HHS-OIGThe SWMBH Corporate Compliance Plan addresses SWMBH’s regulatory compliance obligations as a Prepaid Inpatient Health Plan (PIHP) and how, where it has obligations, it will oversee the PIHP Managed Behavioral Health Organization (MBHO) functions it delegates to the Affiliate Community Mental Health Service Providers (CMHSP). SWMBHs Corporate Compliance Program is designed to further SWMBHs commitment to comply with applicable laws, promote quality performance throughout the SWMBH region, and maintain a working environment for all SWMBH personnel that promotes honesty, integrity and high ethical standards.

SWMBHs Corporate Compliance Program is an integral part of SWMBHs mission, and all SWMBH personnel, Affiliates and contracted and sub-contracted Providers are expected to support the corporate compliance program. SWMBHs compliance plan is comprised of the following principal elements:


  • The development and distribution of written standards of conduct, as well as written policies and procedures, that promote SWMBHs commitment to compliance and that address specific areas of potential fraud;

  • The designation of a Chief Compliance Officer and other appropriate bodies, (e.g., a Corporate Compliance Committee), charged with the responsibility and authority of operating and monitoring the compliance program;

  • The development and implementation of regular, effective education and training programs for all affected employees;

  • The development of effective lines of communication between the Chief Compliance Officer and all employees, including a hotline to receive complaints and the adoption of procedures to protect the anonymity of complainants and to protect callers from retaliation;

  • The use of audits or other risk evaluation techniques to monitor compliance and assist in the reduction of identified problem areas within delivered services, claims processing and delegated managed care functions;

  • The development of disciplinary mechanisms to consistently enforce standards and the development of policies addressing dealings with sanctioned and other specified individuals; and

  • The development of policies to respond to detected offenses, to initiate corrective action to prevent similar offenses, and to report to Government authorities when appropriate.


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