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tv   Government Access Programming  SFGTV  December 9, 2018 5:00am-6:01am PST

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outpatient services from cpmc to sutter pacific medical foundation. again, information about this change was reported to you during the july and august health commission meetings. there are five departments impacted by this change the first three services have transferred management in august of this year and that includes the breast health mammography center at st. luke's, diabetes center at st. luke's and noninvasive cardiology at st. luke's. two of the five services have not transferred. that includes outpatient psychiatry and diabetes center at the california campus. so during previous hearings, the health commission raised concerns regarding the need for the medical foundation to enter into plans similar to the contracts held by cpmc in order
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to ensure that there is continuity of care for the patients impacted. since the last hearing, cpmc has reported on the volume of patients that have been seen at the three services that have transferred and provided an update on the progress with health plan negotiations. so this information is in the memo you have before you. what is reported that the sutter pacific medical foundation has a plan in place. if a contract is not in place with the plan, they will work on developing letters of agreement with the health plan to ensure that there is continuity of care. while it is our policy to develop letters of agreement, we do know that there were staff training issues identified.
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so some patients may experience a disruption to their services. however, sutter pacific medical foundation is working to assess the impact of this and be sure that the staff training issue is accounted for and corrected for. so at this time -- additionally, cpmc has reported that due to a staffing issue, some patients at st. luke's were unable to see a nongestational diabetes center at st. luke's. patients were able to access this educator at the california campus. so it did involve some commuting for patients. those are the main updates that we have at this time. we believe that change in management will have a detrimental impact if the foundation is unable to secure a contract or ensure that letters of agreement are stated.
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however, if it's not the case there, would not be a detrimental impact. commissioners, i know how of a draft resolution before you. warren browner, c.e.o. of cpmc is here and can answer any additional questions. >> dr. browner, would you like to make some comments? or your staff will? >> i will make some comments. >> dr. browner has been referred to an appropriate person. >> it's been transferred to me. i'm happy to see you again to let you know that we've secured the letters of agreement with hill physicians and as the pay for performance measures, we reach out to those who have not had their mammograms, pap spears, we've sent out letters to all who are due for their
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mammograms, so people we've served before who may have gotten caught in the shuffle. we've sent out letters in english and spanish. that's working well. we've continued to grow our diabetes program. we have an educator at the other campus so people won't have to commute. those that did have to commute, we offered them transportation. so i would say that having done many, many moves in many places, it went well and i have to commend, yes, my staff, karen, operations director, who has done a really human job to make this work well for our patients. as we spoke before, as you know, patient care is really moving outside. most diabetes care is done outside of the hospital. it's less expensive. it's less difficult for patients
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and we're pleaseded to offer that to the citizens of san francisco. thank you. any questions for me today? >> thank you. >> i think there's a question on the end. >> yes. >> thank you for your update. did you say with the letters of agreement that the health plans have agreed to the letters of agreement? >> yes. >> with all the patients? >> yes. >> so there is no disruption? >> there was a brief disruption -- >> no continued disruption? >> no. and we've outreached to all patients that we cared for before that are due for their mammograms. >> did you have a question, commissioner? >> hill's physician group -- >> we're working on the contract with them. in the meantime, we have a letter of agreement.
