es.com Code of Conduct

Transcription

1 es.com Code of Conduct

2 A Message from Eric Gurley, President and CEO Immanuel s Mission, Vision and Christ Promises are the founda on of the high quality care and services we provide our residents, par cipants and subscribers. Another important founda onal element is Immanuel s Code of Conduct which demonstrates the value our organiza on puts on ethical business and legal standards. These standards apply not only to those we serve, but also those who serve us. This includes vendors, independent contractors, other health care providers, organiza ons with whom we do business, government en es to whom we report, and the public and private organiza ons from whom reimbursement for services is sought and received. Immanuel s Code of Conduct is the cornerstone of all Immanuel prac ces. You will need to read it from cover to cover. We expect you to understand and follow the Code of Conduct and help make sure others do as well. Although no single document can provide all the answers, the Code of Conduct is a valuable resource designed to give guidance on where to turn if you see any inappropriate or unethical conduct or decisions being made. We ask that you lead by example, ask ques ons if you don t know the answer, and report any problems or concerns about inappropriate or unethical ac ons. You can go to your supervisor, Human Resources Manager, management, or the Corporate Compliance Officer. Immanuel also has in place a hotline ( ) and website (immanuel.ethicspoint.com), both operated by a third party, which allow you to confiden ally and anonymously report incidents of wrongdoing and/or non compliance. I can assure you that there will be no retalia on against you for asking ques ons, raising concerns or repor ng inappropriate or unethical ac ons in good faith. Thank you for the work you do and the Christ centered service you provide! CHRIST Promises Compassion Our Christ centered Mission calls us to genuinely care and love one another; allowing us to share in other s joys and sorrows. Honor We hold a deep regard for the dignity of each person; expressing gra tude for all that has been created by and is in the image of God. Relationships Christ centered love is acted out in our daily rela onships where we give listening ears to hear, caring hands to touch and loving eyes to behold each person as a child of God. Integrity We uphold the trust people place in us by remaining faithful to our Mission; accountable to honest, ethical and responsible behaviors. Serve We desire to model Jesus example of service. Jesus modeled and described serving as the one who is greatest among you shall be your servant. We embrace an a tude of serving by giving of ourselves to contribute to the well being of others. Teamwork We inten onally work together using our God given talents to achieve our Mission. 1 2

3 Purpose of the Code of Conduct You are expected to act with honesty, integrity, and openness. Immanuel is dedicated to adhering to the highest ethical standards. Common sense, good business judgment, ethical personal behavior, as well as compliance with all applicable laws and policies and procedures, are what we expect from all Immanuel employees, vendors, contractors, board members, agents, and other health care professionals affiliated with us. The Code of Conduct details the fundamental principles, values, and framework for ac on within our organiza on. It is intended to deter wrongdoing and promote: Honest and ethical conduct Compliance with all applicable governmental law, rules and regula ons Prompt internal repor ng of viola ons and compliance concerns The Code of Conduct is intended to provide a general overview of basic compliance concepts and to give guidance on acceptable behavior of Immanuel employees, volunteers, vendors, contractors, board members, agents, and other health care professionals affiliated with us. The Code of Conduct is not intended to fully describe the applicable laws or to detail Immanuel policies and procedures. To receive more detailed guidance on applicable laws, policies and procedures, you should contact your supervisor, Human Resources Manager, or the Corporate Compliance Officer. Quality of Care and Services to Residents/Par cipants Dedica on to quality is demonstrated in our goal to: Understand our resident/par cipants expecta ons Provide care and services in a mely and reasonable manner Be responsive to resident/par cipant and family concerns Maintain resident/par cipants rights and dignity at all mes while under our care Each resident/par cipant is an individual en tled to dignity, considera on and respect. Resident/par cipant abuse or neglect is not tolerated in any Immanuel loca on. Immanuel respects the rights of residents/par cipants and their families to par cipate in healthcare decisions and must inform them of their rights, as required by law. This includes the rights to par cipate in decisions on whether to consent or refuse treatment. We are commi ed to providing informa on that will promote knowledgeable decision making. We promote ethical, innova ve, professional, and compassionate care within an environment that nurtures their physical, social, emo onal and spiritual needs. Confiden ality, Privacy and Security Immanuel s employees, board members, vendors, contractors, and agents are each responsible for maintaining the confiden ality, privacy and security of all resident, par cipant and subscriber protected health informa on (PHI) as defined by the Health Insurance Portability and Accountability Act (HIPAA) and applicable state law. Resident, par cipant and subscriber informa on will not be released or discussed unless it is necessary to serve the individual or required by HIPAA or state law. If you become aware of a poten al breach of any PHI, it is necessary that the situa on be reported immediately to the Corporate Privacy Officer ( ), the compliance hotline ( ), or website (immanuel.ethicspoint.com). 3 4

