compliance programs in both investor-owned and nonprofit organizations in a wide variety of industries. Currently there are close to 900 members. See www.eoa.org. It provides educational programs for its members, articles, books, salary survey information, and a job center. It does not appear to offer a certification program for its members. Its research appears to be restricted to salary surveys.
Health Care Compliance Association
This groups mission is to "champion ethical practice and compliance standards within the health care community and to provide the necessary resources for compliance professionals and others who share these principles". It claims to serve all segments of the healthcare industry, although its corporate members appear to be primarily law, accounting and other consulting firms. It provides educational programs, a speakers bureau, a newsletter, and a certification program. It states that it does not lobby and does not focus on bio-ethical issues. See www.hcca-info.org
E-Center for Business Ethics
This is a web-based service (www.e-businessethics.com) of the Colorado State University College of Business. It provides three case studies and links to ethics-related articles, case studies, articles, and books. It also provides a ten-week online certification program apparently aimed at ethics/compliance professionals.
American Hospital Association
The AHA offers a compliance Website through www.hospitalconnect.com , offering a regulatory standards manual exclusively for its members. Other publications and information on educational programs are also offered on that site.
Annual National Congress on Health Care Compliance
The ownership of this forum is unclear. It appears to be a commercial venture begun in 1998 for primarily healthcare compliance professionals. Sponsors include a wide variety of healthcare-related journals and newsletters. See www.compliancecongress.com.
Colleges and Universities
There appear to be a significant number of institutions of higher learning with research and/or educational
focused specifically on ethics or corporate compliance. In addition to Colorado State University as noted above, several other schools appear to be active in this subject matter: Bentley College (MA) , University of St. Thomas (TX), Loyola Marymount (CA), Georgetown, Iowa State, and the Wharton School.
Eye on Integrity
This e-business firm provides online interactive training for employees and managers on more than 100 ethics and human resource topics, organized into more than 25 courses. Its website is www.eyeonintegrity.com.
In addition to the foregoing, the following organizations focused on organizational governance have been providing or can be expected to have been providing at least some educational programs and/or other tools related to ethics or corporate responsibility/compliance:
This organization, established in 1986, offers educational programs, research reports, books, audio and visual tools, self assessment guides, and other resources to hospital and healthcare system governance and management leaders. See www.governanceinstitute.com.
Founded in 1987, this group changed its name in January 2002 from the National Center for Nonprofit Boards. It purports to have 16,000 individual members, with a staff of over 30 and a budget near $10 million. It does not appear to have any healthcare representation on its current board. It provides educational forums, and has a bookstore on its website (www.boardsource.org).
Volunteer Trustees of Non for Profit Hospitals
Established in 1980, this organizations stated purpose is to preserve and further the not-for-profit healthcare sector. It presents itself as "the only national forum run by trustees for trustee-to-trustee exchange, discussion and education". In additional to educational forums and research, this organization has produced several reports and guides as noted in the previous section. See www.volunteertrustees.org.
American Governance and Leadership Group
This is a business venture of the AHA and four individuals who are educational and governance experts. It provides educational programs, publications and consulting assistance. See www.americangovernance.com. (The AHA separately publishes Trustee magazine.)
Selected State-level Organizations
Several state hospital assosiations, most notably in New Jersey, New York, Washington, and Arkansas, have specific centers devoted to governance research and/or education. At least one private health insurance organization, Blue Cross and Blue Shield of Florida, has established a center for ethics (in this case, based at the University of North Florida).