Background:
Blue Cross and Blue Shield of Kansas City’s (BCSBKC) Ethics & Compliance Program is based on the requirements outlined in the Federal Sentencing Guidelines, as amended in 2010, and the Sample Compliance Program outlined by the Blue Cross and Blue Shield Association.
Organization of the BCBSKC Ethics & Compliance Program:
The BCBSKC Corporate Ethics & Compliance Officer will have a direct reporting relationship to the Legal Department and to the Audit Committee of the Board of Directors. The Corporate Compliance Committee will be made up of the officers who serve on the Senior Management Committee.
Elements of the BCBSKC Ethics & Compliance Program:
- BCBSKC will conduct periodic ethics and compliance risk assessments as part of the Corporate Enterprise Risk Management program. This assessment will focus on determining the likelihood that criminal offenses or unethical conduct may occur.
- BCBSKC will establish and maintain Ethics & Compliance Program standards and procedures, as documented in the Code of Ethical Business Conduct, that are reasonably designed, implemented and enforced so that the program is generally effective in preventing and detecting criminal conduct.
- The BCBSKC Ethics & Compliance Officer has responsibility to oversee the Ethics & Compliance Program. The Ethics & Compliance Officer shall report at least annually to the Audit Committee of the Board. Additionally, in order to ensure the Ethics & Compliance Officer’s ability to fulfill his/her obligations, the following requirements apply to the Ethics & Compliance Officer:
- The Ethics & Compliance Officer can only be removed for cause.
- Removal of the Ethics & Compliance Officer requires a majority vote of the Board of Directors.
- A direct reporting relationship will exist between the Ethics & Compliance Officer and the Board.
- The Ethics & Compliance Officer will be given adequate resources, appropriate authority, and direct access to the Board or an appropriate subgroup of the Board.
- BCBSKC will make reasonable efforts not to include any individual within the Ethics & Compliance Office that BCBSKC knows, or through the exercise of due diligence should have known, has engaged in illegal activities, or other conduct inconsistent with an effective ethics & compliance program.
- BCBSKC requires ethics & compliance training for Board members and employees. All Board members and employees will be required to complete annual ethics & compliance training and to annually attest they have read and understand the Code of Ethical Business Conduct. Failure to do so will be reflected in annual performance reviews for employees and will be reported to the Audit Committee for Board Members. The effectiveness of the Ethics & Compliance is evaluated on a periodic basis.
- BCBSKC has monitoring and auditing systems - such as segregation of duties, financial controls, quality assurance and an annual Internal Audit Plan - that are reasonably designed to detect criminal conduct by employees. BCBSKC Internal Audit also conducts periodic evaluations of how well the Ethics & Compliance Program is working.
- BCBSKC has an established, well publicized reporting system by which employees and other agents can report criminal conduct by others within the organization without fear of retaliation.
- BCBSKC has established mechanisms to discipline employees who violate the Code of Ethical Business Conduct, up to and including termination of employment where appropriate. This step includes, as appropriate, discipline of the individuals responsible for the failure to detect violations of law or otherwise unethical conduct. These failures will also be reflected during an employee’s annual performance review. Board members who violate the Code of Ethical Business Conduct will be reported to the Chair of the Audit Committee.
- When unlawful or unethical conduct is detected, BCBSKC will take all reasonable steps to respond appropriately to the improper conduct and to prevent similar occurrences, including making needed modifications to the Ethics & Compliance Program and Code of Ethical Business Conduct.