Humana Military commits to an ethical workplace and the establishment of an ethics and compliance program that is reasonably designed, implemented, and enforced so that it generally will be effective in preventing and detecting violations of law or the failure to fulfill regulations, standards of conduct, or company policies.
Executive Oversight
Our ethics and compliance program is supported at the highest level within the organization. The Director, Contract Compliance and Subcontract Management has been given authority to act as Compliance Official and reports directly to the President and Chief Executive Officer on matters related to ethics and compliance. In addition, the Compliance Official is a member of the parent company's Compliance Project Management Office, which is a cross-functional and collaborative organization that enables a company-wide view of compliance-related activities. The Compliance Official ensures that all Federal Acquisition Regulation (FAR) clauses, as well as other clauses and requirements, are flowed down to those departments responsible for their implementation.
It is Humana Military’s intent to have each of its operational areas responsible for daily compliance to the program. Therefore, various senior officers in the key operational areas of Humana Military are responsible for governance of the program. Finally, as a member of Humana Inc.'s Corporate Compliance Committee, our President and Chief Executive Officer provides reporting and visibility to the senior executives and directors of Humana Military's parent company.
Humana Military Executive Committee
Humana Military's Ethics and Compliance Program is discussed during quarterly meetings of our Executive Committee which consists of Humana Military leadership representing all operational areas of the company. The committee reports directly to the Chief Executive Officer. Pertaining to the Humana Military Ethics and Compliance Program, the Executive Committee is responsible for the following:
Supporting the Compliance Official in fulfilling the responsibilities of the Humana Military Ethics and Compliance Program
Reviewing the evaluation of known or knowable risk(s) and corresponding corrective actions
Reporting on issues of significance related to the members’ areas of accountability
Reviewing trends identified
Annual evaluation of the effectiveness of the Humana Military Ethics and Compliance Program
Delegation of Authority
It is our practice to utilize careful discretion in the delegation of authority to ensure that only reliable individuals are given significant responsibilities for programs and contracts.
The Humana Military Human Resources Department will scrutinize the background of all potential associates. Any individual who is convicted of fraud or of any other felony arising out of a contract with the Department of Defense (DoD) is prohibited from serving on any DoD contract or first tier subcontract in any capacity with the authority to influence, advise, or control decisions with regard to any contract or subcontract issues. Additionally, if the company hires someone who has had any past problems unrelated to federal contracts, such as instances of dishonesty or disciplinary action taken against him or her, it is imperative that such a person not be delegated duties which could be abused or that effective controls and proper supervision be exercised over that associate.
Privacy Office
The Humana Military Privacy Office oversees all activities related to the development, implementation, maintenance of and adherence to Humana Military’s policies and procedures covering the privacy of and access to protected health information. In addition, the Privacy Office ensures compliance with federal and state laws, HIPAA, DoD and TRICARE regulations, and the organization’s information privacy practices.
Information Security Office
The Humana Military Information Security Office is responsible for oversight of all functions and/or activities related to Department of Defense Information Assurance Certification and Accreditation Process (DIACAP). To maintain its DIACAP certification and accreditation, Humana Military DIACAP controls of the following areas are analyzed and audited on an annual basis:
Humana Military has been granted an Authorization to Operate (ATO) by TRICARE Management Activity.
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