A Message from Our CEO
At PromptCare, our patients are at the center of all we do. Delivering the best possible care, products, and services is integral to our mission.
PromptCare is a company of compassionate experts; we have been for 40 years. It’s one reason we continue to grow and thrive in an ever-changing, highly-complex healthcare industry. Another reason we continue leading the industry is that we act with integrity and in accordance with the letter and in the spirit of the law and compliance. We strive to make ethical choices and treat our patients and each other with integrity with every interaction. These actions serve our patients, improve our communities, and inspire our teams.
Our Code of Conduct is the clear guide to how we conduct business at PromptCare. Each of us has the responsibility – everywhere we operate and at all roles – to know our Code of Conduct and live it each day.
Thank you for your commitment to our company’s patients, success, and values.
Paul Jardina, Chief Executive Officer
PromptCare’s Commitment to Excellence
PromptCare’s mission is to enable patients with complex health conditions to live their fullest life.
Standards of Excellence
- I am here to serve my customers. This means prompt, friendly and quality service.
- I promptly respond to patient requests, phone calls and customer needs.
- I communicate in a respectful and professional manner. Nonverbal communication is as important as what I say.
- I anticipate patients’ and others’ needs, working to prevent problems and remove barriers.
- I communicate frequently about how long a patient, caregiver or colleague may expect to wait for service.
- I provide regular updates.
- I walk clients to their destination and seek out those who look lost.
- I seek to understand and improve core measures, quality metrics, best practices, patient satisfaction measures and employee engagement measures.
- I respect the confidentiality of patients and colleagues.
- I report concerns and take appropriate actions to eliminate patient, visitor and/or employee safety hazards.
- I identify opportunities and solutions for service and safety improvements in my work area and assume accountability for our success.
- I keep the facility and my work area neat, clean, presentable, and safe.
- I will take appropriate action when public areas do not meet our standards.
- I listen to understand and respond in a compassionate manner.
- I encourage my colleagues and offer words of praise for their excellent work.
- I partner with my colleagues to manage the workflow of my team.
- I help new or less experienced colleagues feel welcome.
- I thank others for their time and efforts.
- I take responsibility for my attitude and actions.
- I treat others with dignity and respect; rudeness is not acceptable.
- I am supportive and flexible when change occurs.
- I consistently carry out my work duties to the best of my ability, skills, and training, understanding that my work makes a difference in the care of our patients.
- I deal with conflict in a constructive manner and welcome personal feedback to improve performance and relationships.
- I look for opportunities to further my learning.
- I do the right thing because it is the right thing to do, even if nobody is watching.
- I take responsibility to use PromptCare resources appropriately.
- I take steps to maintain personal health and wellness.
- I maintain a positive image and follow the PromptCare dress code.
- I wear my badge, so it is easily read by patients, visitors, and colleagues.
- Any time I have my badge on, I represent PromptCare in a positive light.
- I show respect to all members of the PromptCare team: volunteers, employees, managers, students, and others.
- Before I speak, I consider who might be listening and whether it is appropriate.
- I keep current on organizational information.
How to Use This Code
This Code is divided into sections, each with several component parts. Each section is meant to clarify what PromptCare considers to be best practice while also using examples of actions and behaviors which are not compatible with PromptCare’s Mission, Vision, and Values.
Since the world changes quickly, PromptCare needs to keep pace and update the Code of Conduct (“Code”) regularly. The Code may be amended at any time when deemed appropriate. The Code aims to provide a framework for all our internal policies and standards. This code is available to provide guidance on the specific topics listed. To ensure complete understanding on a particular topic, PromptCare encourages consultation with your respective leader, review the PromptCare Employee Handbook and review applicable Policies/Standard Operating Procedures.
Commitment to Law and Ethics
Government regulations for health care organizations, such as those related to Medicare and Medicaid, are complex. However, following these regulations is critical to PromptCare’s continued growth and success. PromptCare strives to obey the law and to make business decisions that reflect its values. PromptCare, supported by its Chief Executive Officer, is an affirmative action/equal opportunity employer and recognizes and appreciates the rich array of talents and perspectives that equal employment and diversity offer PromptCare. No workforce member or applicant shall be discriminated against in any terms, conditions, or privileges of employment.
