Standards of Conduct

1
Standards of Conduct

• Training today will give you talking points
• You need to read through the book and get
  comfortable with the information
• This replaces two page Standard
• Acknowledgement must be signed and sent to HR
  when all meetings complete

2
Standards of Conduct

• Purpose All MHCC Board memebers, employees,
  physicians, volunteers, contractors following the
  same guidelines
• Governing board supports
• Leadership must support and lead by example
• Standards are the outward/public sign of BRMC
  compliance to legal and ethical behavior

3
Standards of Conduct

• Education the most critical element of the
  compliance program
• Standards do not address all the complexity of
  the issues, rules and regulations
• Outlines whats expected of all who have dealings
  with us

4
Standards of Conduct

• A Commitment to Providing Patient Care
• Document all care and services given
• Individual professionalism being responsible
  for your actions and taking pride in your work
• Effective communication using plain language,
  making eye contact, using proper phone etiquette,
  smiling and greeting patients and family members
• Exceeding the expectations of patients, patient
  family members, and co-workers

5
Standards of Conduct

• A Commitment to Our Community
• You are identified with BRMC when in public
• DO nothing to embarrass yourself or BRMC

6
Standards of Conduct

• A Commitment to Environmental Health and Safety
• Follow all governing rules and regulations,
  i.e.OSHA, FDA. CDC, etc.
• A Commitment to Environmental Health and Safety
• Workforce members will
• Wear appropriately displayed name badges at all
  times and be familiar with others that work in
  their areas
• Report suspicious persons or situations
  immediately
• Remain calm, listen, and diffuse verbally
  hostile situations

7
Standards of Conduct

• A Commitment to Proper Employment Practices
• McLaren Health Care takes reasonable precautions
  to ensure the work environment is free of
  discrimination or harassment
• To maintain public trust,
• Employees may not solicit or accept anything of
  more than de minimus value, including a loan,
  reward, material or property, from a patient or a
  patients family, visitor, contractor, supplier
  or competitor.
• Employees may not use their employment, or any
  information received through MHC, to obtain
  financial gain (direct or indirect) for
  themselves, a member of their family or a
  business with which they or a member of their
  family, is associated.

8
Standards of Conduct

• A Commitment to Ethical Business Conduct
• Outside employment or business activities must be
  limited to off-work time
• Report any situation that may be considered a
  conflict of interest
• Staff and physicians may not share pricing
  information, internal reports, communications,
  procedure schedules
• Honest, accurate, and complete reporting of
  financial transactions

9
Standards of Conduct

• A Commitment to MHC Assets and Financial
  Transactions
• Honest, accurate, and complete reporting of
  financial transactions
• Appropriately representing productivity
• Accurately recording travel expenses and
  mileage
• Securing money, equipment, or supplies from
  theft
• Complying with business expense reimbursement
  policies

10
Standards of Conduct

• A Commitment to Accurate Coding and Billing
  Transactions
• Providing and billing only for services that were
  reasonable and necessary
• Billing for services at levels that are supported
  by medical record documentation
• Waiving of co-pays or deductibles only in
  accordance with policy and procedure
• Bundling or unbundling charges appropriately
• Attempting to collect outstanding balances from a
  Medicare or Medicaid patients only when Advance
  Beneficiary Notices were provided prior to
  service
• Preventing duplicate billing
• Ensuring the accuracy of diagnostic and procedure
  codes

11
Standards of Conduct

• A Commitment to Physician Relations
• The organization will maintain positive working
  relationships and respect the legal rights of
  physicians.
• provides a uniformly-applied privileging process
• teaching facilities and practices to assist in
  advancing the field of medicine.

12
Standards of Conduct

• A Commitment to Confidentiality and Electronic
  Security
• Right to confidential communication of PHI
• Right to receive a notice of uses/disclosures of
  PHI
• Right to access or receive a copy of their
  medical records
• Right to request a restriction to how PHI is used
  
• Right to request changes (amendments) to their
  records
• Right to receive a listing (accounting of
  disclosures) if requested
• the same safeguards used to protect confidential
  patient information should be used to protect our
  business and financial information.

13
Standards of Conduct

• A Commitment to Laws and Regulations
• Anti-Kickback
• Stark Laws (Physician Self-Referral Law)
• Federal False Claims Act
• State False Claims Act
• EMTALA (Emergency Medical Treatment and Active
  Labor Act)

14
Standards of Conduct

• A Commitment to Ongoing Monitoring
• The MHC and BRMC compliance program
• BRMC Hot Line 989-894-3945
• BRMC Privacy Line 989-894-3970
• BRMC Compliance Officer 989-894-3849