San Antonio Community Hospital Health Care Service Plan

“San antonio regional hospital, a related organization, has a compliance officer who reviews the organization's compliance policies, including its conflict of interest statements, document destruction and retention policies at least annually. The organization's board has an organization meeting every january. At the annual organization meeting, conflict of interest statements are distributed to all board members and officers and subsequently collected by the organization's compliance officer. The cfo who attends all board meetings also reviews the board's conflict of interest statements. If a new potential conflict of interest arises during the year, a new conflict of interest statement is signed. If a potential conflict of interest exists during a board discussion, the board member is required to state the conflict and abstain from any related board votes. Board minutes reflect these abstentions. At least once each year, the organization's compliance officer provides a verbal compliance update at a board meeting and reminds board members of their duty to disclose potential conflicts of interest. The organization follows a similar annual procedure for members of its executive management and department directors, including at least annual compliance education sessions. The compliance program described also extends to the health plan.”

“Although the board has not formally adopted whistleblower and record retention policies, the board of the parent organization, sarh, has adopted them and they are considered to apply to the health care service plan.”

“The health care service plan provides healthcare insurance to the employees of san antonio regional hospital (sarh). Sarh's board appoints the trustees of the plan. The plan does not have any shareholders or employees.”

“The form is prepared internally by the finance department and reviewed by the hospital's cfo. The form is then reviewed by the hospital's external financial and tax audit firm. Following the external review, the cfo reviews the form with the hospital's ceo. The form is then sent to members of the hospital's board audit committee, which includes the trustees of the health plan, for review and approval. The form is then sent to the entire hospital board prior to final signatures and filing.”

“Health plan financial statements, conflict of interest statements and governing documents have not been made available to the public but are available upon request.”