Connections - Health - Wellness - Advocacy

Code of Ethics

 

Overview of policy

The Code of Ethics was prepared for the benefit of Connections: Health*Wellness*Advocacy (“Connections”), its members (Board Members, Officers and Employees) and affiliates, as well as their employees and all other members of our community.  The Code is a dynamic document, which shall develop through time with the efforts and contributions of all employees.  Each of the following issues shall be considered in connection with the Code of Ethics and its application to the daily activities of Connections.

The Code of Ethics is in addition to, and not instead of, specific policies and procedures of Connections.  It shall remain the duty of each employee to perform their respective duties in accordance with those policies and procedures.

Connections affirms its commitment to provide patient-friendly, quality behavioral health care in compliance with all federal, state and local laws and regulations governing our operations.  We pledge to do so within the highest moral and ethical standards required by our leadership role. It is the responsibility of the leadership of Connections to evidence the values embodied in this Code of Ethics by personal example and their management practices. 

The following are some of the core principles of the Connections Code of Ethics:

    1. Excellence as the standard of quality for our services;
    2. Honest communications;
    3. Respect for patient rights, including confidentiality and privacy;
    4. Fairness in our business dealings including disclosure to address conflicts of interest  and cost-effective financial management;
    5. Equal opportunity and a positive work environment;
    6. Partnership with our patients and families;
    7. Civic duty to comply with federal, state and local laws, rules and regulations;
    8. Zero tolerance of criminal activity, or conspiracy to commit a crime.

Highest Level of Cost-Effective Patient Care

To maintain our role as leaders, our services must be reasonable, necessary and medically appropriate for the care of each patient.  To that end, it must be provided by properly qualified caregivers who share our values.  That care must also be cost effective and affordable by the communities that we serve.  Clinical decisions will be based on identified patient health care needs and not solely on financial issues.

    1. Admission, discharge and transfer policies will be in compliance with all applicable laws and regulations and will not be solely based on patient or Agency economics.
    2. Unless requested by the patient, only patients whose specific condition cannot be treated at Connections will be referred to another Agency.
    3. All employees and agents of Connections, both clinical and non-clinical, shall support Connections in the establishment and maintenance of medical records and other documents which conform to legal, professional and ethical standards.  Connections shall also ensure that claims submitted for payment or reimbursement for services will only be for such care that is provided by properly qualified persons and that it is billed accurately and documented.
    4. Patients or other payors who have questions about their bill for services will be provided an opportunity to discuss charges and resolve disputes without harassment.
    5. All patient care and its corresponding records must be completed to meet the standards of documentation as required by laws and regulations, payor requirements, and professional standards.  Connections and all of its members will take the affirmative steps necessary to protect the confidentiality of those records.

Education on Ethical Codes 

All employee are trained on Connections’ Code of Ethics upon hire and annually thereafter.

Personal and Professional Ethical Standards

Ethical conduct by all those affiliated with Connections is vital to maintaining an effective Corporate Compliance Program.  All members of Connections should adhere to a high level of personal and professional ethical standards.

An Ethics Committee has been established to serve as an advisory body to Connections’ Clinicians, as well as patients and their families, on matters relating to bioethical decisions arising during the provision of patient treatment, as well as organizational ethical issues.

Connections is a non-profit corporation dedicated to the provision of quality health care services.  All members of Connections must act with loyalty in their conduct for the purpose, benefit and interest of Connections and those served by its members.  As a result, all employees have a corresponding duty to avoid conflicts of interest with those of Connections, and may not use their position and affiliation with the organization for their personal benefit.

No Retaliation Policy 

It is a violation of the Corporate Compliance Program and this Code of Ethics to initiate or allow any type of retaliation or reprisal against anyone making a good faith report of a concern or potential violation of the Code of Ethics. It is an obligation, then, of each board member, employee, physician and affiliate to fulfill the mission of Connections by acting in accordance with this Code of Ethics. This obligation includes the use of our best efforts to assure similar conduct by our vendors and affiliates.

