Code of Conduct
Parker and its subsidiaries and controlled affiliates (“Parker”) is committed to conducting its activities in accordance with high ethical standards and all applicable laws, rules and regulations. This Code of Conduct governs the conduct of all employees and those independent contractors and others affiliated with Parker who the Compliance Officer has designated as covered by the Parker Compliance Program (the “Designated Contractors”). This Code of Conduct will be adopted by the Medical Staff at Parker, and as such governs the conduct of all physicians and other health professionals employed by, or with privileges at, Parker.
It is our collective responsibility to understand and comply with the rules, regulations and laws that pertain to our jobs. If you have responsibility for employees or Designated Contractors, you must continually reinforce to each person under your supervision or direction that he or she must comply with this Code of Conduct, as well as other elements of the Parker Compliance Program. An individual’s failure to comply with this Code of Conduct, Parker’s Policies and Procedures, or another element of the Compliance Program may subject the individual to disciplinary action, up to or including termination.
This Code of Conduct summarizes the key principles that should guide the conduct of all Parker employees and representatives of Designated Contractors. Parker’s Policies and Procedures provide more detailed guidance relating to specific job functions and activities.
- The activities of Parker, particularly those relating to patient care and billing, are subject to a variety of laws, regulations and/or industrial or professional standards. Our conduct must conform to those requirements, particularly as they relate to federal health care programs. There are no exceptions or shortcuts to this policy. The following are some general principles designed to promote Parker’s compliance with applicable standards:
- No one may pay anyone for referrals to Parker of patients or health care business or provide gifts or other financial benefits in return for patient business. Parker staff may not solicit or receive from, or offer to give to, vendors or patients any gift of more than a nominal value unless the gift is specifically approved by the Compliance Officer.
- Parker staff must avoid conflicts of interest where possible (and must disclose all actual or potential conflicts that may arise). Parker staff must not engage in unfair business practices.
- Parker’s medical staff must comply with physician self-referral laws. These laws prohibit physicians and their immediate family members from making referrals to an entity in which they have a financial interest for the furnishing of certain types of health care items or services.
- All medical practitioners furnishing services at Parker must strive to provide each Parker resident with the necessary care and services to attain or maintain his or her highest practicable physical, mental and psychosocial well-being, in accordance with his or her assessment and plan of care.
- All professional practitioners must furnish medical, nursing, and social services in accordance with applicable professional and regulatory standards, and in particular, must maintain required professional licenses and certifications and refrain from engaging in any form of professional misconduct while providing their services at Parker.
- All Parker personnel must protect the rights of Parker residents and patients, including without limitation, their right to be treated with dignity and respect, their right to appropriate privacy and confidentiality in their records and communications, their right to receive adequate and appropriate medical care, and their right to choose activities and health care consistent with their interests and plan of care.
- All Parker reports must be accurately and completely prepared and maintained in compliance with applicable legal and professional requirements. All bills must reflect appropriate charges, be based on the services actually provided, and be supported by documentation in the medical record. All services billed to Medicare, Medicaid and other federal and/or state health care programs must be furnished in compliance with the conditions of participation of these programs.
- There may be times when you may not be certain about what the law may require. It is important to get the correct guidance. The Compliance Officer and your departmental supervisor have resources to address issues that may arise, including binders containing recent laws, regulations and government pronouncements. You should contact the Compliance Officer, your departmental supervisor or any member of senior management at any time to assist you in these matters.
- It is important that Parker’s records accurately reflect the services that we provide, the providers involved, the date of service, the place of service and other items that may be important to document care provided and to ensure proper billing. Employees responsible for entering information in medical and/or billing records are responsible for the accuracy of this information.
- It is every employee’s responsibility to help ensure that all patient information is held in strict confidence, except as otherwise mandated by law.
- The Compliance Officer and others offer regular educational programs that address a variety of compliance issues. Some of those programs are so important that attendance is mandatory. Parker employees must attend all mandatory education sessions. Employees are encouraged, moreover, to attend additional sessions to enhance their understanding of compliance rules and regulations.
- If you believe that you have information about activity that you think may be illegal or unethical, you should report such issues to the Compliance Officer, your departmental supervisor, any Parker officer, manager or supervisor, or through Parker’s confidential Hotline (see phone numbers listed below). Such reports can be made anonymously. Failure to report suspected illegal or unethical activity may itself be a violation of this Code of Conduct and Parker’s Compliance Program. There will be no retaliation for making a good-faith report of possible improper behavior.
- All Parker employees and Designated Contractors are expected to comply with all institutional policies and procedures, including this Code of Conduct. Failure to do so may result in disciplinary action, including termination.
Corporate Compliance Officer