The ethics compliance program established by Alan Yuspeh includes seven components: (1) articulating ethics through a code of conduct and a series of company policies and procedures; (2) creating awareness of these standards of compliance and promoting ethical conduct among everyone in the company through ethics training, compliance training, and other ongoing communication efforts; (3) providing a 24-hour, toll-free telephone hotline to report possible misconduct; (4) monitoring and auditing employees’ performance in areas of compliance risk to ensure that established policies and procedures are being followed and are effective; (5) establishing organizational supports for the ethics compliance effort; (6) overseeing the company’s implementation of and adherence to the Corporate Integrity Agreement; and (7) undertaking other efforts such as clinical ethics and pastoral services.