1. 2017 College of Medicine Compliance & Privacy R
2017 College of Medicine Compliance & Privacy R. Brett Short, Chief Corporate Compliance Officer   Richard Chapman, Chief Privacy Officer

2. Code of Conduct 4 component policies A01-030 Conflicts of Interest
A Industry Representatives
A UKHC Members Interactions with Industry Representatives
A Annual Disclosure of Financial Conflicts of Interest

3. Compliance is Everyone’s Responsibility
Unethical
Illegal
Fraud
Waste
Abuse

4. Gifts & Vendor Interaction
Industry Representatives on Campus
No gifts allowed policy
Must register with Purchasing or Pharmacy and wear badge
By appointment only
Not in patient care areas
*See policies A and A01-155

5. Meal Acceptance Example
Meals
Meals received for free from industry representatives or vendors are considered gifts and may not be accepted.
Exception: Meals can be accepted only when they are offered to all participants as part of an accredited continuing education event.
Meal Acceptance Example
Lunch provided during APA conference (i.e., Accredited) and all attendees invited
Industry sponsored dinner after conference, or invited to dinner by industry colleague OK
Not OK
*See policies A and A01-155

6. Stark Law and Anti-Kickback Statute
Related but not the same
Stark Law – prohibits physicians from referring Medicare patients to an entity with which the physician or an immediate family member has a financial relationship
Anti-Kickback Statute – prohibits receiving inducements in exchange for referrals
Contact the Office of Corporate Compliance with questions at

7. HIPAA Privacy

8. Protected Health Information (PHI)
Individually identifiable information plus health information
Held or Transmitted
In any form or medium, whether electronic, paper or oral 

9. Access of Medical Records
UKHC staff will see patients that are well known in the community during their time at UK
Staff should not use medical records other than for treatment or educational purposes
UKHC Privacy will investigate any reported privacy violations

10. This is a Privacy Breach

11. Is this a Privacy Breach?

12. Reporting Talk to your team lead
Call the Office of Corporate Compliance:
Report online ukhealthcare.uky.edu/compliance
Call the UK Comply-Line
See Policy # A for Reporting