The VillageCare Board of Directors formalized the compliance program in 1999 and continues to demonstrate commitment to conducting business with integrity and in compliance with state and federal laws and regulations that apply to the health care industry. To reinforce commitment to our core values, VillageCare has implemented a Corporate Compliance Program to provide guidance for furnishing quality health care services to the community we serve in an ethical and lawful manner.
Our Corporate Compliance Program includes the following elements:
- Standards of Conduct: and written policies and procedure in order to reduce the prospect of unethical or criminal conduct.
- Oversight: mandates an organizational operation structure capable of implementing and supporting an effective Compliance Program, including a Chief Compliance Officer, Compliance Department and Compliance Committee;
- Communication of Standards: requires the open, honest, interactive and timely communication of compliance policies, procedures, standards and issues;
- Training and Education: emphasizes proactive training and education programs to help ensure each employee is aware of and understands the Standards of Conduct applicable to his or her job;
- Monitoring and Auditing: implements monitoring and auditing protocols and other risk evaluation techniques to help ensure adequate compliance controls are in place;
- Reporting: operates a system to allow employees to fulfill their duty to report compliance issues without fear of retribution; and
- Response, Enforcement and Prevention: ensures a consistent, prompt, appropriate response (including discipline) for non-compliance that is designed to prevent future offenses.
The commitment of VillageCare to our corporate responsibility efforts includes compliance with the Deficit Reduction Act by providing information about the federal and state False Claims Acts. Employees, contractors and agents must agree to abide by the False Claims Act Policy when performing their work activities for or on behalf of VillageCare.
VILLAGECARE'S COMPLIANCE POLICY
At VillageCare, we must ensure that we follow basic, fundamental principles of ethical and business conduct. In today’s dynamic world of healthcare, we must help each other comply with applicable laws and regulations, our own internal policies and procedures and good business practices. To live up to that commitment, we have established a Compliance Program for VillageCare designed to promote a work environment that fosters compliance with ethical, legal and regulatory requirements. The heart of the compliance program is the Code of Conduct, which sets forth the fundamental principles we must follow in dealing with clients, residents, affiliated health care providers, payors, vendors, independent contractors and one another. The Compliance Program is important to VillageCare and the people we serve.
NOTE: January 1, 2007
The federal Deficit Reduction Act of 2005 requires health care providers receiving Medicaid revenues to provide information to employees concerning the Federal False Claims Act, state laws concerning false claims, the healthcare provider’s own policies for preventing and detecting fraud, waste and abuse and an employee’s right to be protected from retaliation.
SOCIAL MEDIA POLICY STATEMENT
At VillageCare, we recognize and encourage our employees’ active participation in social media and online communications.
This Policy is designed to guide you in making responsible decisions when creating, posting or otherwise contributing to blogs, social networks, wikis, virtual worlds or other social media. Whether you use external sites such as Facebook, LinkedIn, Twitter, YouTube, Google+, Instagram, Pinterest or Wikipedia or internal sites or comment on blogs or any form of digital media. The Policy covers three main areas:
1. Basic principles for all types of social media
2. Special guidelines for official use of social media on behalf of the company
3. Special guidelines for personal use of social media
These principles apply to official use of social media on behalf of our company as well as personal use.
Adhere to the Code of Conduct. The Workforce is expected to adhere to all existing VillageCare rules and policies when using or participating in social media. All the rules that apply to other VillageCare communications apply here, specifically: respecting employees, patients, customers, members, clients, residents and one another; protecting confidentiality, privacy, and security of patient, client, resident identifiable information, PHI, employee identifiable information, and VillageCare information; and safeguarding and proper use of VillageCare assets.
Be respectful. When representing VillageCare in any official capacity, the workforce may not post any material that is obscene, defamatory, profane, libelous, threatening, harassing, abusive, hateful, or embarrassing to another.
Abide by the law and respect copyright laws. The Workforce may not post content or conduct any activity that fails to conform to any and all applicable state and federal laws. For the protection of both VillageCare and the workforce, it is critical that all the Workforce abide by the copyright laws by ensuring that they have permission to use or reproduce any copyrighted text, photos, graphics, video, or other material owned by others.
Obtain approval before setting up VillageCare hosted site. The Workforce may not set up a VillageCare-hosted blog or other social media sites without getting approval from the Corporate Communications department.
Proprietary information. The Workforce may not disclose any confidential or proprietary information of or about VillageCare, its affiliates, vendors, or suppliers, including but not limited to business and financial information, represent that they are communicating the views of VillageCare or do anything that might reasonably create the impression that they are communicating on behalf of or as a representative of VillageCare.
Patient/Client/Resident/Member confidentiality. The Workforce may not disclose any patient/client/resident/member identifiable information of any kind on any social media without the express written permission of the patient and/or the VillageCare Privacy Officer. Identifiable information includes but is not limited to photographs, neighborhoods, birthdates, etc. Even if an individual is not identified by name within the information you consider to use or disclose, if there is a reasonable basis to believe that the person could still be identified from that information, then its use or disclosure could constitute a violation of the Health Insurance Portability and Accountability Act (HIPAA) and VillageCare confidentiality policy.
Fraternizing. Avoid “friending” or “linking” or connecting with patients/clients/members/residents and their families. The Workforce may not disclose any personal information obtained through records or documents viewed or obtained though the normal course of business at VillageCare.
Photography. Avoid taking photographs of patients/residents/clients/members without written approval from the individual or their parent/guardian, unless it is for medical purposes as required or authorized by facility or program policy to be maintained as part of the individuals record with VillageCare. Any photos taken on behalf of VillageCare shall be taken on VillageCare provided phones and/or cameras.
Self-hosted sites. The Workforce must not say or suggest that the views and opinions they express related to VillageCare and healthcare topics represent the official views of VillageCare.
Press Inquiries. All media requests and press inquiries should be referred to the Corporate Communications Department.
Reporting Violations. Suspected violations of this policy should be immediately reported to your supervisor and/or the Privacy Officer.
Violations of this policy may subject the violator to disciplinary action up to an including termination or dismissal from VillageCare. VillageCare reserves the right to demand that a post or statement that violates this policy be corrected, edited or removed.
REPORT SUSPECTED VIOLATIONS
VillageCare has implemented a Compliance Hotline, available 24 hours a day, 7 days a week for reporting concerns confidentially and anonymously. In addition, callers may contact the Compliance department directly at (212) 337-5763 or [email protected]
You may also visit villagecare.ethicspoint.com
*Please note the Compliance Hotline Ethicspoint is answered by an independent third-party who provides a report to the Compliance department for investigation.