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>> there are public comment requests for this item. >> waiting for our presenters and our guests to complete their presentations for us. >> we will then proceed with the public testimony. dr. diedel, dr. barnes, michael lions, and lydia montono. each has 3 minutes, please. >> good afternoon. i'm karen diedel, primary care physician at 899 valencia. i speak spanish. i would not say that the transition from the st. luke's diabetes center -- >> could you speak a little louder into -- or maybe raise the micro phone up, so everybody can hear you in the room? thank you. >> good afternoon. i'm karen diedel. i'm a primary care physician at
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899 valencia. i speak spanish. i do not think the transition in the st. luke's diabetes center has gone well. previously the st. luke wes diabetes had 3.6 full-time positions between nurses and nutritionists. now there's a 1.4 f.t.e. there. that's more than a 50% reduction. before there was .1 f.t.e. medical social worker. that bit of time now is at the cal campus. i knew nothing about any transportation for patients to get to cal campus the diabetic r.n. mainly sees pregnant patients. all other diabetic patients, nonpregnant patients, to see a
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diabetic r.n. have to go all the way to the cal campus in the richmond, which is way too far and it simply does not happen. previously, the -- there was a diabetic r.n., spanish speaking, who could see patients on the in-patient side, and then help them to transition to the outpatient side, right there at st. luke's. she only has one day a week way over at the cal campus for the outpatient teaching. she's out sick currently and there's no coverage for her and that's the only spanish-speaking r.n. she was a critical bridge for patients because you can imagine if they saw her in the hospital, they were much more likely to see her on the outpatient side right there at st. luke's. if they have to go to the c
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cal campus in the richmond, it doesn't happen. many of my patients are older, don't speak english. they depend on family members that may be working two jobs to get them to the californ campus it doesn't happen. i feel like the diabetics south of market have been abandoned, particularly the ones that are most vulnerable, the ones with the most difficult time getting transportation all the way to the cal campus in the richmond. they simply don't go. and so i have many diabetics right now who are out of control, being hospitalized. i would ask the question -- >> time. >> you can complete your sentence. >> i would ask the question -- is this to fill st. luke's hospital with sick diabetics so van ness hospital can be filled? >> thank you.
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next, please. >> my name is kevin barnes and i work with the san francisco annes for housing and justice. i feel frustrated coming to you again about the diabetes center at st. luke's. it leaves a very bad taste in my mouth. sutter says the number of hours of diabetic education at st. luke's is the same as before, but that's not true. as dr. diedel said, in the past, there were 3.6 f.t.e.s and now there are 1.4. you heard several months ago from cpmc that they were hiring
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more educators at st. luke's and now the number is down again. this is deceitful, disappointing and unprofessional and it hurts the care of patients at the st. luke's center. at valencia, there's an r.n. educator three days a week, doesn't speak spanish, and mainly sees pregnant diabetics. they use the phone service. they have interpreters sometimes. yes, it means the class standards, but it isn't the most beneficial way to deliver care, particularly to mono lingual patients and those who are less educated. in fairness, this coming january, there is supposed to be another diabetic educator, a nutritionist, not an r.n. at valencia. it's not clear how much time he or she will have. we're told that he or she knows basic spanish. it's not enough to meet sutter's
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policy of being certified to conduct appointments in a language other than english. in room 802 where the new center is located, there are no diabetic education classes. when it was located in the second floor of the hospital, there were classes. the only possible space for classes is the waiting room at 802 and it's impossible. the sweet success diabetes center for pregnant women were maternal fetal is located is modern and spacious compared to the 802 room. sweet success is not lost on me. juxtapose that with 802 in the top floor. patients at the st. luke's diabetes center are seen as second class and forcing them to
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go to the california campus for their care emphasizes that attitude. because the dietician and r.n. are not paid for phone calls with patients, they're not using this method of follow-up. patients miss appointments and educators have a hard time calling to reschedule. because they're not reimbursed much for visits, it appears that -- >> time. >> directing of visits to a shorter time and the visits are too short. education takes time and more so with mono lingual patients. one last thing, my wife and i are moving to miami in one week, where we'll be closer to our daughter and three grandchildren, as well as our other grandchildren in
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nashville, chicago and upstate new york. i want to thank you for your kind attention over the years and to tell you how much i've appreciated your hard work. if you know of any healthcare issues in miami that need to be kept honest, please let me know. thank you, again. >> thank you, dr. barnes. and i envy you moving. thank you. >> i really can't add anything more to what the two doctors have said. it's obvious there's huge, huge cultural competency issues involved in this transfer and particularly the issues of the diabetes care at st. luke's points it out in glaring detail.
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most of the programs were developed very locally to meet local needs and to transfer them over to the -- to transfer the management over to the california -- the northern california-wide sutter program would completely eliminate all the work that had gone into develop these local programs. and in addition, prop q's powers have no enforcement. at least they have oversight and for that -- to allow clinical programs to be removed from your oversight would allow them to get away with more of what you've been hearing about up to now. >> thank you.
