Open Cities Health Center, Inc.

Code of Conduct

January, 2000

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TABLE OF CONTENTS

OUR MISSION......

INTRODUCTION......

BASIC PRINCIPLES......

Principle One: Patient Care......

Principle Two: Legal Compliance......

A.Fraud and Abuse......

B.Billing and Reimbursement......

C.Antitrust......

D.Laws Concerning Children and Vulnerable Adults......

E.Laws Concerning an Environment that is Respectful of Others......

F.Substance Abuse......

G.Lobbying and Political Activities......

H. Tax......

Principle Three: Business Ethics and Communications......

A.Communications with Governmental Agencies and Regulators......

B.Communications with Others......

C.Gifts from Patients......

D.Gifts From Purchasers, Suppliers and Providers......

Principle Four: Confidentiality......

Principle Five: Conflicts of Interest......

A.Outside Interests and Activities......

B.Inside Information......

C.Serving on Outside Boards......

Principle Six: Protection of Model Cities Health Center’s Assets......

A.Financial Reporting......

B.Honoraria......

C.Travel and Entertainment......

D.Personal Use of Corporate Assets......

YOUR COMPLIANCE RESOURCES......

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OUR MISSION

The mission of Model Cities Health Center, Inc. (“OCHC”) is to provide quality health care services to all persons, with an emphasis on improving the health of our community.

Further, we are committed to assuring that underserved and vulnerable people get the health care they need. To that end, we provide the following family-oriented primary and preventive health care services for people living in our community.

  • primary and preventive care, outreach, and dental care
  • essential ancillary services including laboratory test, x-rays, environmental health and pharmacy services
  • health education, transportation, translation and prenatal services
  • links to public assistance (MFIP), Medical Assistance, MinnesotaCare, Medicare, substance abuse treatment, WIC, counseling, and other related support services

We are committed providing our services in an environment free from intimidation, harassment, and unequal treatment with regards to race, color, sex, national origin, marital status, sexual orientation, or disability. We are committed to conducting our business activities in compliance with applicable law and protecting and promoting the integrity of our patients, our employees and OCHC.

INTRODUCTION TO THE CODE OF CONDUCT

Our mission guides us as we do our work. This Code of Conduct is an extension of our mission. It contains six principles that provide more detail on our expectations for everyone’s conduct and behavior. It is expected that you review this document and refer to the principles as you carry out your work. You are expected to conduct yourself in a manner consistent with these principles and the more specific guidance set forth below each principle.

Keep in mind the following as you read this Code:

  • If you find yourself in a situation where you are unsure how to act, or if you simply have concerns, help is available. Contact your supervisor or any of the people noted in the Compliance Resources Directory. An anonymous Compliance Reporting Box is also available.
  • If you believe you are being asked to do something that is against this Code of Conduct or the law, talk to your supervisor to make sure you and your supervisor understand the situation. If your concerns are not resolved to your satisfaction or, if for some reason it is not feasible to discuss the issue with your supervisor, use one of the other Compliance Resources available to you. These are listed on the following page.
  • OCHC may change this Code at any time and will communicate changes to you as quickly as possible.
  • This Code is not a contract for the provision of any benefit to any employee, volunteer, agent, client or other person.
  • You may be subject to discipline for violating the principles set forth in this Code consistent with OCHC human resource policies.
  • This Code, applies to all officers, directors, employees, independent contractors, students, volunteers and interns while providing services at OCHC.

BASIC PRINCIPLES

This is a summary of each of the six principles that make up OCHC Code of Conduct. For more detail about each principle, refer to the corresponding sections in this document.

Principle One: Patient Care

We will strive to provide services to our patients that are of the highest possible quality.

Principle Two: Legal Compliance

We are committed to conducting all of OCHC’s activities in compliance with all applicable laws.

Principle Three: Business Ethics and Communications

We are committed to the highest standards of business ethics and integrity. All business relationships with vendors, contractors and other third parties must be free from offers or solicitation of gifts and favors or improper inducements.

Principle Four: Confidentiality

We will maintain the confidentiality of patient records and other confidential information in accordance with applicable legal and ethical standards.

Principle Five: Conflicts of Interest

You may not use your position to make a personal profit or to assist others in profiting in any way at the expense of OCHC. You are expected to conduct your activities so as to avoid conflicts of interest and the appearance of conflicts.

Principle Six: Protection of Model Cities Health Center’s Assets

You must safeguard and protect OCHC assets by making prudent and effective use of OCHC resources and by properly and accurately reporting its financial condition.

Principle One: Patient Care and Community Health

We will strive to provide services to our patients that are comprehensive, culturally competent, and of the highest possible quality.

