Corporate Compliance Policy
Ethics and accountability are central to the core values and mission of Elder Outreach, operating company of Pleasant Valley Nursing and Rehabilitation. Our residents and their families put their trust in us, as do our personnel, clinicians, vendors, business partners, and others, including the communities we serve. We share the important responsibility to continuously strive to achieve the highest standards of ethical conduct.
Elder Outreach is committed to providing the highest quality care to our residents and conducting business with integrity and in compliance with applicable Federal and state laws and regulations. To this end, Elder Outreach’s Compliance Program expects all employees, as well as all persons and entities with which we contract or who maintain staff privileges, to comply.
As part of our Compliance Program, our Code of Conduct provides general guidance relating to conducting business with honesty and integrity. These standards also provide certain compliance guidance regarding referral activities, the provision of services, and the billing of those services. The Compliance Program provides a mechanism which allows us to identify potential compliance risk areas; address questions and concerns; and implement corrective action, as necessary. We have appointed a corporate compliance officer to oversee the day-to-day activities of the Compliance Program and to perform appropriate audits.
In addition, as a participant in the Medicaid program, we are required to comply with the terms and conditions of the Deficit Reduction Act of 2005 (the “Act”). In accordance with the Act, we are required to establish written policies for all employees and contractors and agents that provide detailed information about the Federal False Claims Act; Federal administrative remedies for false claims and statements; the Louisiana and Arkansas false claims provisions, state penalties (both civil or criminal) for false claims, statements, and whistleblower protections under such laws; and the role of these laws in preventing and detecting fraud, waste, and abuse in Federal health care programs.
CODE OF CONDUCT
Elder Outreach’s Code of Conduct is meant for all employees, physicians, volunteers, and other representatives of Elder Outreach, as well as vendors, suppliers, and independent contractors. The reason for the Code of Conduct is to create and communicate our expectations in promoting an ethical environment and to demonstrate Elder Outreach’s system-wide emphasis on compliance with all policies and procedures, as well as state, federal, and administrative regulations.
All persons associated with Elder Outreach have an obligation to conduct themselves in ways that merit the trust and confidence of peers, as well as the general public. It is expected that this Code of Conduct will be discussed and applied to the entire spectrum of responsibilities of all health professionals, including but not limited to, management, clinical and administrative staff, licensed independent practitioners, governing body members, employees, volunteers, and independent contractors.
STANDARDS OF CONDUCT
Legal Compliance: Elder Outreach shall strive to ensure all activities are in compliance with all state, federal, local, and administrative regulations.
Confidentiality: All employees shall actively protect and safeguard confidential, sensitive, proprietary information, and protected health information in a manner designed to prevent the unauthorized disclosure of such information, in accordance with HIPAA and Hi-Tech laws.
Business Ethics: Elder Outreach commits to the highest standards of business ethics and integrity.
Intimidating and/or Disruptive Behavior: All employees, physicians, volunteers, and other representatives of Elder Outreach are held to the highest standards of conduct in all areas related to their employment. Inappropriate conduct of any kind, including but not limited to, disruptive, discourteous, disrespectful, abusive behavior, or any other behavior deemed inappropriate will be subject to disciplinary action based on the circumstances of the situation.
Response and Discipline: Elder Outreach is committed to creating and fostering a culture in which compliant behavior is encouraged and supported. Elder Outreach is also committed to promptly responding to reported or detected violations of Company policies and developing corrective action where necessary. Those who violate Elder Outreach’s Code of Conduct, compliance policies and procedures, or any law, rule, or regulations under which Elder Outreach operates will be subject to disciplinary action.
Elder Outreach has instituted a Compliance Program to ensure all business practices are in compliance with the applicable Company policies and procedures and applicable civil and criminal laws, rules, and regulations.
A key element of the Organization’s Compliance Program is the ability of employees to express problems, concerns, or opinions without fear of retaliation or reprisal. At the same time, employees have an affirmative duty to report issues or concerns that come to them through the appropriate channels. Failure to do so can result in disciplinary action up to and including termination.
The Organization will not take disciplinary or retaliatory action against an employee who in good faith raises a compliance concern or otherwise participates in the Compliance Program. Retaliation in any form by any individual associated with the Organization is strictly prohibited and is a serious violation of the Code of Conduct.
Our Compliance Program’s Code of Conduct sets general directives for all personnel associated with the Organization to act in a lawful manner and to avoid dishonest behavior, even in the appearance of impropriety.
CORPORATE COMPLIANCE HOTLINE
Elder Outreach provides the Hotline as a service to its directors/trustees, officers, managers, employees, medical staff, contractors, volunteers, patients, and family members to confidentially report information regarding suspected misconduct, fraud or abuse, or any other legitimate concerns. Information provided to the Hotline is treated confidentially and privileged to the extent permitted by applicable law.