Even the most effective compliance training program will not prevent a small number of employees from engaging in activity that does not comply with the organizations policies and procedures or with the law. Every ethics and compliance program needs a method for identifying and resolving this type of conduct. The need for this type of exception-reporting mechanism is reinforced by the OIG Compliance Program Guidance for Hospitals, which states: "The OIG encourages the use of hotlines (including anonymous hotlines), e-mails, written memoranda, newsletters, and other forms of information exchange to maintain those open lines of communication."

HCA maintains an Ethics Line for reporting possible misconduct or obtaining guidance on an ethics or compliance issue. The Ethics Line number is 1-800-455-1996, and is included in our Code of Conduct and on posters throughout our facilities.

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While we have a comprehensive Code of Conduct, there are many areas of compliance risk that, due to their complexity, require additional guidance. We have developed a comprehensive set of policies and procedures to address those risks.