Compliance Statement with Vendor Code of Conduct
Compliance Statement
PromptCare* has a compliance program that requires our workforce members, including all affected individuals, to do their jobs the right way every day. Our PromptCare Code of Conduct is not meant to be a substitute for each person’s internal sense of ethics, honesty, and integrity.
- The program is modeled after the Office of Inspector General’s Seven Elements of an Effective Compliance Program and is consistent with federal and state compliance program requirements.
- We screen all potential workforce members and vendors, to ensure they meet background screening requirements and are eligible to participate in federal healthcare programs.
- We distribute our PromptCare Code of Conduct book during orientation for all PromptCare workforce members. We want our workforce members to understand their responsibility to not only adhere to these principles of conduct, but also actively participate in and promote compliance within the workplace.
- We are committed to the ideals of our mission and our Code of Conduct. We are equally committed to ensuring that our actions consistently reflect our words as expressed in our Mission Statement.
- Our workforce members, contractors and vendors are encouraged and expected to report any issue by speaking to a supervisor, the next level supervisor, business line management, designated PromptCare representative or the compliance department. If any affected individual does not feel comfortable talking to someone within the company about the issue, he or she can call an external toll-free Hotline at 844-410-0049 to report concerns 24 hours a day. Callers may remain anonymous when they report their concerns.
Notice to all Contractors, Vendors, and other Affected Individuals
Pursuant to section 6032 of the federal Deficit Reduction Act of 2005 (DRA), all contractors and vendors of PromptCare must comply with and abide by PromptCare policies for preventing fraud, waste, and abuse. This law applies to any affected individual, representing PromptCare in the furnishing of, or otherwise authorizing the furnishing of Medicaid health care services, supplies, or products used in Medicaid health care service delivery, or monitoring Medicaid health care services provided by PromptCare. The DRA requires PromptCare to provide detailed information to all affected individuals regarding the Federal False Claims Act and applicable state false claims laws. Vendors are responsible for reviewing the Accuracy in Records, Coding and Billing section of the PromptCare Code of Conduct available on our website and for sharing the information with employees conducting PromptCare business.
Contractor/Vendor Code of Conduct
The purpose of this Contractor/Vendor Code of Conduct (“Code” or “Code of Conduct”) is to outline expectations for business conduct in accordance with applicable law and regulations and our company core values. This Code is only a guide to support understanding of our standards and ethical decision-making in our business relations. Contractors and Vendors are expected to share this Code of Conduct with their workforce members and subcontractors. This document supplements, but does not supersede, the contracts and/or business arrangements of PromptCare and each respective contractor/vendor.
Commitment to Law and Ethics. PromptCare expects all selected contractors/vendors to behave ethically and in accordance with all applicable laws, rules and regulations. PromptCare will not tolerate corrupt practices, kickbacks, or improper accounting practices in any form. PromptCare expects all aspects of fair competition and antitrust laws and regulations to be followed. All vendors and contractors are responsible for reviewing the Adherence to Laws and Regulations section of the PromptCare Code of Conduct and for sharing the information with its employees conducting PromptCare business.
Conflicts of Interest. PromptCare demands all contractors/vendors commit to being free of any conflicts of interest that could interfere with their ability to conduct with PromptCare fairly. PromptCare selects vendors, contractors and sub-contractors based on its clinical and business needs, evaluating quality, price, performance history and contracts. Its relationship with vendors must be impartial and fair and follow the relevant company policies. Any actual or potential conflict of interest must be disclosed, as quickly as is reasonably practical to the vendor’s designated PromptCare representative or the compliance department.
Gifts or Gratuities. PromptCare does not allow its workforce members to give or accept business gifts or favors that represent, or could be thought to represent, unfair business incentives. 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. Existing and potential vendors are prohibited from giving cash or cash equivalents (including gift certificates and lottery tickets).
Patient Health Information. PromptCare’s patients demand the highest levels of confidentiality and the protection of their Protected Health Information (PHI), whether the PHI is in paper or electronic form. In accordance with HIPAA and state privacy laws and regulations, PromptCare and its workforce members and any vendor or contractor personnel may not use, disclose, or discuss patient specific information with anyone in or outside of PromptCare unless it is required by the other person’s job or is allowed by a HIPAA compliant business associate agreement or otherwise allowed by law. All contractors and vendors must ensure this information is always secure consistent with applicable laws, regulations, and industry standards. Any known or suspected data security breaches must be promptly reported to PromptCare with detailed reports on the efforts to contain, investigate and respond to any incident.
Eligibility to Participate in Federal and State Health Care Programs. PromptCare demands that all contractors and vendors guarantee all its workforce members have met all legal and regulatory requirements to service the PromptCare business. PromptCare will not conduct business with any vendor excluded, debarred, or ineligible to participate in federal or state health care programs such as Medicare or Medicaid. We require vendors to screen all personnel and ensure they are eligible to participate in federal healthcare programs. Such screening includes conducting periodic checks of the Office of Inspector General’s List of Excluded Individuals/Entities (LEIE) and General Services Administration’s System for Award Management (SAM) databases.
Non-Discrimination/Non-Retaliation/Non-Intimidation Policy. Harassment, discrimination, retribution, and retaliation are not tolerated by PromptCare. PromptCare expects all contractors and vendors to ensure that they follow all PromptCare’s anti-discrimination, non-retribution and non-retaliation policies related to race, color, religion, national origin, political opinion, sex, sexual orientation, gender identity, age, disability, veteran status, genetic information, or any personal characteristic. Additionally, PromptCare expects the workforce of all contractors and vendors to enjoy a healthy and safe workplace, free of harassment, in any form.
Environmental Health and Safety. Further, all contractors and vendors are expected to comply with applicable laws regarding environmental practices, maintain all required environmental permits and follow their respective state/federal reporting requirements.
PromptCare Compliance Program Responsibilities. PromptCare encourages and expects contractors, vendors, and all affected individuals to report any questions, concerns or suspected violations to their designated PromptCare representative, PromptCare’s compliance department or through our Compliance Hotline by phone at 844-410-0049. PromptCare will promptly investigate any reported violations and expect cooperation with such investigations including, but not limited to, implementation of any responsive corrective measures. 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. 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 the PromptCare’s Compliance Committee, Human Resources, or PromptCare’s General Counsel.
The PromptCare Code of Conduct describes the expectations for all PromptCare workforce members and other affected individuals. The Code of Conduct is available on our website. All Contractors, vendors and other affected individuals are required to download and disseminate the PromptCare Code of Conduct, the PromptCare Vendor Compliance Statement and Code of Conduct and PromptCare’s Notice Letter to Contractors and Vendors.
Any questions related to these requirements for PromptCare contractors or vendors should be directed to your immediate company contact or the PromptCare Compliance Department.