Accessing PromptCare Policies
PromptCare policies are available on the company intranet. For example, you can find a copy of the Compliance Plan and this Code of Conduct on the intranet. Check with your supervisor or manager or Information Services for more information on accessing the intranet from your work areas.
Non-Discrimination / Non-Retaliation / Non-Intimidation
PromptCare policy prohibits retaliation and intimidation against officers, workforce members or other affected individuals who report violations of the Code of Conduct or Employee Handbook in good faith using any of the procedures described herein. PromptCare policy protects those who assist in any investigations into such reports, regardless of the recipient of the report including, without limitation, reports to Federal and state agencies.
Anyone who retaliates because of such a report, or who interferes in the investigation into a report, will be subject to disciplinary action. Forms of retaliation include, but are not limited to, discharge, demotion, suspension, harassment, or in any other way discriminating against or unfairly singling out an individual for reporting a suspected violation of the Code. Reporting in good faith does not mean that the reported concern must be correct, but just that the individual making the report does so with a good faith basis for his or her belief that a violation has or may have occurred, and the individual is truthful in making the report. It will be left to PromptCare to determine whether an actual violation has occurred.
If you report a violation or potential violation and believe you have been retaliated against, report that immediately to the Chief Compliance Officer, a member of the Compliance Department, a member of PromptCare’s Compliance Committee, Human Resources, or PromptCare’s General Counsel.
PromptCare is committed to caring for its patients in a comfortable manner with dignity and respect. Some of our patients’ rights include:
- The right to express spiritual beliefs and cultural practices as long as those expressions do not harm or interfere with medical treatment.
- The right to expect that communications and records related to medical care will be treated as confidential, except where disclosure is permitted or required by law.
- The right to receive clear, concise explanations of care and proposed treatments, including possible benefits, risks, recovery expectations and alternate treatments.
- The right to receive care in an environment in which caregivers respect diversity.
- The right to receive care in an environment that does not exclude, deny benefits to or otherwise discriminate against any person on the basis of race, color, national origin, language, culture, ethnicity, age, religion, sex, mental or physical disability, sexual orientation, gender expression, gender identity, veteran status, socioeconomic status or any other characteristic prohibited by federal, state or local law in admission to, participation in or receipt of the services and benefits under any of its programs and activities.
Health Insurance Portability and Accountability Act of 1996 (HIPAA)
HIPAA guides health care providers to protect patients’ rights to privacy and security of their health information.
PromptCare workforce members safeguard the confidentiality of protected health information (PHI) in computer systems as well as paper records. When we discuss patient care, we identify appropriate places to have the discussion and speak in reasonable volumes to limit any inadvertent disclosure of PHI. We should never access or discuss patient treatment or personal information outside of work, and we should only discuss a patient’s protected health information with people who have a need to know. We recognize that some health information has additional protection under federal and state law. This includes drug and alcohol abuse treatment information, HIV test results, mental-health information, and genetic testing results.
Confidential Patient Information
PromptCare subsidiaries or divisions collect, maintain, or have access to patient information such as medical conditions, medical history, medication history and financial information. Workforce members may access health information as needed to carry out their jobs. Workforce members should never access patient information for any other reason.
In accordance with HIPAA and state privacy laws and regulations, you may not use, disclose, or discuss patient specific information with anyone in PromptCare unless it is required by the other person’s job. You may not use, disclose, or discuss patient specific information with others outside of PromptCare unless doing so is allowed by a HIPAA compliant business associate agreement or otherwise by law. Failure to comply with HIPAA and state privacy laws may subject the offending individual and PromptCare to civil and criminal penalties. Every officer and workforce member will receive training regarding the use and disclosure of patient information as appropriate for that person’s job and business unit.
Advance Directives and Health Care Decisions
During admission, PromptCare staff will advise patients of their rights in making health care decisions. This includes the right to accept or refuse medical treatment and have advance directives (e.g., CPR Directive, Do Not Resuscitate, Living Will, etc.). This information is governed by ethical and legal rules. It should be noted in the medical record whether a patient has an advance directive, including the location of the directive and its provisions, if known. Oral instructions should also be noted in the record. A reasonable effort will be made to obtain a copy of advance directives to be placed in the medical record.
