Standards of Ethical Conduct and Business Practices
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- Esmond Fisher
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1 Standards of Ethical Conduct and Business Practices A Ref lection of Our Values
2 Our Values Our values govern the way we behave on a daily basiswith our coworkers, our patients and the general public. Respect We show respect by treating one another with dignity and courtesy. We respect each other s right to privacy and way of life. We exchange ideas openly and freely in an atmosphere where everyone feels heard, challenged and empowered. We act respectfully even in difficult situations or when we disagree. Excellence Excellence begins with each staff member taking pride in her/ his work. It comes from our efforts as individuals to continually improve our knowledge, skills, and performance as well as to demand the best of ourselves in caring for others. Excellence means that we strive to exceed work expectations and professional standards. Service We understand that HealthReach Community Health Centers exists because we respond to the needs of the community, and because people are satisfied with our services. Each time one of us receives a call, it is an opportunity to honor our commitment to service. Professionalism We demonstate professionalism by projecting a positive image of the organization through actions, words and appearance. We understand that our job is to put the needs of the patient first. We cooperate with other providers to improve the health of our community. Empathy Empathy means we take the time to listen and understand what people are experiencing. We act upon other people s concerns and follow through as promptly as possible to improve our services. We respect diversity in each other and in our patients, recognizing that those differences can make us a stronger community. We strive to treat everyone as we would like to be treated ourselves. Communication We recognize communication is a two-way street; it is just as important to listen attentively as it is to speak with sensitivity. We take the risk to question openly the way things are and offer ideas for improving our work environment. We try to give and receive constructive feedback and work through disagreement to mutual understanding. Teamwork As members of a team, we recognize that our actions have an impact on others. We work as partners to solve problems and make decisions. We consider team success more important than individual success and we know that working together ensures the best use of our resources.
3 Table of Contents Living and Working with Integrity...1 Standards of Conduct & Practice...2 Professional Relationships...3 Patient Relationships...4 Confidential Information...5 Conflicts of Interest...7 Stewardship of all Resources...9 Responsible Billing Practices...10 Recognizing the Problem Taking Action...12
4 Living and Working with Integrity T wo fundamental principles form the foundation of how we do business at HealthReach Community Health Centers - acting with integrity and utilizing good judgment. At HealthReach, the values of Respect, Excellence, Service, Professionalism, Empathy, Communication, and Teamwork have long governed the way we behave on a daily basis with our coworkers, our patients, and the general public. In this Standards of Ethical Conduct and Business Practices guide, we have provided information about basic legal and ethical standards to help all of us determine the best response to the situations that we face each day. As employees with integrity, we strive to be consistent, honest, and accountable in our interactions with each other, our patients, and communities we serve. This obligation also holds true in our interactions with competitors, government officials, regulators, and suppliers. We pay constant attention to all legal boundaries and comply with all applicable laws. While employees are not expected to know the detail of the law, they are expected to know when to consult their supervisors for guidance on legal issues. On a daily basis, we are each responsible for truthfulness and accuracy. Our written records and verbal conversations are the foundation of an ethical environment. Even if a supervisor or authority figure asks us to commit or ignore an unethical act, this does not, in any way, excuse ignoring the act or failing to report it. We must always abide by the highest ethical standards, no matter who might be pressuring us to do otherwise. To give us the context for using good judgment in the work that we do, this booklet provides us with some basic legal and ethical parameters within which to operate. Every employee of HealthReach Community Health Centers must be clear about what these policies mean and how they are critical to the way we work -- every hour of every day. 1