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>> hi. i am with senior disability action coalition. right now my heart is pounding really hard. as a person that had her family impacted by diabetes. all i see in this program is very classist and racist move from a hospital. i say it this way because it's not something that you don't know about what the gentrification has done to the mission. and so now these people, latinos
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are at high risk for diabetes and many of us have diabetes. so how can you remove a program that is helping the community? and not put in place something else? and expecting the people already affected by a chronic problem to travel across the city. we know that now because of uber and lyft and because of many, many other issues in the city, commuting time is so hard. you think that older adults will be having the time to do that? i don't think so. so, please, think about your decisions and think about who
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will be affected. thank you. >> thank you. that ends the public testimony, as i have before me. we'll then proceed to commissioners' questions and discussion. commissioners, you will note the revised resolution, which is immediately under and it's 18-5, the prior revision. are there questions from the commission or would the commission like to place the resolution before us for discussion? >> i'm sorry, this actually pertains to what we're discussing today, again, it's still hard to conceptualize that
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st. luke's is no longer the st. luke's three and four generations of san franciscans knew. and i know we have the new mission campus. we had an opportunity to visit it. to see the new facilities, etc., etc. but the quality and spirit of st. luke's remains there, folks. the astounding part to me is, within three blocks, you have the hub of what's left of the latino community in the mission district. and it represents the industry part. but on mission street between 24th and st. luke's, there is program for spanish-speaking elderly, mission cultural center, which was an old warehouse, and now it provides all sorts of cultural program for children all over the city.
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it provides free nutritional. it provides educational programs. and across the street, you have our mental health services, which used to be a funeral parlor. for the last 20 years, it's been providing mental health services for spanish-speaking families. but folks in the mission had the great pride of, which is st. luke's. if you wanted someone to find out about what programs are available in the mission, you knew somebody at st. luke's. it's still that way. one of my sons was born at st. luke's. you say, wait, what's going on here? to me, instead of making it part of the new facility, st. luke's lamp is going smaller and smaller and smaller. i mean, you put -- we have --
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your foundation is on valencia street, 20th almost. nice place. you always see people stop in there. people stop to read, to pick up coffee. couldn't you have diabetes classes there in spanish? i don't know. i've never been in there. isn't there some way creatively we can think about providing these f.t.e.s and have -- a lot of the foundations in the mission would even help out, i'm sure. everybody is going through the changes, but there's still -- what i'm saying is, the spirit of st. luke's, the light -- it's like the general. the general has been there for years and years and years. one other comment. dr. ken barnes, i knew him when he was a resident and i was faculty at san francisco general and ken was a resident and he
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wanted to go to st. luke's and set up a collaboration to provide comprehensive services for minorities and spanish-speaking communities and he went there and he provided the leadership and the collaboration to focus on the unique needs. this is the first time -- pardon me, dr. barnes, i've heard you are leaving, going with your family and god bless you. but this is somebody who really lit the candle to make sure that the programs would expand and the quality would be there. right after that, it was a young pediatrician, richard sanchez, who sat on this commission, one of the first ones, at st. luke's and they provided multiple programs. don't lose that. don't wipe that -- i mean, in front of st. luke's is still the
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plot of the library, oldest in california. now it's over at berkeley and has all of these things going on. but st. luke's is still there, and people in four and five generations -- we don't want to go back to all the hearings we've heard. we've seen families come from all over the bay area, saying they would be driving night and day to take care of the elderly there or young brother or sister being treated with dignity and respect and quality of care because of st. luke's. when you had the nursing school, st. luke's was tops. think of it creatively. diabetes is one of our major illnesses in the latino population and others. let's address this. even with the kids. we could be doing it from the schools, right down from you,
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another two blocks, early childhood education program. named after the first puerto rican woman administrator because of her commitment to women, refugees and health of kids. she died of diabetes. what i'm saying is -- and the school was named after her afterwards. everybody says, we need more education. where? you folks are right down the street. the kids could walk there. let's think of -- we're not saying, you know, the ship's dead. we're saying, let's revisit and think about, you know, the unique families and immigrants we have coming to our unique city and let's provide them with the highest level of care. hill's is a good start.
