Humana Military is committed to an ethical workplace and an ethics and compliance program that is effective in preventing and detecting violations of law or the failure to fulfill regulations, standards of conduct or company policies.
Our ethics and compliance program is supported at the highest level within the organization. The director of government contract management has been given authority to act as compliance official and reports directly to the president on matters related to ethics and compliance. 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.
The council includes Humana Military's president and the president's direct reports. Pertaining to the ethics and compliance program, the executive council is responsible for the following:
- Supporting the compliance official in fulfilling the responsibilities of the 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 identified trends
- Annual evaluation of the effectiveness of the 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 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.
Our 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 information security office is responsible for oversight of all functions and/or activities related to the National Institute of Standards and Technology (NIST) 800-171. To maintain its NIST certification and accreditation, Humana NIST controls of the following areas are analyzed and audited on an annual basis:
- Physical security
- Personnel security
- Administrative security
- Information security
- Information systems security
- Communications security
- Humana Military has been granted an Authorization to Operate (ATO) by the Defense Health Agency (DHA)