PromptCare should provide the forms to patients upon request and direct patients to resources if they need assistance completing the forms. We do not discriminate against patients based on whether they have advance directives. It is vital to follow the law and health system policies related to advance directives and right-to-die issues.
All research, investigations and clinical trials conducted within any PromptCare entity are subject to high ethical standards and must comply with federal and state laws.
PromptCare does not tolerate research misconduct. Research misconduct includes fabrication or falsification of data, research procedures or data analysis; destruction of data for fraudulent purposes; plagiarism; abuse of confidentiality; or other fraudulent actions in proposing, performing, reviewing, or reporting the results of research or other scholarly activities.
PromptCare protects all patients and respects their rights during research, investigations, and clinical trials. All individuals asked to participate in a clinical trial or research project are given a full explanation of the risks, expected benefits and alternatives to volunteering for a clinical trial during their consent process.
An individual’s refusal to participate in a research study will not compromise his/her access to services. Any person engaging in human subject research at PromptCare must obtain approval prior to the research taking place. Every researcher must follow federal regulations and PromptCare policies related to research.
Researchers using investigational drugs in their studies need to partner with the pharmacy team to ensure that applicable policies and procedures are followed, and regulatory requirements are met.
Adherence to Laws and Regulations
Compliance with Federal Health Care Programs (Medicare, Medicaid, etc.)
PromptCare provides services governed by federal, state, and local laws and regulations. Practices prohibited by these laws and regulations include filing of false claims, illegal patient referrals, providing medically unnecessary services, violating the Medicare Conditions of Participation and many others.
Anti-Kickback and Stark Laws and Regulations
PromptCare workforce members must never offer or take compensation of any kind for patient referrals or the maintenance of vendor relationships. Physicians may not refer patients to entities with which they or their families have a financial relationship, unless the financial arrangement is one of the types permitted by law.
One exception to Stark is non-monetary compensation. Non-monetary compensation is compensation in the form of items or services that do not exceed a specific dollar amount per year. Workforce members must strictly follow our organization’s policies when being offered non-monetary compensation or other incidental benefits to themselves or their immediate family members.
Anti-kickback, Stark and non-monetary compensation laws and regulations are very complicated. They often require interpretation by Compliance and/or Legal. If you face a situation that may violate these laws, contact the Compliance and/or Legal team for guidance and review.
No one should take unfair advantage of anyone through manipulation or abuse of privileged information. No officer, director, workforce member or other affected individual may take proprietary information belonging to another company and use it for PromptCare business.
We must also all comply with federal antitrust laws. The antitrust laws are intended to create a level playing field in the marketplace by eliminating unreasonable restraints on trade, monopolization, price discrimination and unfair trade practices. You must be particularly careful in your interactions with all competitors and exercise extreme care to avoid any improper discussions at trade association meetings or other trade events where competitors may interact. If you are not careful, you could violate these laws if you discuss or make an agreement with a competitor regarding:
- prices or pricing strategy.
- policies and procedures
- terms of customer relationships.
- proprietary algorithms
- marketing plans.
- contract terms and contracting strategies.
Violation of the federal antitrust laws can result in severe penalties for PromptCare and for any affected individual who participates in the violation. Any questionable practices should be brought to the attention of PromptCare’s General Counsel.
A key part of our ethical and professional principles is documentation. Each workforce member is responsible for creating and maintaining accurate, complete, and timely patient-care records. Each workforce member should ensure that medical records do not contain false or misleading information and that they meet the requirements of all laws, regulations, accreditation standards and PromptCare’s policies and procedures.
Accuracy in Records, Coding, and Billing
We are committed to accurate record-keeping, coding, billing, and claims submission. There are numerous laws and regulations that govern how we maintain records and bill for our services. The federal False Claims Act (31 USC § 3729-3733) makes it a crime to knowingly make a false record or file a false claim with the government for payment. “Knowingly” is defined as “deliberate or reckless ignorance of facts that make a claim false.” Entities and physicians within PromptCare will only bill and submit claims for services that are provided and medically necessary.