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they have a number of spanish-speaking physicians. all these things could be combined and could really provide -- you could be the flagship of what could be divided in communities like the commission district, campus of san francisco. but st. luke's will still be there. i encourage you to think creatively and think about what that hospital meant and continues to meet to many of our families, immigrant families, who come from san francisco and those who have been here for four, five, six generations. it makes a big difference. >> thank you. commissioners, perhaps we can get a clarification from the foundation because under the report that we are being given here, it says that the st. luke's diabetes center will resume to the same level as
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under cpmc management. do you want to elaborate on that? >> good afternoon. st. luke's campus diabetes program, we took over august 5. and we provide the same level of services. we -- there were some comments made about staffing. we have tried to pair the staffing and we're hiring full-time additional educator that speaks spanish as well to join in january. so we'll be adding more staff to the diabetic program. and we're offering more -- we'll have more opportunities to do some cross training when the cal diabetes program transitions. so we'll have a broader team to support the populations. >> okay.
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>> do you have any solutions -- >> i want to say thank you for your idea about having classes at the center. i think that's a great idea. if there's opportunity there, that's great. certainly we're always looking for places to have classes and to have outreach. and i would just say that my father died very young of diabetes, 59. and i did not grow up with a silver spoon in my mouth. i started military, worked as an l.b.n. and then r.n. and worked and went to college. so i understand that it takes a lot to get ahead and move forward. so i do resonate with the concerns. >> thank you. commissioner loyce? >> i have a couple of questions. one is, if the statement by dr. leidel is accurate that went
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from staff of 3.6 f.t.e. to 1.4 and now you are suggesting you will hire another one, the numbers don't match-up for me. can you help me understand the numbers? and the other thing that you have indicated is that there is transportation available. how is it made no en-- known to the patients? >> thank you. there are 1.6 f.t.e. that are currently at the mission campus supporting the diabetic program. we cooperate and collaborate with the cpmc cal diabetes program and try to do some cross-coverage with staff until we can get the whole team together integrated under the foundation model. we're adding 1.0 additional
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f.t.e., so it will be 2.6 f.t.e., january 7, with the addition of another educator coming from the cal campus. >> so there was not 3.6, as indicated? >> no. there's the two individuals that are supporting the outpatient, primarily based at mission and have remained there. and we have hired them at spmf. i'm not sure where the 3.6 is coming from. >> and the other, transportation that's made available? >> we have over the course -- since taking over, we had a few patients that could not -- that were nonpregnant diabetic patients and we offered them lyft rides to get there for the services. >> is that universally known to
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the population? is it specializes between a provider and the patient only and not broadcast? >> it's not broadcast. we've done it over the last 2 1/2 months. >> thank you. >> any other questions? if not, i think you will have ms. patil explain the revise resolution. >> so the revised resolution 18-5 that you have before you, the title reads, "determining the impact of the change in management of five outpatient departments from california pacific medical center to sutter pacific medical foundation." the other edits are on -- begin on the 3rd page of the resolution and it reads, second to last further resolved, that
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the change in management will have a detrimental impact on healthcare services unless spmf takes the following actions. secure contract with hill physicians or continue to execute l.o.a.s so no affected patients experience a disruption of services. proactively ensure adequate staff training to prevent disruption of services. and provide culturally, linguistically appropriate services for patients with nongestational diabetes. be it fully resolved that the health commission encourages spmf to develop l.o.a.s when needed and update the commission to patients needing care at the clinics and departments. >> thank you.
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and you retained the first resolve to strongly encourage the changes in staffing models or a mix, is that right? >> yes. >> to those are the three resolves. thank you very much. commissioners, questions to ms. patil or a motion in regards to the resolutions? hopefully we can start with the revised resolution. is there a motion for placing it on the -- >> place it on the agenda the revised. >> is there a second? >> second. >> and there's a second. so further discussion of the resolution? >> i was going to ask if
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dr. barnes could have a comment seeing that he put in all the years out there. if that's available through the chair. >> in regards to the resolution or -- >> the issues of -- >> can you step up to the microphone? >> sure. dr. barnes would like to add his interpretation of the numbers of the f.t.e.s. welcome. >> there were 1.6 f.t.e.s within the last year, year and a half. i remember talking to dr. browner in the hallway after one of the hearings and he said they were hiring two full-time bilingual educators. and they happened to be filipinos.
