Introduction

The UW School of Dentistry is committed to conducting its business in compliance with the law. The School can meet this commitment only through the efforts of our department leaders and chairs, administrators, managers and their designees, faculty, staff and students. We must continue to earn the trust and respect of patients and others by conducting our daily affairs with honesty, integrity, and in compliance with the letter and spirit of all applicable laws. Although honesty and integrity are individual attributes, and each individual is ultimately responsible for his or her own conduct, the School is committed to maintaining a working environment that promotes these ideals and permits our employees to demonstrate the highest professional standards in performing their daily tasks.

The School has developed a Compliance Program as a comprehensive statement of the responsibilities and obligations of all employees, students and professionals, to understand and adhere to applicable federal and state laws, and to fulfill the program requirements of federal and state health plans. Compliance practices and procedures of the School will be developed and kept current with applicable laws and regulations.

Basic Principles

  • Integrity: The School honors integrity as a fundamental value and demonstrates the highest levels of professional conduct in all its dealings. Each individual associated with School must perform his/her personal duties in accordance with these values.
  •  Compliance with Legal Standards: The School follows all applicable federal and state laws and regulations. Each person associated with the School is charged with the responsibility to learn and understand the legal standards which relate to his/her duties and to follow them accordingly.
  •  Accurate Billing and Records: The School is committed to maintaining accurate documentation and billing records that reflect services provided. Errors will be assessed and corrected appropriately.

Compliance Program Structure

  • Participation: It is the responsibility of each faculty member, staff, student and independent contractor to abide by applicable laws and regulations and support the School’s compliance efforts.
  • Responsible Officer: The School has designated the Compliance Director as the individual within the School responsible for overall implementation and operation of the Compliance Program.
  • Compliance Committee: The School’s Compliance and Training Committee is responsible for compliance oversight and advises and assists the Compliance Director with implementation and operation of the Compliance Program.
  • Oversight: The Compliance Director will report at least biannually to the Compliance and Training Committee on the status of compliance within the School.
  • Employee and Vendor Screening: The School shall not contract with, employ or extend privileges to any individual or entity that is excluded from participation or is otherwise ineligible to participate in federal health care programs.
  • Education: The School will provide ongoing, effective education and training programs for all faculty, staff and students on Organizational Professionalism and the Compliance Program.
  • Auditing and Monitoring: The School will establish procedures for monitoring the effectiveness of the Compliance Program.
  •  Risk Assessment: The School will conduct ongoing risk assessments and take appropriate steps to reduce the risk of law violation identified through the assessment process.
  • Enforcement and Prevention: Individuals violating the standards of this Compliance Program will be subject to progressive discipline, up to and including termination, if warranted. Sanctions will be applied in accordance with relevant staff personnel policies, School policies/procedures and/or faculty code as appropriate.
  • Organizational Response: The School will respond to potential violations of the Compliance Program and/or applicable federal and state laws/regulations reported by staff, students, faculty members or others that have questions or concerns regarding School activity.

Conclusion

The Compliance Program has been created to foster the School of Dentistry’s commitment to maintaining a working environment that promotes honesty and integrity and permits our employees, students and faculty to demonstrate the highest professional standards in performing their daily tasks.

Joel H. Berg, DDS, MS
Dean, School of Dentistry