5 Although no two situations are alike, we aim for consistency and balance when encountering any ethical issues. This guide can help us make the right ethical choice in difficult situations. Making good ethical choices and acting with integrity are fundamental to how we do business at HealthReach. Standards of Ethical Conduct & Business Practices At HealthReach Community Health Centers, the way we do our work and serve our patients centers on four simple, general standards that apply to all our employees: We provide high quality health care services to the people of central and western Maine, regardless of their ability to pay. We are honest and fair in all our dealings with patients, government officials, regulators, competitors, suppliers, and each other. We abide by the highest code of business and professional ethics. We comply with all applicable laws, regulations, rules, and contractual requirements. We respect the dignity of all patients, employees, and outside parties. The following pages outline how we put these Standards into practice on a day to day basis. 2
6 Professional Relationships HealthReach Community Health Centers is committed to building an environment of mutual respect which promotes staff cooperation and the highest ethical behavior through honesty and fairness. We have long held the values of Respect, Excellence, Service, Professionalism, Empathy, Communication, and Teamwork. Our workplace is highly challenging and demands a strong commitment to excellence. By living and working within values to which we are committed, all employees within HealthReach can achieve this level of excellence. Valuing the differences that each employee brings to the workplace allows employees to produce the best work for our organization, for our patients, and for the communities that we serve. HealthReach Community Health Centers fully supports equal opportunity and affirmative action in all facets of our business. Discrimination of any kind will not be tolerated. No employee, patient, applicant for employment or supplier will be treated in a discriminatory manner because of his or her race, gender, religion, color, national origin, sexual orientation, disability, marital status, veteran status, or age. Any HealthReach Community Health Centers employee who feels he or she has been discriminated against or harassed, or feels he or she has witnessed such action, should promptly report the incident to his or her supervisor, to the Human Resources Department, or to the Corporate Compliance Officer. Harassment of employees for any reason will not be tolerated. Not only is it against the law, but it also devalues its victims, decreases productivity, and damages morale. 3
7 Patient Relationships At the core of HealthReach Community Health Centers Mission Statement is the commitment to provide high quality health care services to the people of central and western Maine. In order to accomplish this mission, the relationship between the staff at HealthReach and the patients we serve must be based on honesty, integrity, and trust. A large part of this trust is the patient s ability to tell his or her health care provider all of his/her concerns without worrying that the issues discussed will be communicated to others (except as required by law). Confidentiality is crucial to our ability to do our work and meet our mission. Caring is also at the core of what we do. Patients must always be treated with the utmost kindness, respect, and consideration. This can be shown in many ways: a warm smile, a gentle touch, a kind word. While staff are always busy, care must be taken to consistently be polite and patient. As with all other ethical behavior, rudeness and disrespectful behavior toward one another or toward a patient will result in appropriate, prompt and corrective action. HealthReach Community Health Centers serves the people of central and western Maine with the highest quality health care, regardless of their ability to pay for our services. One indication of respect is always maintaining confidentiality around the issue of discounted fee services. The level of care that patients receive must be based on clinical need rather than financial considerations. Kindness, Respect, Consideration, and Confidentiality are essential in all that we do. 4
8 Confidential Information The exchange of information is at the heart of HealthReach Community Health Centers' relationships with its patients, employees, and external parties. To this end, all HealthReach Community Health Center s employees are responsible for maintaining the confidentiality of many types of information. Patient and employee information should be discussed only on a "need to know" basis. Employees must protect the confidentiality of current, past, and prospective patients. examples: Discussion of patient information should always be avoided in public places. Patient charts should not be left in a place accessible to the public or unauthorized employees. Release of information to persons who are not a part of HealthReach Community Health Centers should be done only with the patient s written permission or in accordance with applicable law. Employees should not acknowledge to someone outside of HealthReach that they know whether or not a person is, or ever has been, a patient of a Health Center. Employees must protect other employees personal and financial information. examples: If an employee overhears a colleague discussing a personal problem with another employee, the information should not be shared with anyone else. Employees should not discuss worker's compensation or payroll information except as necessary. 5
