COMPLIANCE PROGRAM & CODE OF CONDUCT (YOUR AGENCY)

Compliance & Ethics What is compliance? – In it’s simplest form, compliance means following a rule or request. In healthcare, when we talk about compliance, we refer to following the rules, regulations, policies and laws created by the government, insurance programs and payors. What is ethics? – Ethics simply means doing the right thing. Ethics goes beyond what is allowed by laws and regulations. What is Karmanos’ philosophy regarding compliance and ethics? – Karmanos will fully comply with all applicable federal and state laws, regulations, standards and other compliance requirements at all levels of government and within the various health professions employed at Karmanos. We will not pursue any business opportunity that requires unethical or illegal activity.

Compliance & Ethics A Compliance Program has been established at (YOUR AGENCY) to assist our organization in promoting our commitment to the highest legal and ethical standards. This program has the commitment of everyone at (YOUR AGENCY) including the management, employees, and others associated with (YOUR AGENCY) This program provides education, conducts investigations where there are allegations of misconduct, takes part in monitoring activities, such as audits, to assess areas of risk within the organization. This program provides a pro-active approach to compliance thereby helping the organization maintain it’s commitment to the highest level of compliance and ethical standards. Compliance is part of all of our jobs and depends on everyone’s participation for continued succes.

Elements of (YOUR AGENCY) Complance Program (Your Agency) Compliance Program includes the seven elements of an effective compliance program as defined by the US Federal Sentencing Guidelines: 1. Written standards of conduct and policies and procedures thatpromote the hospital ’ s commitment to compliance. 2. A Compliance Officer to oversee the program. 3. Compliance education and training for all new hires, with annualtraining for all staff. 4. Processes to receive anonymous complaints and to allowcomplaints from staff without any fear of retaliation (for example,the hotline). 5. Responding to allegations of improper activities and, whennecessary, developing a corrective action plan. 6. Auditing and monitoring to identify potential areas of risk. 7. Investigation and remediation of identified systemic problems andnon-employment or retention of sanctioned individuals.

Compliance Policies As required by the Federal Sentencing Guidelines, (YOUR AGENCY) has policies and procedures in place to ensure compliance with laws and regulations.

Code of Conduct Standards Standard (YOUR AGENCY) Commitment 1 -Quality of Care and Services To improve the health of the recipients we serve by providing the highest quality health care services in a caring and efficient manner. 2 -Privacy & Confidentiality To fulfill regulatory standards designed to handle all facets of information management, including reimbursement, coding, security, and patient records. 3 -Coding/Billing Integrity and Record Keeping To maintain timely and accurate patient records and billing only for services actually rendered as documents in patient medical records.

Code of Conduct Standards Standard (YOUR AGENCY) Commitment 4 -Customer Service To apply the Customer Service Standards, which are core to our values, to every interaction with every individual at all times focusing on servicing our patients and families. 5 -Compliance with Laws and Regulations To require all staff members conduct their individual duties and all KCC operations in a manner that meets all applicable legal, ethical and regulatory standards. 6 -Work Place Conduct and Employment Practices To create a work environment in which employees and others are treated respectfully, fairly and afforded opportunities for professional development.

Code of Conduct 7. Not Accept Inappropriate Gifts or Gratuities. Employees are prohibited from soliciting tips, personal gratuities or gifts from recipients and vendors. 8. Giving Gifts to Recipients and Vendors: Employees shall not offer or give money, services or other things of value with the expectation of influencing the judgment or decision making process of any purchaser, vendor, recipient, governmental official or any other person. 9. Avoid Conflicts of Interest. Employees are prohibited from engaging in any activity, practice, or act which conflicts with, or appears to conflict with, the interests of (YOUR AGENCY), its recipients or its vendors.

Code of Conduct 10. Keep Accurate and Complete Records. Employees report accurate information to governmental entities and other third parties. In order to meet this obligation, it is equally essential that every employee accurately and clearly report the relevant facts or the true nature of all care provided. 11. Provide a Safe Workplace. It is the policy of (YOUR AGENCY) to comply with all applicable state and federal laws designed to improve workplace safety. (YOUR AGENCY) is committed to training employees to carry out their work in manner that is safe for them, their coworkers and the recipients they serve. 12. Not Tolerate Harassment or Discrimination. (YOUR AGENCY)’s policy not to discriminate on the basis of race, color, religion, national origin, age, disability, sexual orientation, or gender in providing services to recipients or the public, nor in relation to employment practices.

Code of Conduct 12. Not Tolerate Harassment or Discrimination. (YOUR AGENCY)’s policy not to discriminate on the basis of race, color, religion, national origin, age, disability, sexual orientation, or gender in providing services to recipients or the public, nor in relation to employment practices. 13. Protect Access to Information Systems. (YOUR AGENCY) is committed to protecting all aspects of its information systems and recipient records and Personal Health Information. All employees and other associates with access to (YOUR AGENCY)’s computerized information system shall sign and abide by (YOUR AGENCY)’s Responsible Use Policy, including the protection of confidential passwords and other access information.

Employee Code of Conduct: Ethical Behavior policy Following the Code of Conduct is mandatory for all (YOUR AGENCY) employees, staff and affiliated persons. While the Code of Conduct provides a basic description of unacceptable conduct or performance it does not cover all behaviors that may occur in the workplace. Policy Failure to comply with the code is a serious matter and can lead to disciplinary action (up to and including termination).

Code of Conduct Decision Making At times, a difficult situation may present itself and the right decision may not be clear or easy to make. As you consider possible actions to take, ask yourself these questions: 1.Is there a law or regulation that governs the situation? If there is, the law should be followed at all times. 2.Is there an internal policy or procedure that governs the situation? Would my action be consistent with KCC’s commitment to the highest ethical standards? 3.How would my actions be seen by someone outside the organization? 4.Would I feel comfortable explaining my actions to my friends and family? 5.What would the most ethical person I know do?

Code of Conduct Decision Making Doing the right thing is not always easy. We have all been tempted to take the easy way even if it was not the best way. Try to avoid these excuses for behavior that may not meet the requirements of our Code of Conduct: – All the other agencies are doing it this way. – No one will ever know. – I don’t have time to do it the right way. – I saw my supervisor doing it the other day. – That policy wasn’t meant to apply to me. – After all I have given this organization, I deserve something in return.