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and so that was where the 3.6 came from. i don't have any idea where the filipinos went, but that's what -- where that 3.6 figure comes from. i just want to clarify. >> sure. thank you. and we wish you well in your retirement. commissioner guillermo? >> i wanted to make sure that -- and just for the record, i wanted to voice support for dr. sanchez's comments about really trying to have creativity put in place and in consideration of just the rapid changes in neighborhoods that are happening in san francisco and in the generations of reliance that people have had.
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i know that delivery systems will change, but it doesn't necessarily have to be so object objective a process. it will be a situation of the history of san francisco, its communities, and how it gets impacted for the future, while still accommodating the future, really becomes part of a principled process of decision making. and then, too, the community in little haiti outside of miami could use your advocacy. if you are not aware, and i'm sure you probably are, find your self there. >> commissioners, further discussion of the proposed resolution, which has been placed for us.
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>> i have one more comment. no matter how much gentrification is done and people are forced out of san francisco, particularly people of color, some folks who are needy will always be here and the commitment needs to be to address those needy populations. if you're not doing that, i have difficulty with your organization. so i need to make it clear and support dr. sanchez and there will be us here and y'all need to respond to us. >> also note, the final resolve action point is what was discussed earlier, by moving hospitals, the commission loses oversight on the types of services that were within the hospital and we really are not only encouraging the help, but that you would take it as good
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faith, to say that you would give us an update as you bring all your educators, you can be assured that as we are continuing the development hearings on an annual basis that it would come up at that point that i would encourage that you voluntarily present to us a report probably within six months of suggestion as to how well the transition is going. and whether or not the community feels that -- and it gives the community a chance to work with you. i thank you for some good suggestions in which we're trying to encourage that the community and the foundation would start a new relationship and feel that they are being served and you feel satisfied and that you are serving them as
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you articulated to us already. if that -- are we prepared for the vote? let's have a vote. all those in favor of the revised amendment -- well, proposed resolution, please say aye. opposed? resolution has been passed. thank you very much. >> thank you, commissioners. >> clerk: item 9, sfdph compliance training. it's the same presentation in your packets and there are some notes that i gave you on the right of your desk.
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>> good afternoon, commissioners. i'm maggie rykowski, department of affairs and chief integrity officer and i'm here to give you an overview of our compliance program. we're here to ensure that our governing body is aware of the compliance program. so i will briefly give you an overview. so these are the topics that i will go over. i will start with our mission. we strive to support a culture of compliance and our program is in accordance with all federal and state standards and regulations and we do follow the office of inspector general's seven elements for compliance
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program. so -- >> that's the federal -- >> yes, the federal guidelines. the office of the inspector general has guidelines of what elements need to be incorporated into an effective compliance program. there are seven elements and we follow all of those. and i will -- so i will go over each element and let you know how we meet those requirements. so the first element, have to designate a compliance officer. i'm the chief compliance officer for the department. and i have one at sfg. as well as laguna honda. and behavioral health. and i will be adding a compliance officer for population health. we also have compliance committees. each has their own committee and
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we have a d.p.h. compliance committee as well. our policies and procedures, we do have comprehensive policies and procedures that are reviewed and updated as needed. and we also have a very comprehensive code of conduct, which i will be speaking to in a little bit. for providing education and training, we do provide a lot of education and training. in january, we are actually going to be providing a robust training module for compliance. we're going to combine our compliance and data security training into one module and it will be interactive and we're excited. we've worked the entire year on putting this together with a vendor. that will be rolled out in january. we also do other training. we'll do trainings, for example,
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if we notice there are providers having issues with documentation. we'll do specific training for them. we also are going to be rolling out a compliance newsletter that will be dealing with compliance topics that we feel need to be paid attention to. we'll outline them in our compliance newsletter. for element four, lines of communication, we have an 800 number, a hotline, where anyone can actually call with any issues, problems, concerns, anything they want to bring to our attention. we also have a confidential email where they can email us and this is monitored throughout the day. for element five, our internal audit, we do a tremendous amount of internal auditing and