Process for Reporting Violations 

An integral part of the Corporate Compliance Program is the establishment of a mechanism in which employees, volunteers, students, contracted providers, and other stakeholders may, anonymously if so desired, report violations of the Code of Ethics or other non-compliant activity.  If any person sees or experiences potential misconduct, including inappropriate business practices, the first avenue of reporting should be their Clinical Supervisor, Human Resources, or the Corporate Compliance Officer.

Any questions about legality or ethical nature of any actions by or on behalf of Connections should be referred to the appropriate supervisory or management representatives.  If there is a continued uncertainty after an internal review, then an employee has the right to contact the President & CEO.

It is the duty of each employee within Connections to uphold the standards set forth in the Code of Ethics and to report violations through procedures outlined in the Corporate Compliance Plan.

Disciplinary action for violations of the Code of Ethics and the Corporate Compliance Plan shall be enforced through each member’s discipline on a case-by-case basis, and may result in termination of employment.  If Connections determines that such a violation may include criminal violation of an applicable law or regulation, Connections will advise the appropriate law enforcement authorities of that possibility and cooperate with that authority in regard to any subsequent investigation or prosecution of that person. 

Patients and other stakeholders 

Respect must be demonstrated at all times to our patients, fellow employees and all those that we come in contact with on a daily basis.  We operate in good faith and take all reasonable steps to prevent, detect, investigate and address any fraud, waste, theft, abuse or other wrongdoing against our patients.

Vendors, Suppliers and Contractors 

Connections must provide services and conduct business in a manner that will reflect our values.  To achieve our mission, our conduct must be legal in regard to rules and regulations.  Our conduct in business, marketing, service delivery, and professional responsibilities must also be moral and ethical in regard to our obligations to others. This obligation includes the use of our best efforts to assure similar conduct by our vendors and affiliates.

Marketing 

Marketing efforts shall not mislead the public or misrepresent Connections as to the types of service available.  Should the patient require or request services not available or inconsistent with the Connections mission, referrals will be given to the patient for appropriate options.

Be truthful and accurate when describing the quality, features, or availability of services to our patients. Be similarly careful in describing a competitor’s Services or services. It is never appropriate to criticize a competitor to a patient or interfere with any contact between a patient and a competitor.

Equal Opportunity 

Connections is an equal opportunity employer for all persons without regard to race, color, national origin, sex, age, religion, creed, marital status, sexual orientation, veteran status, or handicap, including persons known to have HIV and/or AIDS.  It is also our policy to adhere to all relevant provisions of the Americans with Disabilities Act (ADA).  We will make reasonable accommodations wherever necessary for all employees or applicants with disabilities, provided that the individual is otherwise qualified to safely perform the duties and assignments required and that the accommodations made do not require unreasonable difficulty or expense.  Additionally, Connections is committed to providing a dignified work environment, free from any form of harassment or discrimination and will thoroughly investigate any alleged instances and take corrective action if warranted.

Health and Safety 

Connections shall work to ensure a workplace which conforms to all laws and regulations regarding occupational health and safety.  Connections is committed to proper maintenance of the environment. All medical waste, hazardous materials and other Services shall be utilized and disposed of in a manner that conforms to all applicable environmental laws and regulations.

Harassment Free Workplace

Harassment may take many forms, from overt advances to demeaning comments, jokes, language, and gestures. Even if it is not intended in a harassing manner, such behavior may be perceived as harassment and it is important to be sensitive to how others could see such behavior.

Whenever words, behaviors, or actions of the employee create an intimidating, hostile, or offensive environment, it may be considered harassment. Although it may not involve a direct threat, it can be destructive to a positive working environment.

In the event an unwanted sexual advance is made and reported, your job, evaluation, pay or work assignments are not threatened because a sexual advance was rejected.

As stated in the above “No Retaliation Policy,” there is to be no retaliation or reprisal for reporting harassment.

