Code of Conduct
Memorial is committed to conducting its business operations in full compliance with federal, state, and local laws and regulations; participation requirements of federal and state healthcare programs, such as Medicare and Medicaid, and private insurance plans; accreditation and certification requirements for healthcare services; and ethical standards.
Memorial expects each vendor of items and services for its patients to likewise conduct affairs in an ethical manner that is in compliance with all applicable laws, regulations, and guidelines.
Screening of Vendors
Memorial conducts screening of all vendors against the following databases at the time of initial contracting and monthly thereafter:
- List of Excluded Individuals and Entities (LEIE) maintained by the Office of Inspector General of the U.S. Department of Health and Human Services
- The System for Award Management (SAM) maintained by the U.S. General Services Administration, which includes individuals and businesses debarred from receiving federal contracts
- The Healthcare and Family Services Provider Sanctions (HFSPS) list maintained by the Illinois Office of Inspector General, which includes individuals and businesses excluded from participation in the Illinois Medicaid program
As a Condition of Doing Business with Memorial, Each Vendor:
- Shall conduct monthly LEIE, SAM, and HFSPS screenings of all employees and contractors (and any downstream contractors and employees) providing items or services, directly or indirectly, to patients of Memorial, and retain documentation of each such screen for no less than 10 years.
- Agrees to provide documentation of monthly screenings to Memorial within three business days of Memorial's written request.
Information on False Claims
The Deficit Reduction Act of 2005 requires the Memorial to disseminate information to vendors concerning federal and state false and fraudulent claims.
As a condition of doing business with Memorial, each vendor must ensure that its employees and contractors (and any downstream contractors and employees) understand and will comply with Memorial’s False Claims Recovery Policy.
Each vendor shall provide documentation of its annual dissemination of the policy to employees and contractors to Memorial within three days of Memorial’s written request, and maintain such documentation for not less than 10 years.