Humana Military is a signatory member to the Defense Industry Initiative (DII) on business ethics and conduct. The DII signatories are united in the commitment to adopt and implement principles of business ethics and conduct that acknowledge and address their organizational responsibilities under federal procurement policy and law, thereby contributing to the National Defense. Every year, DII helps train hundreds of ethics officers how to comply with contracting laws at home and abroad, and how to conduct themselves in an honest and ethical manner in all business situations. Those ethics professionals, in turn, help train hundreds of thousands of defense industry employees on the latest in ethics and compliance.
The mission of our ethics and compliance program is to put integrity first. We execute that mission by continuously striving to instill an unwavering commitment to ethical behavior and accountability in every associate, while delivering world-class healthcare services to our deserving beneficiaries.
Our vision is to be the government's essential partner in helping to shape a stronger health system that enriches the lives of those we serve and supports our national security. Therefore, we place the utmost value on trust and believe that every leader and every associate in our organization plays a vital role in protecting it. We also believe that trust is a critical building block in the construction of any successful ethics and compliance program, but integrity must be the foundation.
We recognize and are compelled by our duty to be accountable to our associates, provider partners, shareholders, our government customer and our community. This sense of duty begins with our leadership and is passed down through the ranks to our associates. It is through our collective actions that our business is conducted with integrity.
Humana Military adheres to our parent company, Humana Inc.’s code of conduct, "Ethics Every Day" which sets forth our commitment to integrity and advises associates of the various areas in which they may encounter problems. This manual is provided to all Humana Military associates upon employment and is reviewed annually. Additionally, while completing annual review documents, all associates are asked to acknowledge their responsibility to comply with all applicable laws, regulations and company policy. Our associates are also asked to pledge to act with honesty, integrity and responsible corporate behavior.
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:
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.
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:
Our training program is reflective of our mission to put integrity first and to ensure that all parts of our organization act as one cohesive unit.
Our training program is designed to illustrate how each associate contributes to our company’s success through ethical behavior and emphasizes the need to remain compliant with our vision, our corporate business ethics and code of conduct, company policies and procedures and all applicable state and federal laws in the daily execution of our respective duties. Our program features the following elements:
Policies and procedures are published in the policy source section of our parent company’s intranet site with additional company specific policies published on the Humana Military intranet site. These written materials, while tailored to specific operations, must ensure that all key areas of the company are addressed in a consistent and effective manner.