If we make an error in a bill or claim, we will correct the problem by taking one or more of the following steps:
- Refund overpayments or payments made in error.
- Resubmit claims.
- Provide additional team training.
- Contact government authorities.
- Create new or revised policies and procedures.
- Discipline staff.
Federal penalties for violations of the False Claims Act can be up to three times the value of the false claim, plus fines. Individuals who report violations of the Act and/or possible false claims submitted by their employers are protected under the Act from being fired, demoted, threatened, or harassed by their employers.
PromptCare will conduct ongoing reviews of coding and billing practices of its member institutions and physicians to ensure accuracy in record-keeping, coding and billing and claims submission.
Expense Reporting and Payroll
PromptCare workforce members who use the time and attendance system and submit expense reports must do so completely, accurately, and on time. When submitting payroll or expenses, you are attesting that your time and expenses were for legitimate business on behalf of PromptCare. Contact the Finance or Human Resource teams with questions on payroll and expense reimbursement.
Your supervisor or manager’s signature/approval on a payroll record or expense report confirms that it has been reviewed. It also confirms that the reported hours or expenses have been verified and correctly allocated.
We are required by law to maintain certain types of medical and business records, usually for a specified period. Failure to retain these documents for such minimum periods could subject PromptCare to penalties and fines, cause the loss of rights, obstruct justice, place the organization in contempt of court, or put us at a serious disadvantage in litigation.
PromptCare has established controls to assure the retention and timely destruction of retrievable records, such as hard copies and records on computers, and electronic systems. Workforce members are expected to comply fully with the applicable record retention and destruction schedule.
Computer System and Email Usage
The following principles apply to all PromptCare computers and systems:
- All computers, software and related systems are company property and should be used for business purposes.
- Use computers and systems in an effective, ethical, and lawful manner.
- User accounts may be audited at any time.
- Use only computers and systems you are authorized to use wherever those pieces of equipment are located.
- Take all reasonable steps to protect the integrity and privacy of PromptCare systems, computers, software, and data. Users must not share their access codes, account numbers, passwords, or other authorizations with others.
- Using copyrighted material (including software or data) in any situation without the copyright owner’s authorization is prohibited.
- Follow PromptCare’s policies for email, internet, and social media.
- Respect the privacy of others, including email, computer files and data transmission.
- Refrain from using PromptCare computers for any unauthorized activities or illegal purposes. Inappropriate uses included (but are not limited to):
- Changing or destroying data owned by others.
- Interfering with valid access to a computer or system.
- Harassing computer users at PromptCare
- Attempting to discover or change passwords.
- Threatening computer-related security systems at PromptCare
Ethical Conduct in the Workplace & Compliance in Business Relationships
Intellectual Property, Patents, and Copyrights
During your job, you may have the opportunity to develop or design proprietary information including:
- New trade secrets
- Customer lists
- Works of Authorship
- Business and Product Development plans
- Modifications to or for the Workplace
Whether expressed orally or in writing, these products and information are considered intellectual property. As a PromptCare workforce member, using company materials on company time, any new development, whether it is eligible for patent or copyright, is the property of the company. By signing the Code of Conduct, you agree that any intellectual property is the property of PromptCare or PromptCare’s entities.
In addition, you agree not to use or disclose any proprietary information, or anything related to such information during employment or after termination, without the prior written consent of an executive officer of PromptCare, except as may be necessary and appropriate in the ordinary course of performing your duties.
As a workforce member of PromptCare, you agree that all original works of authorship, including without limitation, text, artwork, and computer software, made solely or jointly with others within the scope of and during your employment, are “works made for hire” as that term is used in the United States Copyright Act of 1976, as amended. It is not the intent of this section to change the relationship between author or creator and PromptCare that has existed through the years in relation to copyright ownership of scholarly works. Copyright laws are relevant to our workforce in two different ways:
- Copy infringement occurs when you copy an author’s protected work without his/her consent.
