Almost Family Corporate Compliance
Message from the Officers of Almost Family:
While everyone who works for Almost Family must contribute to the creation and maintenance of such an environment, our executives and management personnel assume special responsibility for fostering a context for work that will bring out the best in all of us. You can count on us to do everything in our power to meet Almost Family standards and we are counting on you to do the same. We are confident that our trust in you is well placed and we are determined to be worthy of your trust.
Provide Accurate and Complete Documentation
Client care must be necessary, appropriate and well documented. We must ensure the medical necessity of the care provided and verify client eligibility as needed. In addition, we will accurately record all services provided, and document physician authorization.
Improper coding of services and care provided (i.e., upcoding, fragmentation, use of obsolete or inappropriate coding) will not be tolerated and will result in immediate sanctions (i.e., disciplinary action, termination, substantial fines).
Always Obey the Law
We will conduct our business in accordance with all applicable laws and regulations. Compliance with the law does not compromise our ethical responsibility. Rather, it provides the minimum, absolute, essential condition for performance of our duties.
Carefully Bid, Negotiate, and Perform Contracts
If you are involved in proposals, bid preparations or contract negotiations, you must be certain that all statements, communications and representations to prospective partners or suppliers are accurate and truthful. Once awarded, all contracts must be performed in compliance with specifications, requirements and clauses.
If you buy goods or services for Almost Family or are involved in the procurement process, you must treat all suppliers uniformly and fairly. In deciding among competing suppliers, you must objectively and impartially weigh all facts and avoid even the appearance of favoritism. Established routines and procedures should be followed in the procurement of all goods and services.
Decline Inappropriate Gifts
Almost Family employees may accept meals, refreshments or entertainment of nominal value in connection with business discussions. While it is difficult to define “nominal” by means of a specific dollar amount, anything considered lavish, extravagant or frequent is inappropriate. It is each employee’s responsibility to ensure that his or her acceptance of such meals, refreshments, or entertainment is proper and could not reasonably be construed in any way as an attempt by the offering party to secure favorable treatment.
Almost Family employees are not permitted to accept funds in any form or amount, or any gift that has retail or exchange value of $25 or more from individuals, companies or representatives of companies having or seeking business relationships with Almost Family. If you have any questions about the propriety of a gift, gratuity or item of value, contact your Compliance Officer or call the Compliance Helpline (1-877-272-9740) for guidance.
Generate Accurate Billing and Claims
We will generate billing and claims accurately reflecting that services rendered are supported by relevant documentation and are submitted in compliance with applicable laws, rules, regulations and program requirements. We will never intentionally make or present improper, false, fictitious or fraudulent claims to any government or private health care program, employee, department or agency. Honesty and accuracy in billing and in the making of claims for Medicare or Medicaid payment is vital.
Improper or fraudulent activity can include:
• Cost Report Falsification
• Misrepresentation of Services
• Duplicate Billing
• Multiple Coverage and Secondary-Payor Fraud
• False Claims and Statements
• Billing for services we did not provide
• Non-approved Treatment or Equipment Usage
• Improper Coding (i.e., Upcoding, Unbundling)
• Non-ordered/Non-performed Testing Submission
• Improper Physician and Other Referrals (Stark I & II, Anti-Kickback)
If you become aware of the submission of improper, false, fictitious or fraudulent claims, it is your obligation to report this immediately to your supervisor, or to the Corporate Compliance Officer or by calling Compliance Helpline (1-877-272-9740) .
Maintain the Integrity of Physicians
Business integrity is a key principle for the selection and retention of those who represent Almost Family. Physicians, agents, representatives or consultants must certify their willingness to comply with our policies and procedures and must never be retained to circumvent our values and principles. Paying bribes or kickbacks, obtaining the proprietary data of a third party, or gaining inside information or influence are just a few examples of what could give us an unfair competitive advantage and result in violations of law.
Manage Controlled Substances
Some of our colleagues routinely have access to prescription drugs, controlled substances, and other medical supplies. Many of these substances are governed and monitored by specific regulatory organizations and must be administered by physician order only. It is extremely important that these items be handled properly and only by authorized individuals to minimize risks to us and to clients. If you become aware of the diversion of drugs from the organization, you should report the incident immediately.
Treat All Employees with Respect, Dignity, and Fairness
It is the responsibility of members of the Almost Family team to create and maintain a work environment in which employees are treated with respect, and where diversity is valued and opportunities are provided for development. Harassment or abuse of any kind is prohibited in the Almost Family workplace. All employees want and deserve a workplace where they feel respected, satisfied and appreciated. Employees will be hired, promoted and compensated according to their qualifications, performance and potential. We will not tolerate harassment by anyone based on the diverse characteristics or cultural backgrounds of those who work with us. Degrading or humiliating jokes, slurs, intimidation, or other harassing conduct is not acceptable in our workplace.
Protect Client Confidentiality
Every employee of Almost Family is required to maintain the utmost confidentiality concerning the treatment, care, and condition of all clients.
Written and computerized medical client information can never be removed without management approval. Also, employees must be careful to safeguard their client care conversations and discussions in areas where they may be overheard by parents, family members, and the public. It is your obligation to immediately report any breach in confidentiality to your supervisor, the Compliance Officer, or call the Compliance Helpline (1-877-272-9740) .
Refuse Inappropriate Referrals
Any business arrangement with a physician must be structured to ensure precise compliance with legal requirements. Such arrangements must be in writing and approved by an Almost Family Officer.
