Humana-Military.com

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Our Scrutiny:  Be Prudent

Internal Control System

Humana Military endeavors to ensure all of its associates, providers, and business partners are familiar with and are committed to compliance and the exhibit of ethical behavior.  Therefore, Humana Military has established a rigorous internal audit function and utilizes various external audit resources which are comprised of the following:
         

Internal Audit Functions

  • Operations/Compliance Reviews
    • Reviews of business practices, policies, procedures, internal controls for compliance and the special requirements and deliverables of Government contracts such as FAR and DFARS requirements; procurement policy; TINA; procurement integrity; small business utilization; Government property; Government audits; and systems
    • Conducted on an annual basis and systematically cover major areas of company operations as well as focus attention on the special requirements of Government contracting
           
  • Human Resource Oversight
    • Involves scrutiny of policies and procedures pertaining to general ethics issues; employee hiring practices; conflicts of interest; annual training; equal opportunity; affirmative action; drug-free workplace; and harassment
    • Includes monitoring of Ethics Hotline calls concerning Humana Military
                    
  • Vulnerability Assessments
    • Government-mandated internal control reviews cover all major functions of the organization
    • Performed on a one-year, three-year, or five-year basis depending upon the vulnerability rating (high, medium, low, respectively) of the function
           
  • Letters of Assurance
    • Government-mandated Letters of Assurance compiled annually which detail findings pertaining to the evaluation of internal accounting and administrative control systems
           
  • Operational Internal Control Stewards
    • Individuals from each operational area of the organization assigned responsibility for the assessment and reporting of risk in his/her area of responsibility

External Audit Functions

  • Humana Inc. Corporate Compliance Committee
    • This committee governs Humana Military's parent company's Corporate Compliance Program.  Composition of the committee includes senior leadership representing Humana Military Operations; Compliance; Internal Audit; Special Investigations Unit; Law; Customer Service Centers; Finance; Human Resources; Marketing and Sales; Medical Management; Pharmacy; and Communications and Information Systems.  Humana Inc.'s Chief Compliance Officer chairs the committee and reports directly to the Humana Inc. CEO and updates the Audit Committee of the Board of Directors when necessary.  The responsibilities and functions of Humana Inc.'s Corporate Compliance Committee mirror those of Humana Military's Executive Committee.
                         
  • Independent Accountants
    • The primary responsibility of the independent accountants is to certify the accuracy of our parent company’s financial statements in regard to generally accepted accounting principles.  In addition, the independent accountants are used to meet various more specific and distinct certification requirements, like those required under our former MCS contracts.
                     
  • Humana Inc. Internal Audit Department
    • The Humana Inc. Internal Audit Department reviews any operations and business conducted by Humana Inc. or one of its subsidiaries, including Humana Military.  Additionally, it oversees all financial controls as mandated by Sarbanes-Oxley.  Humana Inc.'s Internal Audit autonomy is assured since it reports to the Board/CEO and the Board of Directors Audit Committee. 
                
  • Utilization Review Accreditation Commission (URAC)
    • During its accreditation process, URAC performs reviews of various company functions such as Medical Management, Health Website, and HIPAA Privacy.  These reviews are performed on a periodic basis contingent upon the function being reviewed.
                   
  • Compliance Project Management Office
    • Parent company's cross-functional and collaborative organization that enables monitoring, auditing, and more effective action as well as a company-wide view of compliance-related activities
    • Ensures a proactive, coordinated approach to company compliance
    • Emphasizes company's commitment to meeting and exceeding the highest standards of business ethics and compliance in response to dynamic regulatory guidelines.


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Last Update: September 16, 2009