9 Employees must protect company information. examples: Confidential, proprietary information about HealthReach Community Health Centers should only be disclosed on a need-to-know basis. Employees should not discuss company information, or fellow employees personal information with members of the media without prior authorization from the President/CEO. Employees must protect information from other organizations. examples: Copyright rules must be respected. 6
10 Conflicts of Interest HealthReach Community Health Centers expects its employees to avoid conflicts of interest. Conflicts of interest exist when employees engage in a personal activity or have a personal interest that could influence their decisions at HealthReach Community Health Centers. A conflict also exists when employees make personal use of confidential information acquired through their employment at HealthReach. A conflict can be identified by asking whether there is a potential for even the appearance of divided loyalty. Employees must not accept improper gifts from vendors, patients, or their friends and families, so as not to create any appearance of impropriety, favoritism, or conflict of interest. examples: Staff may only accept gifts that can be shared with other team members, such as flowers or baked goods or gifts with a value less than $25. If a more lavish gift is offered, the intended recipient should thank the person offering the gift and explain that gifts are not necessary and not permitted by HealthReach policy. If a patient, friend or family insists on offering a gift, the employee should suggest that a donation be made in honor of the intended recipient through the HealthReach Development Office. Staff must not sell products (Avon, crafts, etc.) to patients. Employees must not borrow from or lend personal funds to a patient or supplier. Staff must not give or receive compensation or gifts in exchange for referrals. 7
11 Employees should not use their position or authority to influence HealthReach Community Health Centers to conduct business with friends or family members. examples: A Health Center practice manager should not use a temporary agency run by a member of his or her family. Employees should not purchase products or services for HealthReach from a friend or relative without the approval of their supervisor and Purchasing. Employees should not participate in activities through outside directorship, employment, or political office that conflict or compete with that employee s responsibilities at HealthReach Community Health Centers. examples: A HealthReach doctor serving on the Board of a social services agency must not use undue influence to direct those patients to HealthReach Community Health Centers. If an employee is active in a political campaign, he or she must not solicit contributions for that candidate from other employees. We cannot, of course, list all the possible conflicts. Ultimately, it is the responsibility of each individual to avoid any situation that could even appear to be a conflict of interest. It is important to note that under certain circumstances, conflicts of interest can amount to violations of criminal law. Any doubts should be resolved in a discussion with supervisors or the Corporate Compliance Officer. 8
12 Stewardship of All Resources All HealthReach Community Health Centers employees are charged with the responsibility of using care with the many resources provided to them through the organization. HealthReach Community Health Centers greatest resource is its staff, and the staff s greatest resource is their time. During work hours, employees are required to use their time wisely for the good of the organization. There should be very limited use of company time for personal phone calls or errands. Staff should be punctual when coming to work and should only leave work early under unusual circumstances and with the approval of their supervisor. Time cards and expense vouchers must accurately reflect hours worked and miles traveled in job related activities. Employees are required to use their work time wisely for the good of the organization. We must make sound decisions regarding the best use of our financial resources. We must not purchase items that we do not need for our work or waste the supplies that have been provided to us. The budget, as set forth by the HealthReach Community Health Centers' Board of Directors, will guide our purchasing decisions. We must always act with honesty and integrity in all areas of finance including billing, purchasing and payroll. Donations earmarked for a specific purpose must always be used for that purpose alone. Everything you do as a HealthReach Community Health Center employee is a reflection of the organization s values. 9
