The ethics and compliance program's foundation rests on the support of several committees and individuals both at the corporate level and within the facilities.

Corporate ethics and compliance officer

Kathi Whalen serves as Senior Vice President and Chief Ethics and Compliance Officer for HCA Healthcare.

Learn more about Kathi


Ethics and compliance officers (ECOs)

Company-affiliated facilities and divisions have ethics and compliance officers (ECOs) to oversee and implement the HCA Healthcare ethics and compliance program, and to oversee the facility or division's compliance with the requirements of federal healthcare programs.

We have developed ECO guides which provide information, resources as well as tips on how to effectively oversee the ethics and compliance program in a hospital, an ambulatory surgery center or service center setting. A copy of the Hospital ECO Guide is available and can be requested by completing a brief form. In addition to the guides, Facility ECOs are provided with comprehensive training and ongoing education regarding their responsibilities.


Responsible executives

Responsible executives are individuals within the corporate office who have been identified as the subject matter experts in particular areas of compliance risk, and who are responsible for those areas.

Area of Compliance Risk Responsible Executive Name
Americans with Disabilities Act – Access to Services VP, Chief Diversity Officer Sherri Neal
Americans with Disabilities Act – Physical Access VP, Construction and Equipment Clint Russell
Americans with Disabilities Act – Physical Access Director, ADA Program Rodney Harris
Antitrust VP, Legal and Corporate Secretary John Franck
Aviation Director, Corporate Aircraft TBD
Behavioral Health President, Behavioral Health Svcs Eric Paul
Billing VP, Regulatory Compliance Gail Garrett
Case Management VP, Performance Improvement and Case Management Kathy Smeykal
Clinical Investigation and Research VP, Compliance Research David Vulcano
Coding VP, Regulatory Compliance Gail Garrett
Collections CEO, Revenue Cycle Point Solutions Shannon Dauchot
Core Measures and eCQMs VP, COG CFO Michelle Cotton
Cost Reports AVP, Reimbursement Operations, Government Programs Angelo Pagano
Credentialing and Privileging AVP, Office of Professional Practice Advancement Susan Goodwin
Data Science and Data Integrity VP, Chief Data Scientist Edmund Jackson
Electronic Health Record VP, Chief Health Info Officer Jim Jirjis
Emergency Preparedness VP, Emergency Operations Michael Wargo
EMTALA VP, Legal Operations Scott Noonan
EMTALA VP, Critical Care Services Jeff Guy
Environment VP, Engineering and Facility Mgmt. Brian Weldy
ERISA VP, Employee Benefits Sherri Henry
Financial Reporting Executive VP, CFO Bill Rutherford
Global Anti-Corruption VP, Legal and Corporate Secretary John Franck
Government Contracts VP, Ethics and Compliance Elsie Faciane
Graduate Medical Education VP, Graduate Medical Education Bruce Deighton
Home Health and Hospice President, Post- Acute Services Gregg Stanley
Hospital Epidemiology and Infection Prevention VP, Chief Hospital Epidemiologist Ken Sands
Information Security VP, Chief Information Security Officer Paul Connelly
Insurance VP, Risk and Insurance and President, HCI Shirley Fuller Cooper
Intellectual Property Sr. Managing Counsel Rob Arreola
Intellectual Property Managing Counsel Eric Gray
International Business President, International Operations John Reay
Labor and Employee Relations VP, Labor Relations Thomas Beck
Laboratory VP, Chief Laboratory Officer Heather Signorelli
Laboratory CEO, Integrated Regional Labs Joanne Trout
Laboratory VP, Regulatory Compliance Gail Garrett
Licensure, Accreditation and Certification VP, Regulatory and Accreditation Services Ken Grubbs
Marketing and Advertising SVP, Marketing and Communications Deb Reiner
Medicare Bundled Payment Programs President, Post- Acute Services Gregg Stanley
Medicare Conditions of Participation VP, Regulatory and Accreditation Services Ken Grubbs
Medicare Coverage Determinations VP, Regulatory Compliance Gail Garrett
Medicare Coverage Determinations CMO, American Group and VP, Group Clinical Operations Pranav Mehta
Medicare Enrollment VP, Regulatory Reimbursement Ops Eric Smith
Occupational Safety VP, Risk and Insurance and President, HCI Shirley Fuller Cooper
Occupational Safety VP, Chief Hospital Epidemiologist Ken Sands
Payer Contracts SVP, Employer and Payer Engage. Kathryn Torres
Payroll VP, Finance (Parallon) Marc DeRossett
Pharmacy VP, Chief Patient Safety Officer Karla Miller
Pharmacy Senior Director, Medication Regulatory and Systems Compl. Kara Murray
Pharmacy AVP, Pharmacy Services and Care Delivery Systems Hayley Burgess
Physician and Provider Relations SVP, Provider Relations Sandra Morgan
Physician Relationships VP, Legal Operations Scott Noonan
Physician Services/Practices VP and ECO, HCA Physician Services Group Susan Peters Mitchell
Political Activities SVP, Government Affairs Jeff Cohen
Privacy AVP, Chief Privacy Official, Information Protection and Security Karen Raines
Provider-based Entities AVP, Reimbursement Operations, Government Programs Angelo Pagano
Procurement HealthTrust President and CEO Ed Jones
Real Estate VP, Real Estate Nick Paul
Records Management VP, Chief Information Security Officer Paul Connelly
Rehabilitation Services President, Post-Acute Services Gregg Stanley
Safety and Risk Prevention VP Regulatory and Accreditation Services Ken Grubbs
Safety and Risk Prevention VP, Chief Patient Safety Officer Karla Miller
Safety and Risk Prevention VP, Chief Hospital Epidemiologist Ken Sands
Safety and Security VP, Chief Information Security Officer Paul Connelly
Sarbanes-Oxley Act Executive VP, CFO Bill Rutherford
Securities Regulation VP, Legal and Corporate Secretary John Franck
Tax VP, Tax Lee Grubbs
Transfer Centers VP, Transfer Centers Amy Norman

Committees

Ethics and compliance committees throughout HCA provide direction and support to the ethics and compliance program.