NSider • Posted on Jan 9, 2024
Important Policy Updates
from BCBSM’s Enterprise Compliance Office
The Compliance Office partners with subject matter experts across the enterprise annually to review compliance policies and update organizational changes, align to industry trends, and provide regulatory guidance.
The policies reflect our organization’s ongoing commitment to a strong culture of compliance at Blue Cross and its subsidiaries.
As part of the annual review, the following six policies were examined:
Tara Roberts
Director, Government Programs
NASCO Compliance and Privacy Official
Code of Business Conduct
Corporate Ethics and Compliance
Detection and Prevention of Fraud,
Waste, and Abuse
Health Information Privacy
Data Incident Response Management
Attestation
For 2024, the following updates were made:
Policy Name(s)
Code of Business Conduct
Corporate Ethics and Compliance
Detection and Prevention of Fraud, Waste and Abuse
Health Information Privacy
2024 Update(s)
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Expanded on roles and partnership of People Services with the Compliance Office related to ethics and compliance investigations.
Emphasized confidentiality, non-retaliation, non-intimidation, anonymous reporting, and escalation options.
Aligned language to support the NCQA Accreditation efforts for health equity.
Reordered the Code to begin with useful conflicts of interest content.
Clarified gift card guidance to limit the exchange of gift cards with external parties.
Added three new sections:
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Referenced new Antitrust Policy where applicable, for related questions or reporting please contact (OGCAntitrustQuestions@bcbsm.com).
Third-Party section addresses compliance oversight expectations.
Workforce Member Relations section highlights specific disruptive and unacceptable workplace behaviors.
Non-Solicitation section creates awareness of corporate policy and clarifies non-solicitation expectations.
Each policy has an effective date of January 1, 2024. There were no material updates to the Attestation and the Data Incident Response Management policies.
The updated compliance policies will be available for review in Nshare in the upcoming weeks. For additional information or questions about these changes, contact NASCO’s Compliance and Privacy Official, Tara Roberts at tara.roberts@nasco.com
As a reminder, BCBSM prohibits retaliation against any workforce member who reports in good faith, so when in doubt, contact the BCBSM Compliance Office at ComplianceOffice@bcbsm.com or anonymously at 844-STOP-FWA.