13 Responsible Billing Practices Ethical billing practices is an area of great concern, not only to HealthReach Community Health Centers but also to our patients and funding sources. Patients and insurers are billed appropriately and accurately for the services provided. HealthReach Community Health Centers mission is to provide high quality health care services to the people of central and western Maine. In order to continue that mission, we must bill and be paid for the services that we provide. We must abide by all legal mandates and appropriate accounting principles. These laws and regulations are extremely complex; all employees are expected to bill for services accurately and in accordance with state and federal laws. Not understanding applicable laws and regulations is no excuse for inaccuracies in the billing process. These unintentional inaccuracies can lead to sanctions and penalties just as if they were intentional. HealthReach Billing Practices Bill only for items and services rendered and medically necessary Code for services accurately, neither upcoding nor downcoding for services rendered Avoid duplicate billing Ensure that cost reports accurately reflect the services rendered Do not unbundle bills to increase reimbursement rates Refund any credit balances to the patient or to the funding source in a timely manner Negotiate bill collections with honesty and integrity If you have any questions about the appropriateness of a billing practice, your supervisor, the billing department, or the Corporate Compliance Officer will be able to help you. If you are unsure, it is your responsibility to ask. 10
14 Recognizing the Problem Most kinds of ethical problems are not difficult to recognize. But for some more subtle issues, the fact that there is an ethical problem may not be obvious. Here are some signs to watch for: You feel uncomfortable about a business decision, or about something you have been asked to do. You have witnessed a situation that made you or someone else uncomfortable. You feel that HealthReach Community Health Centers would be embarrassed if a situation were revealed by the media. You feel that a potential issue would be awkward if discussed in front of the licensing board. Your responsibility as a HealthReach Community Health Centers employee is to bring questionable situations to the attention of the Corporate Compliance Officer. If you are not sure whether there is an ethical problem, it is better to ask. All such questions will be treated as confidential. The Corporate Compliance Officer will perform an investigation and may bring the issue in front of the Corporate Compliance Committee for further guidance. In either case, the Corporate Compliance Officer will respond to you quickly with a finding and recommendation for further action. If you are not sure whether there is an ethical problem, ASK! 11
15 Taking Action We must all be alert and concerned about possible violations of HealthReach Community Health Centers Standards of Ethical Conduct and Business Practices, whether these violations occur because of oversight or intention. If an employee becomes aware of a particular activity or situation that the individual, in good faith, believes may violate federal or Maine law or regulation, or HRCHC s own policies or procedures, the individual has a duty to report that concern to his or her supervisor or the Corporate Compliance Officer. HRCHC will not tolerate retaliation, including intimidation, threats, coercion, discrimination, demotion, discharge, or any other form of retaliation, against any individual who, in good faith, raises concerns about and reports on HRCHC s compliance with laws, regulations or HRCHC s own policies and procedures. Federal and Maine Whistleblower protections are afforded to any employee, volunteer, vendor or contractor who reasonably believes there is evidence of any of the following: Gross mismanagement of a federal grant or contract; A gross waste of federal funds; An abuse of authority relating to a federal grant or contract; A substantial and specific danger to public health or safety; or, A violation of law, rule, or regulation related to a federal grant or contract (including the competition for, or negotiation of, a grant or contract). These Standards are based in part on various laws, including the Federal False Claims Act, and employees should be aware that violations of those laws may result in criminal penalties or adverse judgments in civil lawsuits. Because of the importance of these issues, HealthReach Community Health Centers may take action, including termination, against any employee whose actions have been found to be inconsistent with these Standards of Conduct. Our patients and the communities we serve depend on us to be responsible and act ethically. With these Standards as a guide, we can meet these expectations with confidence. 12
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17 Ethical Conduct & Business Practices Acknowledgment of Receipt and Disclaimer I acknowledge that I have received HealthReach Community Health Centers Standards of Ethical Conduct and Business Practices, dated May, I understand that it is my responsibility to become familiar with the content of the Standards of Ethical Conduct and Business Practices, and to abide by the guidelines set forth therein. I understand that if I have questions about the Standards of Ethical Conduct and Business Practices, it is my responsibility to ask my supervisor or a Human Resources Representative for clarification. Employee Name (printed) Employee Signature Date
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20 When in doubt... ASK! The Corporate Compliance Officer for HealthReach Community Health Centers: Dawn Brady Contact her anonymously at: HealthReach Community Health Centers P.O. Box 624, Wilton, ME Phone: or (cell)* *leave a confidential message Fax: (207) Dawn.Brady@HealthReach.org 05/2018
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