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Physician Compliance Services

A Pledge to Uphold the Hightest Professional Standards

Corporate Compliance Program Pledges of Principles

Maintaining compliance is crucial to our clients' success. Periodic checks and updates ensure ongoing compliance in all departmental operations. All procedures are performed in accordance with written contracts with third-party payers and all legal requirements. Company assets and information are continuously safeguarded and business is conducted with integrity and in compliance with all applicable federal, state and local laws and regulations.

Introduction and Compliance Program Overview

Purpose:

The purpose of this Pledge of Principles is to clearly state the legal rules and regulations that affect company activities for officers, providers and employees so that we will understand and apply them in our day-to-day activities.

General Business Conduct:

We conduct business with integrity and in compliance with all applicable federal, state and local laws and regulations.

Management and Individual Responsibility:

Officers, directors and supervisors share the responsibility of making sure that employees under their supervision are aware of and comply with the Compliance Program ("the Program"). Each employee is personally responsible for following the policies included through the provisions of the Program and seeking help, when needed, to avoid illegal business conduct.

Interpretation:

If you have a question about the Program, that is, how it should be interpreted or applied, it is your responsibility to contact your supervisor, the Legal Department or the Corporate Compliance Officer to obtain clarification and guidance.

Reporting Violations:

Not only are we responsible for complying with the provisions included in this Program but also for reporting any activity which we honestly and fairly believe may be a violation of any law or regulation, Company policy or any portion of the Pledge of Principles. Reporting violations is required and failure to report a known or suspected violation can in and of itself be a cause for discipline. To report violations, contact your supervisor, the Legal Department or the Corporate Compliance Officer.

Disciplinary Action:

Violation of any of these policies, failure to report a violation, retaliation against an employee who reports a violation, or a supervisor's failure to assure that employees under his or her supervision comply with the Program may result in disciplinary action and/or termination of employment for cause.

Pledge of Principles

Service Quality and Customer Care:

We work as a team to promote the reasonable satisfaction of patients, employees, providers, customers and third party payers. We are committed to providing quality service in an environment where patient rights are protected. We base each patient's plan of care on the assessed needs of the individual patient. We protect the integrity of a care provider's decisions to order tests, treatments and other interventions based on those needs. All employees conduct their practice, or perform their duties within the scope of their capabilities, licenses and certifications and applicable standards of care.

Informed Consent, Including Ethical Research:

We include patients in the decisions affecting their treatment plans. Patients are provided with sufficient information about the proposed treatment plan, research study or alternatives including the benefits, burdens and risks of the plan to enable them to make informed judgments about their participation. All clinical research is conducted ethically, in a manner that protects and respects the rights of patients.

Confidential Information:

We protect the confidential nature of all clinical, personnel, financial, commercial, technologic and business information. We access and divulge information in conformity with legal requirements only as appropriate to the Company's operations and the care of our patients. We are careful about written and spoken communications so that information is given only to people authorized to receive it, and unauthorized disclosures are prevented. It is especially important for us to safeguard medical information about patients and employees.

Safeguarding Company Assets and Information Gained as an Employee of the Company:

We protect organizational resources, including facilities, equipment, funds, information and data against loss, theft and misuse. We must use company information only for business purposes. We are all responsible for protecting this kind of information from inappropriate disclosure to those outside the company.

Record Keeping:

We prepare and keep all business data, information, clinical records and reports in a complete, accurate and timely manner. We store records in a safe and secure place for the time required by law or Company policy, whichever is longer.

Documentation of Services:

We document all patient care services in a proper, accurate, and timely manner and all billing is supported by such documentation. Patient records are legible and organized in a manner that makes them understandable.

Billing and Coding Integrity:

We perform billing, coding and reimbursement procedures in accordance with written contracts with third party payers and all legal requirements. Services are billed using only billing codes that accurately describe the services that were provided and accurately reflect documentation in the medical record. We do not engage in any improper coding techniques that would result in a classification and payment higher than one that properly reflects the service actually performed (upcoding). We do not bill services separately that are required to be billed together (unbundling). We bill only for medically appropriate services actually performed by licensed individuals.

Communication:

Clinical and billing staff communicate with each other effectively and accurately to ensure correct and timely billing.

Conflicts of Interest:

We avoid situations where our personal interests could conflict or appear to conflict with the interests of the company. A conflict of interest occurs whenever we permit the prospect of personal gain to improperly influence our business judgment. We make organizational decisions fairly and objectively to promote the best interests of the Company without favor, preference or based on personal considerations.

Self-dealing:

We are prohibited from using information gained through our employment at the Company for our own benefit.

Proper Accounting:

We must ensure that company payments and transactions are properly authorized by management and accurately and completely recorded in company records in keeping with Company policy and accepted accounting practices.

Receipt of Gifts, Gratuities or Favors:

We should not accept gifts, money, favors or other items of significant value (greater than $200.00) from anyone outside the company whose motivation is to receive some special treatment in exchange. Since it may be difficult to determine whether the giver's motivation is improper, it is best to refuse gifts offered to us by those outside the Company.