Conflict of Interest 

Connections and its employees strive to avoid any situation that holds potential to act in a manner that is not in the best interest of the organization. Selection of vendors or suppliers, as well as purchasing decisions must always be made on the basis of evaluating and comparing price, quality, performance and suitability. Decisions are not influenced by any other factor, such as personal relationships, gifts, hospitality or anything else of direct or indirect value.

Connections’ Board Members and Officers must review its Policy Regarding Conflicts of Interest and sign its Disclosure of Interest Certificate.

Patients (includes exchange of gifts, money and gratuities)

 Connections and its employees understand the challenges of accepting gifts from patients and recognize that in some cultures small gifts are a token of respect and gratitude. When determining whether to accept a gift from a patient each employee must take into consideration the therapeutic relationship, the monetary value of the gift, a patient’s motivation for giving the gift, and the Clinician’s motivation for wanting or declining the gift. Any concerns an employee has about this should be discussed with his or her supervisor.

Personal gains 

Connections and its employees must strive to act in a manner that is in the best interest of the organization. Selection of vendor or suppliers, as well as purchasing decisions must always be made on the basis of evaluating and comparing price, quality, performance and suitability. Decisions are not to be influenced by any other factor, such as personal relationships, gifts, hospitality or anything else of direct or indirect value.

Although it is never appropriate to request a gift, it is often proper to accept unsolicited gifts from suppliers whenever that practice is customary for one’s job or position. It is never allowable to accept cash or a cash equivalent such as checks, money orders, or vouchers. It is especially important to avoid even the appearance of conflict of interests. As a general rule, it best not to accept anything beyond an occasional meal or gift of a nominal value.

All members of Connections must act with loyalty in their conduct for the purpose, benefit and interest of Connections and those served by its members.  As a result, all employees have a corresponding duty to avoid conflicts of interest with those of Connections and may not use their position and affiliation with the organization for their personal benefit.

Patient Information 

Connections is committed to respecting our patients’ privacy and confidentiality through compliance with all related laws and standards, particularly the HIPAA (Health Insurance Portability and Accountability Act of 1996) regulations regarding privacy of protected health information. All patient care and its corresponding records must be completed to meet the standards of documentation as required by laws and regulations, payor requirements, and professional standards.  Connections and all of its members will take the affirmative steps necessary to protect the confidentiality of those records.

Privacy of Communications 

Confidentiality of patient and employee records is the cornerstone of our Corporate Compliance Program.  For our patients this means that all information collected for the provision of medical care belongs to them.  It will not be released without their permission, and if released, only according to the applicable laws and regulations.  For our employees this means that all disciplinary activity and compliance issues will remain confidential and restricted to the employee and those members who are directly involved.

Intellectual Property 

Connections’ creativity and innovative ideas make significant contributions to its continued success in the marketplace. Employees are encouraged to us their skills and knowledge to develop new and improved services and to discover improved ways to work. The company’s accomplishments depend on protecting our intellectual property. Therefore, it is important to not leave proprietary information lying visibly on our desks or in other places where it could be easily found by unauthorized individuals. We must not discuss confidential information in a public or private place, where it could be overheard. We also need to follow required procedures for safeguarding and disposing of proprietary information.

Waste, Fraud, Theft, Abuse Other Wrong Doing 

In order to safeguard the ethical, organizational and financial wellbeing and reputation of Connections the organization has a duty to conduct its affairs in a professional, ethical, responsible and transparent way and to follow applicable laws, regulations, contract requirements and standards. We operate in good faith and take all reasonable steps to prevent, detect, investigate and address any fraud, waste, theft, abuse or other wrongdoing.

Connections employees will abide by the following:

    1. Employees work together to create an organizational culture and environment that is risk-averse and discourages and prevents such actions.
    2. Employees are responsible for knowing the signs of potential fraud, waste, theft, abuse or other wrongdoing. These signs include, but are not limited to prime documents being lost and replaced by photocopies; an unexplained sudden change in lifestyles; new personnel resigning quickly; and suppliers/contractors/customers insisting on dealing with a particular employee.