Integrity is our foundation. To protect CDS and its employees, partners and customers from incidents that may result from corporate misconduct, we have a strong focus on ethical conduct and compliance. All CDS associates contribute to the success of our compliance program with active participation and commitment. We know it’s critical to our continued growth and success as a company and to our customer's success as a client.
The CDS compliance program is structured based on guidelines established by the U.S. Sentencing Commission and the Department of Health and Human Services Centers for Medicare & Medicaid Services. This includes requirements for:
- Written policies and procedures (code of conduct)
- Designation of a compliance officer and a compliance committee
- Training and education
- Effective lines of communication with processes for receiving allegations
- Auditing, monitoring and investigations
- Enforcement through consistent disciplinary action
Initially, we present a compliance program summary to all new employees and contractors. Our chief operating officer issues each new employee and contractor a personally signed letter explaining our compliance program, its purpose and various mechanisms for reporting suspected violations of our code of conduct, including anonymous reporting capabilities through an independent hotline company. Additionally, new employees and contractors must have security awareness training, which includes training related to the Health Insurance Portability and Accountability Act (HIPAA) prior to accessing any of our systems.
Within the first 45 days of employment, CDS employees and contractors attend a two-hour class further detailing our compliance program, its relationship to various federal laws and our corporate policies and reporting mechanisms. Each year after the initial year of employment, all employees and contractors attend a compliance refresher course.
To prevent any conflicts of interest, the compliance officer has a direct reporting relationship to the CDS Board of Directors Compliance Committee, which actively oversees all compliance initiatives and investigations.
Our Values – Our Code of Conduct
CDS has established a foundation of values embodying a culture of ethics and compliance. Our code of conduct, Our Values, defines compliance-related laws and policies and includes seven values that are intertwined throughout our daily business processes:
See more information on Our Values.