Use of Bribes, Kickbacks, Gifts or Gratuities in Business Dealings:

We market our Company's services on the basis of quality. We do not use gifts, bribes or false promises to improperly influence our customers or anyone with whom we deal. Neither we, nor our families, are allowed to receive kickbacks, rebates or anything of value, either directly or indirectly, from the Company's customers, vendors or payers except in accordance with the gift rules outlined above.

Gratuities and Government Employees:

We must faithfully abide by laws which regulate our dealings with government officials. Strict laws impose gift limitations and reporting requirements on gifts to federal, state and local officials. If we deal with government employees, we are responsible for knowing these limitations and properly reporting any expenditures.

Referrals:

We make patient referrals based only on the medical needs of the people we serve and we do not make payments or provide non-cash benefits to anyone for providing a patient referral, or to get such a referral.

Collections:

The Company pursues collections in accordance with the Fair Credit Reporting Act and all other applicable laws.

Contracts:

Only Company officers are authorized to sign contracts on behalf of the company. All contracts must be reviewed, in advance of signing, by our Legal Department.

Travel and Business Related Expenses:

We must promptly record business expenses we incur completely and accurately on expense reports. Entertainment, meals and travel expenses which we report on expense reports must have a business purpose.

Software Piracy:

When using software, we must take care not to duplicate it or use it in any unpermitted manner.

Antitrust:

We may not engage in any illegal discussions or exchange any illegal information with our competitors about pricing. Advertising and Promotion of Company Products and Services: We are truthful with our advertisements and promotions; we do not make misrepresentations of our services. All of our advertising must be reviewed in advance by the Legal Department.

Recording and Reporting Information:

Our Company's records must be accurately and completely maintained. We should never make false entries in Company records. False entries in reports submitted to the state or federal government, in particular, may expose us or the Company to civil and criminal penalties.

Political and Charitable Activity and Contributions:

Complicated laws regulate political contributions made by companies such as this. For this reason, all political contributions made from Company funds should be cleared in advance with the Legal Department. None of us should receive reimbursement from Company funds for personal political contributions. Corporate charitable contributions should be cleared first with the director of the department; final decisions regarding contributions are approved by the Chief Financial Officer.

Safety, Health and Environmental Protection:

The Company is committed to providing a healthful work environment. We must abide by safe operating procedures and all laws and regulations relating to health and safety issues.

Employee Relations:

We must not discriminate against employees or applicants on the basis of race, color, religion, sexual orientation, national origin, disability, gender, age or veteran status. We value diversity and recognize that all employees contribute directly to the organization's success. We must not engage in sexual harassment, including unwelcome sexual overtures, advances, requests for sexual favors or other similar conduct in any way which would adversely affect another employee's work performance or create an offensive working environment.

Substance Abuse:

We maintain a drug-free workplace. We may not use, possess, manufacture, dispense, distribute or sell illegal or non-prescribed drugs or alcohol while we are conducting company business, while on company property or while operating a Company vehicle. All employees are expected to be familiar with, and abide by, the Company's Substance Abuse Policy.

Weapons or Firearms:

We do not carry or display weapons or firearms while on Company property.

Work-related Charges, Indictments, or Convictions:

We must promptly notify the Company Legal Department in the event that we receive any kind of subpoena, extraordinary communication from third-party payers, outside attorneys, legal correspondence or any other unusual notification relating to the Company. We inform our supervisors immediately about requests from government auditors or investigators and do not interfere with the Company's response to such requests.

Company Loyalty:

We are representatives of this Company. By our acts, words and deeds, we demonstrate our loyalty and dedication to the success of the Company and our pride in the Company for which we work. We will not jeopardize or damage the integrity, reputation or relationships of the Company.

During the time we are affiliated with the Company, we will not participate in any business that competes with the Company. We will bring all appropriate business opportunities to the Company and not divert them to ourselves or others. We will enhance the Company's relationships with the people and companies with whom the Company does business. We will not cause any person to leave their employment with the Company improperly so that they might come to be employed by us or another company in a comparable capacity.

In turn, the Company, through its officers and directors, provides an environment that enables us as individuals to uphold this Pledge of Principles. Further, the Company enables us to know that we are supported in our application of the Pledge of Principles' provisions.

Provider and Employee Issues / Concerns

Open communication is essential for accomplishing the goals of the Compliance Program. That objective is to minimize and prevent fraud, waste and abuse. The success of the Program depends on maintaining effective channels of communication. As an employee, you must be willing to bring forward problems and know that you will be listened to, taken seriously, and protected from retribution for doing so.

Raising Questions and Concerns 

If you become aware of an activity that you think may be a problem or if you have any questions about this Pledge of Principles or the Compliance Program, please contact your supervisor, the Legal Department or the Compliance Department. If you are unsatisfied with the response or have additional concerns, you should continue to raise the issue through the supervisory structure or to the Corporate Compliance Officer.

Important Telephone Numbers

Compliance Department (954) 838-2511
Toll-free (800) 437-2672 (x2511)

Compliance Hotline (954) 838-2411
(ANONYMOUS) (800) 437-2672 (x2411)

Legal Department (954) 838-2770

© 2014 Sheridan Healthcare. "Sheridan" includes Sheridan Healthcare, its subsidiaries, affiliates and managed entities