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monitoring. at the beginning of the year, we do a comprehensive assessment, risk assessment, to outline what risks we could have for the year and have a developed work plan and this is done for each area for zfg, laguna honda and behaviorial health. and we do robust auditing. throughout the year, we will do proactive auditing open our charts to ensure they meet compliance standards. for element six, our disciplinary guidelines, we work closely with the department of human resources to ensure when there is an employee who is involved in a compliance issue and discipline is warranted, that that discipline is done correctly and uniform throughout the department. and element seven, response to
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offenses action plan. when something is brought to our attention, we investigate it immediately. we will look, if needed. we will take action to correct the problem. and we do develop corrective action plan and training for the staff to ensure it does not happen again. 5 want to touch on our code of conduct. so our code of conduct is a framework. and we recently expanded our code of conduct to make sure it meets all the elements that are required. our code of conduct was a few pages. our new code of conduct is 20. and we also have a summary form that will summarize the key points for staff. so the elements of the code of
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conduct are as seen on the slide. we will basically, you know, bill for services that are provided. we don't want to bill for things that we did not provide services for. we don't want to overbill. access to care. we're fully committed to providing our clients and patients access to quality and medically necessary healthcare services. business -- we conduct our business ethically and we want to ensure that we're honest in our communication and we maintain confidentiality of all patient-related information. and for workplace conduct, we strive to provide a productive, healthy, safe work environment where everyone is treated with dignity and respect. and conflict of interest, which involves any circumstance where an employee has a personal,
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financial interest that may improperly influence the performance of their duties and we make sure that we work hard to make sure that our employees realize the conflict of interest and what they need to do to ensure that there is no conflict of interest in their business practices. as our governing body, there are -- the federal government believes the governing body is ultimately responsible for compliance of the organization with rules, regulations and laws. and i know the health commission, you are involved in our operations at d.p.h. this is through the j.c.c., your committee meetings. i do come annually to give you information on our compliance activities for the year. and so i feel that that we are meeting the standard. so there are three really key
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laws that we need to follow. the false claims act, a federal statute that sets out criminal pep alts for falsely billing the government. the medicare reduction act. and we're required to have written policies applicable to employees that address fraud, waste and abuse and we do have those policies. and the fraud enforcement and recovery act. and that is an act that expanded enforcement provisions for the false claims act. so i'll touch very briefly on our reporting compliance concerns. it's a duty for standards, to understand our program, scope of practice, and to understand what they can do under their licen
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licensee. it may have a conflict of interest, actively participate, and it includes annual mandatory compliance training. build and maintain a culture of compliance. and this is something that we really strive for. prevent, detect and respond to problems, so it's everybody's responsibility and prevent retaliation. we have a very active whistle-blower program and one that we have people bringing concerns to us and ensure there is no retaliation. and the d.p.h. employees, our contractors, affiliates, anyone that does business with d.p.h., they have a beauty and responsibility to report misconduct.
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we thoroughly investigate every issue brought to our attention. what it is completed, we'll look to see if it's valid. we'll take corrective action. and it could have an employment, could be corrective discipline with an employee if there is deemed it's misconduct. and some potential consequences of violation, you know, lots of eligibility, which would be detrimental to the department. reduction in reimbursement rate rates. and in closing, this is our poster that we have posted throughout the organization that we really encourage staff to
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call our number. they can call the 800 number. they can email us if they suspect any misconduct, if they have any compliance, question whatsoever. we're available to assist them because we want it ensure that we have a tight and robust compliance program. >> thank you. thank you very much. could you remind us when you normal normally would compile -- would it be calendar year or fiscal year? >> i believe we've done calendar year. >> and you are recommending that you tip to do that? >> yes, absolutely, yes. yes. i think it's really important
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that you can see compliance issues, concerns. anything that has to do with compliance, i believe it would be beneficial for the health commission to be aware of that. >> we do have that calendared as a regular report? >> yes. >> as you're discussing the compliance officers that you have in different areas, what about other areas such as within primary care or the jails? >> primary care is handles by dsfg as well as the jails. they cover the other areas of the health department. other areas of the health department are covered. and then i will -- as i said, i will be bringing on another compliance officer for population health. currently, i have my other compliance officers that will cover population health.