- Copyright protection is needed when you want to protect or copyright your own work. Except as permitted by law, you will not reproduce or use any copyrighted materials without the express permission of the copyright holder, unless licensed under an agreement. Copyrights apply to such things as articles, photographs, books, movies, computer software and advertising.
Confidential business information is a valuable corporate asset to PromptCare that, if inappropriately disclosed, could harm PromptCare, its workforce members, its customers, and its business partners. “Confidential information” is all information, either of a proprietary nature or not otherwise publicly known, relating to PromptCare or any of its subsidiaries, clients, business partners, suppliers, and workforce members.
Confidential information includes, but is not limited to: financial data, marketing/sales information, client payment information, client or personal information, client lists, training and operations material and memoranda, computer code, trade secrets, pricing information and confidential information from partners and vendors. Everyone should hold in strictest confidence and shall not, directly, or indirectly, in any manner, disclose to any person or entity, or use for the benefit of himself/herself or others, any information deemed confidential by PromptCare, except in connection with and for the benefit of PromptCare’s business and in strict compliance with PromptCare rules, policies and directives, or otherwise as expressly permitted in writing by PromptCare. No one should use knowledge of PromptCare ‘s confidential dealings, learned through his/her association with PromptCare, for personal gain or advantage, nor shall anyone disclose such information to enable others to profit from it. If your employment or contractual relationship ends for any reason, you are still bound to protect the confidentiality of information you obtained while you were a PromptCare workforce member. You must hold it in the strictest confidence and not use it to benefit yourself or any third party.
Conflicts of Interest
PromptCare workforce members must avoid relationships and activities that could interfere with their ability to conduct business fairly. If you have outside activities or personal interests that influence or appear to influence your ability to make objective decisions on the job, a conflict of interest may exist.
Generally, a supervisor should not directly or indirectly supervise, evaluate, or be involved in the employment of any workforce member with whom they have a personal or business relationship. Any actual or potential conflict of interest must be disclosed, as quickly as is reasonably practical, to your supervisor, manager or to the Compliance Department.
Using PromptCare information, resources, or company time for anything that brings personal or financial gain to you, or your family may be a conflict of interest. If you have another job or plan on having one elsewhere, you should tell your supervisor or manager the name of your outside employer and the type of job to determine if a conflict exists.
Gifts, Gratuities, and Entertainment
PromptCare workforce members will not give or accept business gifts or favors that represent, or could be thought to represent, unfair business incentives. Further, PromptCare workforce members will not violate laws, regulations, or policies of PromptCare or cause embarrassment to or reflect negatively upon the reputation of PromptCare.
Free vendor-sponsored training or education, including travel and lodging, may only be accepted when a full fair market analysis is conducted along with the validation of the educational materials. These analyses must be approved by PromptCare’s General Counsel.
PromptCare workforce members are prohibited from accepting cash or cash equivalents (including gift certificates and lottery tickets) from patients, existing and potential vendors, or referral sources. If a patient or guest offers you cash or a substantial gift, attempt to return the gift. If you are unable to return the gift, PromptCare’s General Counsel and Chief Compliance Officer must be contacted to address the issue.
PromptCare workforce members must never provide gifts, entertainment, meals, or anything else of value to anyone affiliated with the federal government.
PromptCare is committed to maintaining positive working relationships with contractors, subcontractors, and vendors. We select vendors, contractors and sub-contractors based on clinical and business needs, evaluating quality, price, performance history and contracts. Our relationships with these companies will be impartial and fair and will follow the relevant health company policies. Confidential information about contracts with contractors, subcontractors and vendors will not be released to any third party without permission, unless required by law.
Community Activity: Participation on Community Boards
PromptCare strongly encourages workforce members to be involved in the communities we serve. This includes serving on boards of directors of other organizations. If you would like to serve on a board for an organization whose interests may conflict with PromptCare, you must first get approval from your supervisor or manager. If you and/or your supervisor or manager need help with the decision, contact the Compliance and/or Legal Department.
Everyone who works for PromptCare should understand how decisions made in Congress, at the Food and Drug Administration, Centers for Medicare and Medicaid Services, and various state and local governments can affect how and what we are able to accomplish as a health care company.
