Integrity Standard - Accuracy of Records

Policy:
We will keep accurate, true and complete Company records. Accuracy and reliability in the preparation of all business records are mandated by law and are of critical importance to the Company’s decision-making processes and to the proper discharge of our financial, legal and reporting obligations. We must never misrepresent facts, falsify or suppress records. In addition, all records should be stored for the period of time required by applicable laws or contracts or Company policy, whichever is longest.

Recordkeeping and Reporting
We must ensure that all Company records, business expense accounts, vouchers, bills, payrolls, service records, and reports, whether electronic or on paper, are reliable, accurate and complete. Transactions between the Company and outside individuals and organizations must be promptly and accurately entered in Company records in accordance with Company policies and procedures. We will not improperly alter or make false entries on, or willfully fail to make correct entries on, any Company record or document. False or misleading entries on records are unlawful and could subject the Company and, in some cases, individual employees to fines and other civil or even criminal penalties. In addition, we will not facilitate the creation of false or misleading records of any of our covered groups, vendors or any other business partner.

We will create and submit only true and accurate reports. We must not create or submit false or misleading reports of operating statistics or measurements, such as sales reports, performance data and utilization data. If we are not sure of the accuracy or reliability of information, we must take steps to verify it or immediately contact our Supervisor for advice.

We will establish, maintain, support and follow internal controls designed to provide reasonable assurance that transactions are authorized, and that transactions and other data are recorded and presented in a manner that is accurate, complete, current and not misleading. We will record all Company transactions in accordance with generally accepted accounting practices and principles or statutory accounting principles. We will charge all items to the appropriate account, regardless of the financial status of the line of business, contract or cost center. We will not maintain any secret or unrecorded funds. We will follow appropriate Company procedures to ensure that errors are corrected, as they become known, through credits, refunds or other mutually acceptable means.

We will never take any steps that would impede, obstruct, improperly influence the conclusions of, or affect the integrity or availability of any audit, review or investigation, regardless of whether that audit, review or investigation is performed by government, external or internal personnel.

Record Retention
We will preserve and maintain Company records in accordance with the Company’s and department’s document retention policies. We must not improperly destroy any corporate accounts, records or other official Company documents.

When litigation, a government audit or investigation is imminent or pending, our normal document destruction procedures will be suspended until all documents relevant to the litigation, audit or investigation can be identified and segregated.

Questions & Answers

Q. I am concerned about the accuracy of the reports we are providing to some of our large groups that have performance guarantee requirements. What should I do?
A. Discuss your concerns with your Supervisor to make sure you understand the reporting requirements. If you are not comfortable doing that, or if you still have concerns after talking with your Supervisor, contact the Legal Department or one of the other Corporate Resources. The accuracy of information we provide to groups is a very important matter. Many of our larger groups routinely exercise their right to audit the performance guarantee results. A misstatement or misrepresentation of the results could damage our reputation and relationship with the group. False reporting to either government or private plans may subject the Company and individuals to civil and/or criminal liability.

Q. How will I know if a document that is scheduled for destruction under Company policy is relevant to pending litigation, investigation, or audit?
A. When the Company becomes aware that such a legal proceeding, audit, or investigation has commenced, or is imminent, the Legal Department or the Compliance Officer will circulate a memorandum identifying which records and documents are relevant to the pending legal proceeding, investigation, or audit and may not be destroyed. As more information becomes available, the Legal Department or the Compliance Officer will inform departments as to which, if any, of the previously identified documents may be destroyed. If you receive information regarding a potential government investigation or audit, or litigation to which the Company is a party, promptly notify your Supervisor or the Legal Department.

Q. If I need a certain record for a point past the scheduled destruction time, should I retain a personal copy?
A. Most, though not all, records will be destroyed in accordance with a specific schedule; this schedule depends upon a number of factors, such as legal and business requirements, whether the document contains business information or patient medical data, and the like. Ordinarily, you should not keep personal copies of documents scheduled for destruction. If you believe that a certain record or category of records should be kept for a longer time, notify your Supervisor.

Q. We are in the process of closing with a large group account. Our contact with the group has indicated that it would ‘seal the deal’ if we would delay the first months billing by 30 days so that they can show a large profit in the current month. The billing would be recorded appropriately on our books. Is this allowable?
A. While our financial records might be stated correctly, it is never permissible to knowingly assist a current or potential business partner to misstate their reporting. There have been a number of cases where regulators have targeted not only companies with inaccurate records, but also third parties who facilitated the misstatement. This situation should be discussed with your Supervisor, or reported to the Corporate Integrity HOTLINE.

Q. I have been asked to sign a certification that a financial report I generate is accurate. Is this important?
A. Yes, report certifications are very important. Certifications demonstrate HCSC’s commitment to the integrity, accuracy and timeliness of its reporting and related disclosures.

Report certifications:
• Establish a written record to support the accuracy and completeness of reports.
• Document that data or information submitted has been reviewed and is accurate to the best knowledge of the certifier.
• Encourage disclosure of any issues via the "Exceptions" section of the certification.
• Provide a vehicle for feedback to management on identified exceptions

Certifications are submitted to Audit Services, which acts as the administrator for Financial, Government and Performance Guarantee report certification programs. You may also be required to provide the Company with other types of certifications. If you have any questions about the report certification process, contact the Vice President of Audit Services or another Corporate Resource.

Q: What should I do if I have questions or suspect problems with some aspect of our financial reporting or internal accounting controls?
A: Always remember that the accuracy of our financial statements & records and the proper functioning of our internal accounting controls is essential to the Company. Discuss your concerns with your Supervisor to make sure that you understand the applicable accounting or financial reporting requirements. If you are not comfortable doing that, or if you still have concerns after talking with your Supervisor, you should contact the Compliance Officer or another Corporate Resource. You may also use the Corporate Integrity HOTLINE to anonymously and confidentially report your concerns regarding financial reporting, internal accounting controls, or auditing matters.

Q: What should I do if I have completed a financial report and someone wants to make some changes to that report which, in my opinion, will result in less than accurate information?
A: Discuss your concerns with your Supervisor to make sure you understand the reasons for the proposed changes. If you are not comfortable doing that, or if you still have concerns after talking with your Supervisor, you should contact the Compliance Officer or another Corporate Resource. You may also use the Corporate Integrity HOTLINE to anonymously and confidentially report your concerns regarding financial reporting, internal accounting controls, or auditing matters.

Remember, if you do not understand, or if you have any questions concerning, this Integrity Standard or any other part of the Code, contact your Supervisor, a higher level Supervisor, any of the Corporate Resources or call the Corporate Integrity HOTLINE (1 800 838-2552).

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