OCHC is committed to providing high quality health care and related services to all of our patients in a manner that responds to that patient’s particular needs. We will strive to provide comprehensive care to our patients, including not only primary and preventative health care and dental care, but also health education, transportation, translation, and prenatal services. We will strive to provide links to public assistance (MFIP), Medical Assistance, MinnesotaCare, Medicare, substance abuse treatment, and other support services as appropriate for each individual patient.

In addition to quality patient care, we are committed to improving the health of our community. We are committed to community health education and prevention programs, such as health fairs, working within the schools, immunization programs and other related efforts to increase access to quality health care in the community we serve.

We will make every effort to provide culturally competent care to our patients. We will not make a distinction on the grounds of race, color, national origin, sex, marital status, sexual orientation, or disability in the treatment of patients, the use of equipment and other facilities, or in the assignment of personnel to provide services.

We will treat all patients without regard to their income or insurance status. If a patient has insurance, care will only be provided consistent with the terms of that coverage and applicable federal and state law.

All of our patients have a fundamental right to considerate care that protects each individual’s dignity and privacy. We must safeguard this right in all aspects of patient care. We recognize that a patient may or may not decide to involve family members in his or her care decisions. When a family member or guardian is involved in a patient’s care decisions, we will treat the family member or guardian with the same respect and dignity that we offer the patient.

Principle Two: Legal Compliance

We are committed to conducting all of OCHC’s activities in compliance with all applicable laws.

You must conduct yourself lawfully when acting on behalf of OCHC. While this Code does not provide an exhaustive discussion of all laws and regulations applicable to OCHC, it identifies some of the more important issues you must consider. You are expected to be familiar with and abide by all legal requirements related to the rights, safety, and health of patients and to the rules that apply to payment for services. If you are not familiar with these laws, or have any questions about them, contact your supervisor.

A.Fraud and Abuse

You must refrain from conduct which may violate fraud and abuse laws. These laws prohibit:

  • Payments in exchange for the referral of patients;
  • Submitting false, fraudulent or misleading claims to any government entity or third party payor, 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
  • 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.

If you have any questions regarding these rules, please contact your supervisor.

B.Billing and Reimbursement

Almost all of our patients receive assistance from a state or federal program, receive benefits from a private insurance company, or have services covered by a federal grant. In order for OCHC to be reimbursed by these payors, we must strictly comply with the technical rules established by laws, regulations and contractual requirements. Because these rules vary from program to program and from insurance company to insurance company, different rules may be applicable for different patients. You must recognize that these rules may dictate the procedures to be followed and records to be kept with respect to each individual patient. You are expected to be familiar with and to follow the billing and reimbursement rules applicable to the services they provide. If you have any questions about these procedures, please contact your supervisor.

C.Antitrust

You must uphold all antitrust and similar laws that regulate competition. Examples of conduct prohibited by these laws include:

  • Agreements to fix prices, bid rigging, collusion (including price sharing) with competitors;
  • Boycott, certain exclusive dealing, and price discrimination agreements; and
  • Unfair trade practices, including bribery, misappropriation of trade secrets, deception, intimidation and similar unfair practices.

D.Laws Concerning Children and Vulnerable Adults

OCHC is committed to providing care to patients in a manner that complies with laws that protect the rights of persons with disabilities, the elderly, children, or others who may be vulnerable to abuse or neglect. You must continually strive to maintain a clinic environment that is free from the maltreatment of the physical, emotional, spiritual, and financial status of children and vulnerable persons.

OCHC is also committed to preventing, detecting, and, where appropriate, reporting of suspected abuse or neglect of any person receiving services at OCHC, adult or child. If you suspect abuse or neglect of any patient or patient’s child either at home, at school, at day care, at work, or in the clinic setting, you should immediately discuss your suspicion with your supervisor, the Compliance Officer or the Executive Director. In certain circumstances, you are also required to make reports to state authorities.

E.Laws Concerning an Environment that is Respectful of Others

OCHC believes that fair and equitable treatment of employees, patients and others is essential to fulfilling our mission. Patients, employees and other individuals entering OCHC can expect to be treated without bias as to race, color, creed, religion, national origin, marital status, gender, status with regard to public assistance, sexual orientation, age, disability, or any other classification protected by law.

It is also our policy to recruit, hire, train, promote, assign, transfer, lay off, recall, and terminate employees based on their own abilities, achievements, experience, and conduct without regard to any protected class status.

OCHC will not tolerate any form of illegal harassment or discrimination. Each allegation will be properly investigated in accordance with OCHC human resources policies.

F.Substance Abuse

OCHC is committed to creating a work environment that is free from substance abuse. As an employee of OCHC, you must comply with state and federal laws and OCHC policies regarding controlled substances. In addition, you must report any suspected use of drugs or alcohol while on the job to your supervisor, the Compliance Officer or the Executive Director.