4 Business Informa on Confiden ality Integral to Immanuel s business success is our protec on of confiden al business informa on, as well as the nonpublic informa on entrusted to us by employees and business partners. Confiden al and proprietary informa on include such things as financial data, consumer informa on, compensa on informa on, marke ng and corporate databases, and business proposals and strategies. Harassment Free Workplace We believe that employees have the right to work in an environment free of harassment. Immanuel will not tolerate any form of harassment, sexual or otherwise, from any employee. Sexual harassment may include sexual advances, request for sexual favors in conjunc on with employment decisions, verbal or physical conduct that creates an in mida ng environment or interferes with work performance. Degrading or humilia ng jokes, slurs or in mida on will not be tolerated. Protec ng secure and confiden al informa on is the responsibility of every employee. Confiden al informa on is a company asset. Though many of us may have access to confiden al informa on for use in the context in our jobs, Immanuel prohibits the sharing of this informa on unless you have a legi mate need to know and have agreed to maintain its confiden ality. Business informa on should be disclosed only as required in the performance of your job du es or as authorized by Immanuel or its affiliates. Marke ng and Adver sing Immanuel will not use adver sing or marke ng programs that cause confusion between our services and those of our compe tors, and we will not degrade our compe tors business or opera ons. We will comply with all state and federal requirements concerning adver sing. All adver sing and marke ng materials that contain Immanuel logos and informa on must be preapproved by the Vice President of Marke ng and Communica ons or his/her designee. If you experience or observe any form of harassment, immediately report the incident to a supervisor, your Human Resources Manager, the Corporate Compliance Officer or using the compliance hotline ( ) or website (immanuel.ethicspoint.com). Discrimina on Free Workplace Immanuel prohibits discrimina on due to a person s race, color, creed, religion, ancestry, sexual orienta on, gender, na onal original, age, ethnicity, gene c informa on, veteran status, or any other protected status. At Immanuel, we are commi ed to a fair and equitable workplace and to equal employment opportunity in all employment facets for all employees and applicants for employment without regard to their membership in any protected class. To deliver on Immanuel s commitment to quality, we should work toward the highest degree of performance, behave professionally at all mes, and promote high standards and integrity. All board members, employees, vendors, contractors, and agents share in the responsibility of preven ng discrimina on and should report any instances of this conduct. 5 6

5 Drug and Alcohol Use Immanuel is commi ed to providing a safe work environment and to fostering the well being and health of its employees, vendors, contractors, volunteers, and agents. The foregoing par es are prohibited from possessing, selling, trading, or offering for sale illegal drugs or otherwise engaging in the use of illegal drugs or alcohol while on Immanuel premises or while performing work for or on behalf of Immanuel; repor ng to work under the influence of illegal drugs or alcohol that is with illegal drugs or alcohol in his or her body; or, using prescrip on drugs illegally. Par es may drink alcohol in modera on while represen ng Immanuel at a social event as long as the event is not on an Immanuel premise and the employee s work day has been completed. Specific to the Board members only, a er normal work hours, Board members may drink alcohol socially or while conduc ng business regardless of the loca on. Viola ons of this policy are subject to disciplinary ac on up to and including termina on of employment, contract, or affilia on. Such viola ons may also have legal consequences. Gi s to/from Residents/Par cipants Gi s to and from residents/par cipants are highly discouraged because they give residents/par cipants not receiving or giving gi s the impression that the care they receive is less than the resident/ par cipant who gives or receives a gi. However, if a gi is not solicited, resident/par cipant gi s given to employees in gra tude may be accepted if they are of very li le value. Handmade items with li le marketable value or perishable items such as flowers may be accepted. Employees may not accept cash or cash equivalents, which includes gi cards or cer ficates, currency, or checks, unless through a formal approved event (i.e. Christmas or Scholarship funds). Gi s, Gratui es and Business Courtesies Immanuel is commi ed to compe ng solely on the merit of our products and services. We should avoid accep ng any gi, gratuity or business courtesy from our vendors and contractors or poten al business affiliates if the value is more than nominal and it is intended or could be construed to influence business opportuni es awarded to any such vendor or contractor. We should not feel any en tlement to accept and keep a business courtesy. Although we may not use our posi on at Immanuel to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies that promote successful working rela onships and with the vendors and contractors Immanuel maintains or may establish a business rela onship with. Business courtesies include meals, refreshments, entertainment or other benefits, which are detailed below. Meals, Refreshments and Entertainment Immanuel employees may accept occasional meals, refreshments, entertainment (e.g., spor ng or theatrical event) and similar business courtesies from a current or prospec ve vendor in order to further develop a business rela onship if these guidelines are followed: The invita on is for an ordinary business meal or gathering during which the host is present and business is conducted. Business courtesies of personal benefit such as ckets to spor ng events, theatrical events, or golf ou ngs unaccompanied by the host may not be accepted. The business courtesy does not reflect a pa ern of frequent acceptance from the same person or en ty. The cost associated with such an event must be reasonable and appropriate. As a general rule, this will mean that the cost should not exceed approximately $100 per person. Vendor payment of expenses for travel costs or overnight lodging for such event (other than transporta on in a vehicle owned privately or by the host company) is prohibited. Payment of lodging for an Immanuel employee or agent or his/her family in connec on with sports and entertainment events is prohibited. 7 8

