Code of Conduct

  • INTRODUCTION:

    The Code of Conduct sets forth LHCC’s Principles and Standards for all their employees as they specifically relate to LHCC compliance efforts pursuant to federal laws, rules, and standards of the Medicare/Medicaid programs. The Principles articulate the policies of LHCC and the Standards are intended to provide additional guidance to persons functioning in managerial or administrative capacities. The Principles set forth in the Code of Conduct shall be distributed to all Physicians and employee. The Code of Conduct will be updated as necessary; LHCC will distribute any change or update by sending each employee an individual copay, via the courier or email. All employees are responsible to ensure that their behavior and activity is consistent with the Code of Conduct.

    PURPOSE:

    The Code of Conduct has been adopted by LHCC to provide standards by which employees of LHCC will conduct themselves in order to protect and promote corporation-wide integrity and to enhance LHCC’s ability to achieve LHCC’s mission.

    LEGAL COMPLIANCE:

    1. Principle. LHCC will strive to ensure that all activity by or on behalf of the professional corporation is in compliance with applicable federal and state laws, and regulations, as they specifically relate to the prohibitions against the filing of false or fraudulent claims with Medicare, Medicaid, or other federally funded healthcare programs. All employees of LHCC are expected to support the professional corporation in its commitment.
    2. Standards. The following standards are intended to provide guidance to management and employees in administrative positions to assist them in their obligation to comply with applicable laws. These standards are neither exclusive nor complete. Employees are required to comply with all applicable laws, whether or not specifically addressed in the Code of Conduct. If questions regarding the existence of, interpretation or application of any law arise, they should be directed to LHCC's Compliance Officer or LHCC's respective Accounts Manager who shall refer all legal issues to LHCC's outside legal counsel.
      1. Antitrust. All employees must comply with applicable antitrust and similar laws which regulate competition. Examples of conduct prohibited by the laws include (1) agreements to fix prices, bid rigging, collusion (including price sharing) with competitors; (2) boycotts, certain exclusive dealing and price discrimination agreements; and (3) unfair trade practices including bribery, misappropriation of trade secrets, deception, intimidation and similar unfair practices. LHCC employees in managerial or administrative positions are expected to seek advice from LHCC's Compliance Officer, who shall refer the issue to LHCC's outside legal counsel when confronted with business decisions involving a risk of violation of the antitrust laws.
      2. Fraud and Abuse. LHCC expects its employees to refrain from conduct with may violate the fraud and abuse laws. These laws prohibit (1) direct, indirect or disguised payments in exchange for the referral of patients; (2) the submission of false, fraudulent or misleading claims to any government entity, including claims for services not rendered, claims which characterize the service differently than the service actually rendered, or claims which do not otherwise comply with applicable program or contractual requirements; and (3) making false representations to any person or entity in order to gain or retain participation in a program or to obtain payment for any service.
      3. Discrimination. LHCC believes that the fair and equitable treatment of employees, patients and other persons is critical to fulfilling its vision and goals. It is a policy of LHCC to treat patients without regard to the race, color, religion, sex, ethnic origin, age or disability of such person, or any other classification prohibited by law. It is a policy of LHCC to recruit, hire, train, promote, assign, transfer, layoff, recall and terminate employees based on their own ability, achievement, experience and conduct without regard to race, color, religion, sex, ethnic origin, age or disability, or any other classification prohibited by law. No form of harassment or discrimination on the basis of sex, race, color, disability, age, religion or ethnic origin or disability or any other classification prohibited by law will be permitted.  Each allegation of harassment or discrimination will be promptly investigated.
      4. Stark. All employees must comply with applicable Stark Regulations and similar laws which regulate self-referral and compensation. Examples of provisions included in these laws are (1) agreements for "kickbacks" between doctors and providers; (2) supervision by referring physicians of those providing designated health services to qualify for the in-office ancillary service exception; (3) managed care exemptions; (4) exception where no alternative provider is available; (5) reporting of provider financial relationships and those of their immediate families; and (6) a list of designated health services that are covered by the self-referral ban. LHCC employees in managerial or administrative positions are expected to seek advice from LHCC's Compliance Officer, who shall refer the issue to LHCC's outside legal counsel when confronted with business decisions involving a risk of violation of the self-referral and compensation laws.
      5. OSHA. All employees must comply with LHCC's OSHA Policy Manual.
      6. ADA. LHCC and LHCC's employees will comply with the Americans with Disabilities Act (ADA). The ADA prohibits discrimination on the basis of disability for goods and services provided to LHCC patients. Each allegation of discrimination will be promptly investigated.

    BUSINESS ETHICS

    1. Principle. Infurtherance of LHCC's commitment to the highest standards of business ethics and integrity, employees shall strive to accurately and honestly represent LHCC and shall strive not to engage in any activity or scheme intended to defraud anyone of money, property or honest services. Furthermore, any LHCC employee aware of any potential violation of the federal fraud and abuse laws shall have the primary obligation to report such potential wrongdoing to the professional corporation.
    2. Standards. The standards set forth below are designed to provide guidance to ensure that LHCC's business activities reflect the high standards of business ethics and integrity.  Employee conduct not specifically addressed by these standards must be consistent with LHCC's Principle with respect to "Business Ethics".
      1. Honest Communication. LHCC requires candor and honesty from its employees in the performance of their responsibilities and in communication with LHCC's Compliance Officer. No employee shall make false or misleading statements to any patient, person or entity doing business with LHCC about other patients, persons or entities doing business or competing with LHCC, or about the products or services of LHCC or its competitors.
      2. Misappropriation of Proprietary Information LHCC employees shall not misappropriate confidential or proprietary information belonging to another person or entity nor utilize any publication, document, computer program, information or product in violation of a third party's interest in such product. All LHCC employees are responsible to ensure they do not improperly copy, for their own use, documents or computer programs in violation of applicable copyright laws or licensing agreements. Employees shall not utilize confidential business information obtained from competitors, including customers lists, price lists, contracts or other information in violation of a covenant not to compete, prior employment agreements, or in any other manner likely to provide an unfair competitive advantage to LHCC.

    Revised 4/2014

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