G.Advocacy and Political Activities

Employees must not engage in any activity that may place OCHC’s tax-exempt status in jeopardy or that would violate any laws regarding lobbying, advocacy, or political activity. Certain advocacy and political activities may adversely affect the organization, and employees must be aware of them:

  • Employees may not contribute any of OCHC money or property, or the services of any OCHC director, officer or employee, to any political candidate, party, organization, committee or individual, in violation of any applicable law. Directors, officers and employees may personally participate in and contribute to political organizations or campaigns as individuals--not as representatives of OCHC--and they must use their own funds.
  • Any attempts to influence the decision-making process of governmental bodies or officials by an improper offer of a benefit is absolutely prohibited. Any requests or demand by any government representative for any improper benefit should be immediately reported to your supervisor. We have many contacts and dealings with governmental bodies and officials. You should conduct all such contacts and transactions in an honest and ethical manner.

Where its experience may be helpful, OCHC may publicly offer recommendations concerning legislation or regulations being considered. In addition, it may analyze and take public positions on these issues that have a relationship to the operations of OCHC when our experience contributes to the understanding of such issues.

H. Tax

OCHC must comply with applicable tax laws. We will engage in activities to promote our charitable purpose, and to ensure that our resources will be used to further the public good rather than the private or personal interests of any individual. Consequently, OCHC and its officers, directors, and employees must avoid compensation arrangements in excess of fair market value, accurately report payments to appropriate taxing authorities, and file all tax and information returns according to applicable laws.

Principle Three: Business Ethics and Communications

We are committed to the highest standards of business ethics and integrity. All business relationships with vendors, contractors and other third parties must be free from offers or solicitation of gifts and favors or improper inducements.

A.Communications with Governmental Agencies and Regulators

All OCHC employees who have contact with governmental agencies in the regular course of their duties must make only thoughtful, honest, and accurate statements to the agencies and their representatives. It is a violation of this principle to make any false or misleading statements to any regulatory agency either in conversation or in written documents such as government health care program claims, federal, local, and state income tax returns, and other filings made with governmental agencies. OCHC is committed to cooperating with appropriate government investigations or inquiries about possible violations of the law.

You must immediately report to your supervisor, the Compliance Officer or the Executive Director any contact initiated by a governmental agency involving billing or financial or reimbursement issues that does not occur in the normal course of your duties. If you are contacted by a regulatory official as a part of an investigation, to the extent possible, you should avoid answering any questions or producing any documents before discussing the requests with your supervisor, the Compliance Officer or the Executive Director. You must remember that your answers to government inquiries matter greatly in any investigation. Any answer you give must be true and must accurately represent your responsibilities and OCHC activities. In addition, state and federal laws govern the release of certain types of confidential information and should be considered before responding to any requests.

B.Communications with Others

You are expected to communicate with candor and honesty in performing your job. You must not make false or misleading statements to any patient, person, or entity doing business with OCHC. Any communication with the media should be referred to the Executive Director.

C.Gifts from Patients

You must strive to create an environment at OCHC that is free from the appearance of impropriety. As a result, you may not solicit tips, personal gratuities or gifts of any kind from patients or family members. Items of nominal or minor value ($25.00 or less) may be accepted. If you have any questions about receiving a gift, please contact your supervisor, the Compliance Officer or the Executive Director.

D.Gifts From Purchasers, Suppliers and Providers

You may not accept gifts, meals, favors, services, entertainment or other things of value from purchasers, suppliers, or health care service providers if there is any possibility that the gift may appear to influence your decision-making, whether or not it actually influences your decisions. Items of nominal or minor value ($25.00 or less) may be accepted. In addition, you may not offer or give money, gifts, meals, services or other things of value to influence any purchaser, supplier, customer, government official or other person. If you have to think about whether a gift falls into this category, it probably does, so decline it or don’t give it. If you have any questions on these issues, please contact your supervisor, the Compliance Officer or the Executive Director.

Principle Four: Confidentiality

We will maintain the confidentiality of patient records and other confidential information in accordance with applicable legal and ethical standards.

You must maintain the confidentiality of patient information. Do not reveal any personal or confidential information concerning patients unless there is a legitimate business or patient care purpose. In certain circumstances, written consent must be received before you may release the information. If you have any questions about whether certain information is confidential or the release of information is appropriate, ask your supervisor, the Compliance Officer or the Executive Director.

As an employee of OCHC, you may also possess and have access to a wide variety of OCHC confidential and sensitive business information. You must actively protect and safeguard OCHC confidential and sensitive business information, and prevent the unauthorized disclosure of that information.