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Federal Sentencing Guidelines--HYPOTHETICAL

By Steve Paterson posted 02-21-2014 11:55 AM

  

I have to assume that all of us will eventually encounter a high level manager who wants to block our goal of doing the right thing.  Here is one solution that has worked well for me for10 years.

I used a selection of interview questions from varuious auditing tools and developed an Audit Questionnaire that I send to all levels of staff throughout the organization, including President/CEO, VPs, Directors, Business Office Managers, billing and coding staff, etc.

The questionnaire requires each individual to answer very straightforward questions to disclose any suspicious business activities and any gray areas we may be operating in. I've added several questions of my own over the years based on situations that have come up.

Examples: Is there any activity that you consider to be a violation of laws, code of conduct, regulations, generally accepted accounting principles, professional practice, or business ethics?  Have you encountered any situations in which the organization complied with legal minimums of behavior, yet failed to go the extra mile to demonstrate its commitment to the highest ethical standards? Discuss any areas in which there is a coding or accounting treatment that could be construed as aggressive or otherwise ianppropriate.  Discuss any situations where you were asked to conduct your business in a matter you felt was not ethical or appropriate--how did you respond?   Do you feel comfortable raising issues without fear of retaliation?

The completed questionnaires are returned to me. I forward them to the Chair of the Board Finance and Audit Committee.  That individual reviews them with the Committee which determines if external auditors or consultants should come in to probe any specific areas under the direction of the Board.

This process has helped to motivate staff to stay clean themselves and not get drawn into any scheme or gray areas others are operating in.  Everyone knows who has to complete a questionnaire and what questions will have to be answered.  The instructions in the questionnaire tell the individuals to contact the itegrity hotline if they feel they need to remain anonymous with any of their answers, and everyone knows that every hotline report will eventually be reported to the Board. It's a bit of preventative medicine.

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