6 Conflicts of Interest Immanuel employees must avoid any rela onship or ac vity that might impair, or even appear to impair, our ability to make objec ve and fair decisions when performing our jobs. At mes, we may be faced with situa ons where the business ac ons we take on behalf of Immanuel may conflict with our own personal or family interests because of the course of ac on that is best for us personally may not also be the best course of ac on for Immanuel. We owe a duty to advance the legi mate interests when the opportunity to do so arises. Employees must never use Immanuel property or informa on for personal gain or personally take for ourselves any opportunity that is discovered through our posi on with Immanuel. Some examples which may give rise to a conflict of interest are: Being employed (you or a rela ve*) by, or ac ng as a consultant to, a compe tor or poten al compe tor, vendor or contractor, regardless of the nature of the employment, while you are employed with Immanuel. Hiring or supervising rela ves.* Serving as a board member for an outside organiza on that does business with Immanuel. Owning or having a substan al interest in a compe tor, vendor or contractor. Having a personal interest, financial interest or poten al gain in any Immanuel transac on. Accep ng gi s from any person or outside business doing or seeking to do business with Immanuel under circumstances where it appears the purposes of the gi may be to influence the conduct of business with the donor. *Rela ve is defined as any person who is related by blood or marriage, or whose rela onship with an Immanuel employee is similar to that of persons with who are related by blood or marriage. Financial Repor ng We are commi ed to complying with sound financial repor ng prac ces. We use generally accepted accoun ng principles to maintain accurate books and records. We will maintain a financial repor ng system that contains accurate entries, including a complete lis ng of all financial transac ons and reflects actual transac ons. Immanuel will not create false or misleading entries in any financial records. All funds and assets must be properly recorded. Cost reports will be completed in an accurate manner, ensuring that the company is reimbursed in accordance with applicable laws and regula ons. Kickbacks, Referrals and Bribes The An Kickback law makes it a crime to knowingly and willfully offer, pay, solicit, or receive something of value to induce or reward referrals of business under Federal health care programs. In accordance with this statute, Immanuel does not accept or offer to provide anything of value in exchange for the direct or indirect referral of residents, par cipants or business, or in return for buying services or supplies. Some examples of kickbacks, referrals and bribes may include, but are not limited to, the following: Making payments to or from referral sources that exceed fair market value. Providing or accep ng free or discounted goods or services among referral sources. Establishing payment arrangements with vendors, suppliers or referral sources where reimbursement is based on the amount of volume of business rather than the value of services provided. 9 10