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i'm bringing on a compliance officer, who will focus on population health and then we'll look at other areas of the department that some of the duties can be assigned to that person as well. >> okay. and what about within contracts? central offices? >> if there are any issues brought to our attention, if it is the contract office it, would come to me and i would be working with craig wagner and be sure that we'll look into it. >> commissioner guillermo? >> thank you. i was just wondering how the compliance training gets
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received or throughout the department. oftentimes people don't really pay as much attention to the training or they don't take it as seriously or it's not as -- it's not something that people understand the connection of and just wondering what the orientation is. >> our current -- what the training we've had previously, it was a power point slide. and, you know, we identified -- we didn't feel that staff would take it very seriously. they would click through the slides quickly. what we did was, we were able to work with the controller's office -- we got some funding, so we could develop a more robust, comprehensive training module that is going to be very interactive. it will be much more engaging. you will not be able to click through it quickly. you will actually have to
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participate in the training. and this will all be -- it will all be on our e.l.m. education platform. we'll be able to closely monitor who has taken the training, who needs to take the training. so i really believe in january when we roll out this new training module it will be -- our training will be much enhanced. >> if i could add to that, commissioner, we've been thinking about that question quite a bit. so in addition to the improved training module, as we roll that out in addition to that, we're going to be doing additional program of communication about the role of that training in our operations and the importance of it from the perspective of the individuals. so that will be going through our management teams. we'll have an additional
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refurring bulletin that goes out. they have one on privacy. we'll be adding additional message on compliance, where we can highlight. so in addition, we're trying to work on improving the organization organizational culture with attention to compliance and privacy. >> given the concerns about cyber security, is that a separate consideration? >> we do have in our module some data security. there is data security, yeah. there is data security, and then i believe that there is going to be for a more comprehensive --
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>> yeah. so as we roll out the e.h.r. starting this spring, everybody who touches that e.h.r. will have to go through a separate training program related to the e.h.r. so that will be in addition to and complementary of the compliance training. so as part of that, we'll have defined roles and responsibilities. it will be tailored to each individual section. and so, obviously, privacy and protection of data is a huge component of it. and it's one of our hard rules, that nobody will have access toss that e.h.r. until they have completed the training. >> so what i'm suggesting, because some new programs will be rolled out and programs that you've been describing, that along with the annual report, a
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progress report on where we are, because many of these are in process. and let us know how it's going. and i'm wondering -- there are training modules that the hospitals have had and in training units. are we going to make use of those as part of the program or are these special compliance lectures that are more in person? >> in addition to our training module, which is -- you sit down on a computer and you do it -- and you can -- you don't have to be all in one sitting. you can do part of it because it's over an hour long. it's very comprehensive. in addition to that, we do
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on-site training. if we identify there's an issue, for example, say, in document asian. that we notice that there is the document asian not supporting the billing codes being used, we will go and do on-site documentation training. we do that now for privacy. everyone does the privacy training and we do in-person training that's tailored to meet the needs of the department. so it will go to a unit, like, say, one of the outpatient clinics, for example, or an in-patient area at the hospital and do training that is specific for them. so everyone takes the general training and then we do specific training that are more tailored to the work area. >> so recently, there's been a lot of discussion about the conflict of interest issue.
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is there a special training in regards to what that really means, very complicated area? >> yes. >> so we definitely cover conflict of interest in the compliance training. so that's one of the elements of it. in addition to that, it's part of what i was describing in response to commissioner guillermo's question, in that part of our compliance program, we'll be doing a series of trainings on conflict of interest in particular. so we're working between compliance and privacy affairs office, myself, h.r. and city attorney's office to do an additional training to targeted groups and we will also use this compliance bulletin, this recurring communication that we sent out to highlight issues of conflict, to make sure that people know what the rules are, but more importantly, who to ask
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if they have any questions or if they see anything that they want advice on. >> commissioner sanchez? >> i think this really defines an area that is -- will be addressed and will continue to be pertaining to our due diligence. the question i'm not clear of yet. in the past, many of the commissions were assigned, including ours, attorneys that came from the city attorney's office. and we were billed on that. now we have a multitude of attorneys assigned to the health department, joint conference committees, etc., and i know other commissioners are saying, we're getting more attorneys, etc. so what i'm trying to think of, you know, as we proceed with our own department of public health due diligence model, is there some point i

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