Corporate Compliance Program

The Corporate Compliance Program is part of the Mount Sinai Medical Center's (MSMC) Compliance Department. We provide oversight and education related to the following areas:

• Physician and Business Contracts Oversight & Monitoring
  We are responsible for monitoring professional services (facility), part-time agreements (provider), and administrative/business (non-clinical) contracts. We have a formal review and oversight process for these contracts to ensure we are compliant with regulatory mandates. Education is provided annually to physicians and other contracted service providers.
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• Conflict of Interest
  Mount Sinai Medical Center has an obligation to ensure that its trustees, faculty, employees and other staff adhere to the highest standards of ethical conduct free from any improper external influence or any appearance of impropriety. In order to safeguard the integrity of both Mount Sinai and its constituents, Mount Sinai has adopted a rigorous conflicts policy predicated on full disclosure and appropriate management of any possible conflict of interest.
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• Stark Non-Monetary Compensation Oversight Program
  In order to ensure adherence to annual IRS/Stark Law limitations to physicians who receive non-monetary compensation, Corporate Compliance is responsible for oversight of various programs and events hosted by Mount Sinai for voluntaries and/or other outside physicians.
  
  The oversight program entails providing Stark Law education to physicians/employees who plan to host an event on behalf of Mount Sinai and ensure that the event plans and details are in accordance with requirements as outlined by Stark Law and IRS guidance.
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• The office of Corporate Compliance also assists in education on the Code of Conduct and other Compliance Related Policies, activities related to the confidential Compliance Helpline & Confidential Disclosure process, as well as confidential investigations and exit interviews.