PromptCare is actively involved in two advocacy groups, NHIA for infusion and AA Homecare for Respiratory. There are times when these groups ask for our support in raising awareness about a key vote that may be coming up in the Senate or the House of Representatives. You may receive emails from management asking you to send a request to your individual Senator or Member of Congress. Some of us have even been known to go to Washington D.C and knock on doors to get raise awareness. Your participation is completely voluntary.
Any marketing program developed and implemented by PromptCare to our referral sources and the community at large will abide by PromptCare’s ethical standards. Marketing programs will reflect truth in advertising and will factually represent those services and programs being advertised. PromptCare may use advertising to inform referral sources and the community of the availability and value of our services and products.
PromptCare is perceived by the community as a reliable, authoritative source of information about medical care and the health care industry. We should remain mindful of the trust placed in us by the public and strive to provide accurate, balanced information. Advertisements that make health or safety claims must be supported by tests or studies approved by experts in the appropriate field. Advertisements must be fair. Any immoral, unethical, or unscrupulous behavior found in an organization’s promotions or advertisements may be a violation of the law.
Any promotional activity, including marketing, physician relations and public relations endeavors related to PromptCare will be based upon actual programs, services and operations and will be presented truthfully. All activities that represent the health system will be presented to the public in accordance with ethical and acceptable business practices.
When using online social media tools, workforce members may be subject to aspects of this Code of Conduct, their duty of confidentiality, PromptCare’s policies and procedures and/or Standards of Excellence. Consequently, appropriate professional behavior is always expected. Workforce members shall not engage in personal, abusive attacks on fellow team members or patients via social media. Posting patients’ protected health information (whether on or off the clock) is strictly prohibited and is a violation of HIPAA.
PromptCare, supported by its CEO, recognizes, and appreciates the rich array of talents and perspectives that a diverse staff offers our organization and institutions. PromptCare is proud to be an equal opportunity/affirmative action employer that takes deliberate steps to recruit, accommodate and maintain a diverse workforce. If you need information or have questions about employment issues, please contact the PromptCare Human Resources Department. If you suspect a violation of employment laws, you are encouraged to report your concern to your supervisor, manager, the Human Resources Department, the Compliance Department, or the Integrity Helpline.
PromptCare strives to maintain a safe, healthy, and efficient environment that is free from any form of harassment or threatening behavior. Harassment and violence are strictly prohibited (which is described in more detail in PromptCare Human Resources Department policies). Workforce members are expected to treat each other with respect through courteous communication and professional demeanor. Workplace violence may include robbery and other commercial crimes, stalking, inappropriate or unwelcome physical contact, threats, terrorism and hate crimes. PromptCare workforce members may not have firearms, weapons, explosive devices, or other dangerous materials on PromptCare premises except for permitted concealed weapons as permitted by state law.
PromptCare workforce members who see, or experience harassment or violence should report it to their supervisor or manager, Human Resources, any senior manager, or the Compliance Department, or contact the Integrity Helpline. All PromptCare workforce members have the right not to be subjected to discrimination as described in the Equal Employment and Anti-Discrimination Statement as well as the Americans with Disabilities Act policy.
Drug-Free and Alcohol-Free Workplace
PromptCare prohibits any workforce member from reporting for or being at work with any detectable amount of alcohol, drugs or controlled substances (or their metabolites) in their system. It may be appropriate to have limited alcohol at an approved PromptCare function.
Sometimes it may be necessary for workforce members to use drugs prescribed by physicians or other qualified providers. Such drugs must be used following the prescribed instructions and for the intended purpose. PromptCare has the right to decide if workforce members using prescription drugs are fit to perform their tasks.
At work, you may have access to drugs and controlled substances. All drugs and controlled substances must be handled carefully and in strict compliance with all laws, policies, and regulations. If you suspect that prescription drugs or controlled substances are being taken from your department or misused, you must immediately notify your manager.
Environmental Health and Safety
PromptCare is committed to obeying all environmental laws and regulations that apply to our business. We are also committed to providing a healthy and safe environment for patients, guests and PromptCare workforce members. Smoking, the use of any tobacco products and the use of electronic cigarettes is prohibited in or on all PromptCare properties including grounds, parking lots, vehicles, parking structures and sidewalks within property boundaries. PromptCare workforce members are encouraged to communicate this policy with courtesy to patients and families.
