Effective Date: June 2, 2008

Dear Valued Employees and Vendors,

A primary element of our Code of Conduct is billing and coding compliance. We have in place policies, procedures and systems to facilitate accurate billing to government payers, commercial insurance payers, and patients. These policies, procedures, and systems conform to pertinent Federal and state laws and regulations. We prohibit any colleague or agent of HCA from knowingly presenting or causing to be presented claims for payment or approval which are false, fictitious, or fraudulent.

I have enclosed for you a newly drafted policy and procedure, which will take effect January 1, 2007. As with our Code of Conduct, the Deficit Reduction Act of 2005 requires all Medicaid recipient entities (HCA facilities) to develop and distribute policies, such as this one, outlining federal and state false claims acts, as well as information regarding whistleblower protections and the entities’ policies to reduce fraud and abuse.

I would like to remind you that each hospital, surgery center and clinic has a designated Ethics and Compliance Officer available to discuss any potential violation. Also available to you is our Ethics Line at (800) 455-1996. Thank you in advance for taking the time to read this policy.


Marie Crockett
Division Ethics and Compliance Officer
(816) 507-5621