We will strictly adhere to the following rules:
• We do not pay for referrals.
• We do not accept payments for referrals that we make.
If you become aware of or involved in a situation involving bribery, kickback or inappropriate referrals, it is your obligation to immediately report it to your supervisor, the Compliance Officer, or call the Compliance Helpline (1-877-272-9740) .
Avoid Conflicts of Interest
A conflict of interest may occur if your outside activities or personal interests influence or appear to influence your ability to make objective decisions in the course of your job responsibilities. A conflict of interest may also exist if the demands of any outside activities hinder or distract you from the performance of your job or cause you to use Almost Family resources for other than Almost Family purposes. It is your obligation to ensure that you remain free of conflicts of interest in the performance of your responsibilities at Almost Family. If you have any question about whether an outside activity might constitute a conflict of interest, you must obtain the approval of your supervisor before pursuing the activity or contact the Compliance Officer or call the Compliance Helpline (1-877-272-9740) .
Federal and state antitrust laws protect the integrity of our free enterprise system. These laws address agreements and practices resulting in the restraint of competition including boycotting suppliers, discussing pricing or clients with competitors, implementing unfair or deceptive business practices and misrepresenting services. These laws may affect your dealings with clients, doctors, payers, suppliers and competitors of Almost Family. For purposes of the antitrust laws, member facilities of Almost Family are not competitors of one another. However, health care providers not controlled by Almost Family should be considered competitors.
In general, avoid discussing sensitive topics with competitors or suppliers, unless you are proceeding with the advice of the Corporate Compliance Officer. You must not provide any information in response to oral or written inquiry concerning an antitrust matter without first consulting the Corporate Compliance Officer.
All of our employees are responsible for maintaining a safe and healthful work environment. We must comply with all federal, state and local health and safety laws and regulations, including the rules and regulations of the Occupational Safety and Health Administration (OSHA). If you become aware of a situation that is unsafe or unhealthy to those involved, it is your obligation to report this immediately to your supervisor or by calling the Compliance Helpline (1-877-272-9740) .
Relationships with Subcontrators, Suppliers, and Educational Institutions
We must manage our subcontractor and supplier relationships in a fair and reasonable manner, consistent with all applicable laws and good business practices. Our selection of subcontractors, suppliers, and vendors will be made on the basis of objective criteria including quality, technical excellence, price, delivery, adherence to schedules, service, and maintenance of adequate sources of supply. Our purchasing decisions will be made on the supplier’s ability to meet our needs, and not on personal relationships and friendships.
We will always employ the highest ethical standards in business practices in source selection, negotiation, determination of contract awards, and the administration of all purchasing activities. We will not communicate to a third-party confidential information given to us by our suppliers unless directed in writing to do so by the supplier. We will not disclose contract pricing and information to any outside parties.
All agencies having relationships with an educational institution must have a written agreement, which defines both parties’ roles and the agency’s retention of the responsibility for the quality of client care.
Management's Responsibilities under the Corporate Compliance Program
Management throughout the organization is responsible for setting the example, ensuring that everyone is provided with appropriate resources, and that they are consistently holding themselves and Almost Family employees accountable for their actions.
Employee's Responsibilities under the Corporate Compliance Program
All employees have an obligation to assure that the Corporate Compliance Program is a success. Employees can help to achieve that success by completing the following actions:
• Read and regularly review the Code of Ethics and the policies that support it in order to learn the compliance requirements that apply to individual responsibilities;
• Participate in Corporate Compliance Program training sessions and staff meetings designed to help understand employee obligations under the Code of Ethics;
• Abide by the requirements set forth in the Code of Ethics;
• Ask questions and seek assistance when uncertain about the proper course of action;
• Know the Corporate Compliance Officer, and how to reach him/her;
• Support employees who report suspected violations of the Code of Ethics. Recognize that retaliation against persons who report suspected violations is not permitted;
• Be alert to situations that could result in illegal or unethical conduct and encourage other employees to consult with supervisors or the Corporate Compliance Officer if it appears that they may be in danger of violating the law or the Code of Ethics; and
• Report suspected violations of the Code of Ethics.
Resources for Guidance and Reporting Violations
Almost Family has established the Compliance Helpline (1-877-272-9740) . This is a toll-free number staffed 24 hours a day, seven days a week by an outside organization designed to assist you in meeting the challenges of performing your duties and responsibilities.
You should first discuss your concerns with your immediate supervisor. If you are not comfortable talking to your supervisor, you may raise the concern directly with a department manager or the Corporate Compliance Officer. If your issue requires further investigation or if you have additional concerns, you may contact the Compliance Helpline at 1-877-272-9740 .
Remember, there is never a penalty for using the toll-free Helpline . People in positions of authority cannot stop you. If they try, they are subject to serious disciplinary action, up to and including dismissal.
In addition, if you need information on how to contact your Compliance Officer, or wish to discuss a matter of concern with the corporate compliance office, you are encouraged to use one of the following confidential means of communication:
• Call the 1-877-272-9740 HelpLine
• E-mail the Compliance Officer at email@example.com
• Fax the Compliance Officer at his secured fax line 502-891-1007.
• Call or write the corporate office to the attention of the Compliance Officer.
When you contact these sources, you will be treated with dignity and respect. Your communication and anonymity will be protected to the greatest extent possible. Your concerns will be seriously addressed, and if not resolved at the time you call, you will be informed of the outcome.