7 Fraud, Waste and Abuse Immanuel is commi ed to detec ng and preven ng fraud and financial waste and abuse. Immanuel intends to fully comply with the federal False Claims Act and any similar state law that fight fraud and abuse in government healthcare programs. These state and federal laws prohibit the knowing and/or inten onal use of false or fraudulent claims, records or statements for the purpose of obtaining payment from the government. These laws apply to Medicare and Medicaid program reimbursement and prohibit, among other things, billing for services not rendered; billing for undocumented services; falsifying cost reports; billing for medically unnecessary services; assigning improper codes to secure reimbursement or higher reimbursement; par cipa ng in kickbacks; and retaining an overpayment for services or items. Suspected false claims viola ons should be reported to your supervisor, the Corporate Compliance Officer, the compliance hotline ( ) or website (immanuel.ethicspoint.com), or to the appropriate federal or state agency. Ineligible Persons, Excluded Individuals and En es Immanuel does not do business with, hire, or bill for services rendered by excluded or debarred individuals or en es. Employees, volunteers, board members, contractors, vendors, and agents must report if they become excluded, debarred, or ineligible to par cipate in any government healthcare program, or become aware that anyone doing business with or providing services for Immanuel has become excluded, debarred or ineligible. Reports must be made as follows: Employees and volunteers must report to Human Resources and/or the Corporate Compliance Officer Board members must report to the Board Execu ve Commi ee and/or the Corporate Compliance Officer Contractors, vendors and agents must report to the Corporate Compliance Officer Coding and Billing Integrity Immanuel is commi ed to accuracy in billing and coding prac ces and to compliance with all governmental and third party payor requirements. We will provide employee orienta on and training, and enforce billing policies, audit procedures and billing controls to ensure that each Immanuel loca on bills accurately for its services and only bills for services rendered. We will not allow anyone to present or cause to be presented, fic ous or fraudulent claims. Health, Safety and Environmental Laws Immanuel is commi ed to providing and maintaining a healthy and safe environment for its employees and those whom we serve, while adhering to all applicable environmental laws. To achieve this commitment, all Immanuel loca ons must follow company policies, government rules and regula ons and local prac ces that promote workplace health and safety. You should be aware of and abide by all health and safety standards that apply to your job du es. Please no fy your supervisor immediately if you become aware of a condi on or situa on that presents a danger or may be in viola on of health and safety standards. Property, Equipment and Supplies Immanuel employees should use Immanuel resources for authorized business purposes only. Immanuel s assets, property, communi es, centers, equipment and supplies should be protected against loss, the, damage and misuse. Employees should understand that a misuse of company resources includes the falsifica on of me

8 Accuracy, Reten on and Disposal of Documents and Records Each person is responsible for the accuracy of Immanuel s documents. You may not falsify informa on or cause a document to be misleading. You may never alter or destroy a document that you know or should know to be relevant to a government inves ga on, an audit, or an internal inves ga on. You must retain and protect medical and business documents and records in accordance with applicable state laws. You must follow Immanuel s record reten on and destruc on policies. Do the Right Thing Several key ques ons can help iden fy situa ons that may be unethical, inappropriate or illegal. Ask yourself: Does what I am doing comply with Immanuel s Code of Conduct and policies? Have I been asked to misrepresent informa on or deviate from normal procedures? Would I feel comfortable describing my decision at a staff mee ng? Am I being loyal to my family, Immanuel and myself? Is this the right thing to do? No Retalia on Immanuel employees and others who report a possible viola on of the Code of Conduct in good faith, will not be subjected to retalia on or harassment by Immanuel or any of its employees. Repor ng and Inves ga on We are each responsible for repor ng, in good faith, possible instances of wrongdoing and/or non compliance with regula ons or policies. All reported concerns will be taken seriously and the process of inves ga ng ma ers will be handled with professionalism and confiden ality. Inves ga ons will be conducted with the intended purpose of iden fying any possible non compliance with policy and procedures, rule and/or regula on, understanding the root cause and implemen ng plans to ensure reoccurrence does not happen and improvement in processes are made. Compliance Repor ng If repor ng possible instances of wrongdoing and/or non compliance with regula ons or policies to your supervisor, Human Resources Manager or management is inappropriate or ineffec ve, or if an individual seeks anonymity in repor ng a concern, Immanuel has a hotline ( ) and website (immanuel.ethicspoint.com) available 24 hours a day, 7 days a week for individuals to report any compliance related concern. An external party operates the compliance hotline and website and callers/users are reminded that they are not required to iden fy themselves, if they so choose. Immanuel will make every effort to protect the caller/user s iden fy within the limits of the law