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.
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 | Brian Christenson |
| 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 Clinical Data Analytics | Kacie Kleja |
| Core Measures and eCQMs | SVP, HIM | Cindy Nichols |
| Cost Reports | AVP, Reimbursement Operations, Government Programs | Angelo Pagano |
| Credentialing and Privileging | VP, Regulatory and Accreditation Services | Ken Grubbs |
| Data Science and Data Integrity | VP, Chief Data Scientist | vacant |
| 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 |
| Imaging | SVP, PPR & Women's Services | Amy Casseri |
| Information Security | VP, Chief Information Security Officer | Paul Connelly |
| Insurance | VP, Risk and Insurance and President, HCI | Brad Spicer |
| 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 |
| Manufacturing Compliance | Executive Director, Quality Assurance and Regulatory Affairs | Karen Wagener |
| 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 | Brad Spicer |
| Occupational Safety | VP, Chief Hospital Epidemiologist | Ken Sands |
| Patient Safety | VP, Chief Patient Safety Officer | Karla Miller |
| 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 |
| Physician and Provider Relations | SVP, Provider Relations | Amy Casseri |
| 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 | VP and Chief Privacy Officer | 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 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.