University of Maryland Emergency

“The entity is a maryland corporation whose stockholders are physicians and members of the governing body.”

“During the current fiscal year, there have been no changes in the manner in which the governing body is elected.”

“The entity receives a copy of the 990 and a representative of the governing body approves it before signing the electronic filing authorization.”

“As part of their employment by university of maryland faculty physicians, inc. (fpi) and the faculty practices of the university of maryland (pas), employees and faculty are required to follow the medical service plan. Msp policy #37 lists the requirements of compliance and good business practices. As part of the msp policy #37, fpi also maintains a corporate compliance plan, which details expectations around conflict of interest situations and billing responsibilities. Fpi relies on the good faith of its employees in the exercise of their responsibilities. All business judgments on behalf of fpi should be made by its employees on the basis of such trust and in fpi's best interests. Fpi fully respects the rights of employees to privacy in their personal affairs and financial activities. The purpose of this policy is to provide guidance to employees in avoiding situations in their personal activities which are, or appear to be, in conflict with their responsibilities to fpi. Although it is impractical to attempt to define every situation which might be considered a conflict of interest, generally speaking, a conflict exists when an employee's personal interests or activities may influence his or her judgment in the performance of his or her duty to fpi. There may be cases where such conflicts are more theoretical than real, but employees should be concerned about possible conflicts and review and disclose this situation in light of the following guidelines. A major focus of the corporate compliance plan is currently on coding, billing, and documentation compliance and ensuring that regulations are being followed. However, compliance goes beyond avoiding penalties. Our total corporate compliance plan includes a full range of issues, including: -employment contracts -conflicts of interest -patient confidentiality -records retention -contracts and business relationships (including professional service agreements) -waivers of co-payments, coinsurance and deductibles, and more. While the compliance office will make every effort to provide appropriate compliance information to all employees, and to respond to all inquiries, no educational and training program, however comprehensive, can anticipate every situation that may present compliance issues. Responsibility for compliance with the corporate compliance plan, including the duty to seek guidance when in doubt, rests with each employee. The above information is discussed with each new employee and faculty member upon hire. Annual corporate compliance training touches on the above as well.”

“Compensation for each pa president and officer is reviewed annually by the dean of the school of medicine. The compensation discussion includes a review of both base and variable compensation components compared to relevant benchmarks. These two components reflect the total approved salary (tas). Aamc report on medical school faculty salaries issued by the american association of medical colleges provides compensation guidelines in the 25th percentile, 50th percentile and 75th percentile as benchmarks. Once the tas is approved by the dean, it is then sent to the umb campus president for final approval. The variable or bonus component of compensation for clinical activities is managed through a school-wide performance based incentive compensation (pbic) plan. Bonus payments are also approved by the president of umb before distribution.”

“The organization makes its governing documents, conflicts of interest policy and financial statements available upon request.”

“Under the medical service plan of the university of maryland school of medicine, medical services are rendered by the members of the faculty on behalf of the school of medicine in connection with their duties to provide clinical instruction for medical students and other trainees and to deliver healthcare to the general public without regard to the patient's ability to pay for services.”

“The process for selecting the auditors has not changed from the preceding year.”