PromptCare workforce members are expected to be free from the smell of smoke.
If you think an environmental law, rule, regulation or PromptCare policy is being violated, ask Human Resources or the Compliance Department for assistance.
Interaction with any Government Agency
If you are contacted by a government agency or representative, notify your immediate supervisor, and the Compliance department. It is important that we are honest and open with the government and its representatives and provide government inspectors with complete and accurate information. PromptCare workforce members must not hide, modify, or destroy documents, lie, or make false statements.
Obtaining Assistance and Reporting Violations
When you have ethics or compliance questions or need more information, feel free to contact your supervisor or manager, the Human Resources Department, or the Compliance Department. You may also read the company policies for more detailed information. Ethics and compliance concerns will be kept confidential whenever possible, though there are instances such as an official investigation, patient, or staff safety, etc., where we may not be able to maintain confidentiality.
We have implemented a confidential, external Integrity Helpline to allow you to present an ethics or compliance concern anonymously. The helpline may be used to report possible violations of this Code of Conduct, Compliance Program, health system policies and procedures and other laws and regulations.
Every PromptCare workforce member must report suspected violations of the Code of Conduct to their supervisor or manager, senior manager, the Compliance Department, or the Integrity Helpline. We will notify you if it becomes necessary to reveal your identity in an official investigation.
PromptCare protects all workforce members against retaliation for reporting Code of Conduct violations or participating in investigations. Penalties for retaliatory behavior can be severe.
The Compliance Department, along with the Compliance Committees, exists to support PromptCare’s commitment to ethics and compliance. The Compliance Program is implemented and enforced by the Chief Compliance Officer, Privacy Officer, Security Officer, and Compliance Committee staff.
Reporting a Concern
PromptCare suggests following the established leadership chain when reporting issues or concerns.
An open-door policy is the best policy to have when addressing concerns, therefore, as much as it is within your ability to do so, always first report concerns to your immediate supervisor or manager. When reporting, please attempt to follow the recommended reporting structure:
• Immediate supervisor or manager
• Department director
• Department vice president
Disregarding the chain of command may affect the morale of staff and management and can create an atmosphere of distrust. If you are uncomfortable reporting your concern to any level in the chain, direct your concern to the next level of leadership. If you do not feel comfortable approaching the individuals above, one of the following resources may be contacted.
• Chief Compliance Officer
• Human Resources
If you wish to report anonymously: Lighthouse Integrity Helpline—1-844-410-0049. The Hotline is available 24/7.
Investigating and Responding to Reports
All reports of violations or suspected violations are investigated. These reports, including those from the Anonymous Hotline, are managed by the VP of Human Resources and the Chief Compliance Officer, who may utilize other areas so that an appropriate investigation can be conducted. Each has a responsibility to investigate issues and potential violations depending upon the subject or content of the report. If you have identified yourself on your call or if you have reported a potential violation you are expected to cooperate with the investigation.
If the investigation substantiates a suspected violation, PromptCare will initiate corrective action, including, as appropriate, promptly refunding any overpayment amounts, notifying appropriate government agencies, taking disciplinary action, implementing systemic changes to prevent a recurrence of the problem in the future or other appropriate corrective action.
Corrective / Disciplinary Actions
Disciplinary action may be taken against anyone who is determined to have:
- authorized or participated in activities that violate the Code or the law, including all Federal health care program requirements.
- failed to report a policy violation or possible violation of the law.
- made a false report regarding a suspected violation for the purpose of harming or retaliating against another person.
- failed to cooperate in an investigation or interfere with an investigation.
- retaliated against an individual for reporting a suspected violation or for participating in an investigation.
The type of corrective action taken will depend on the nature, severity and frequency of the violation and may include reprimand, training, probation, suspension, reduction in salary or bonus, demotion, or dismissal. Disciplinary actions will be fairly and evenly enforced. The PromptCare Employee Handbook and PromptCare Policies, related to conduct and professional behavior, provide further guidance.