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 our Code of Conduct . You can access a copy of this document on the organization’s website.
- Use common sense and good judgment. You’re accountable for your actions and your statements could have an impact on others. Remember that what you post or publish may be public information for a long time.
- Don’t post information or news that you know is false. If you realize that you’ve make a mistake or error, correct it quickly.
- Be respectful. Always be fair and courteous to fellow co-workers, customers, vendors, suppliers or people who work on behalf of VillageCare even if you disagree with their opinion. A conversational, personal tone often works best – similar to how you’d speak.
- Be sensible. When posting, avoid using statements, photos, video or audio that reasonably could be viewed as malicious, obscene, threatening or intimidating, that disparage customers, co-workers or vendors, suppliers, or that might constitute harassment or bullying. Examples of this type of conduct might include offensive posts meant to intentionally harm someone’s reputation or posts that could contribute to a hostile work environment on the basis of race, color, religion, sex/gender (including pregnancy), gender identity and expression, national origin, disability, marital status, age, sexual orientation, citizenship status, Veteran status or any other classification protected by applicable law, rules or regulations.
- Be transparent and disclose your relationship to the company. If you’re writing about VillageCare or our services or industry, use your real name (not a pseudonym), identify that you work for VillageCare and be clear about your role. If you have a vested interest in what you’re discussing, be the first to openly say so.
- Maintain the confidentiality of our patient’s, business and proprietary information. Don’t externally post or share patient health information - this includes posting photographs of patient’s in our care settings and in their home. Don’t post business-related, confidential information or communications that belong to VillageCare or our customers, vendors, suppliers or others, such as customer lists, financial data, systems and technology information, intellectual property and operating plans. This type of information also shouldn’t be shared with others at VillageCare unless there’s a legitimate “need to know” and you’re authorized to do so. If you’re uncertain whether information is meant to be private or internal to VillageCare, seek the advice of Corporate Compliance Officer, General Counsel or your Manager.
- Refer media, press and investor inquiries to our authorized company spokespersons if an official company response is needed. Employees should not speak on VillageCare’s behalf with the media, press without contacting the AVP of Corporate Communications.
- Minimize security risks. Social media sites and accounts can attract hackers and can present risks to corporate networks as well as your personal computer or mobile device. A compromised account can also cause disclosure concerns for our company. To minimize these risks, use a password for social media accounts that isn’t easy to guess. Monitor your social media accounts periodically if you don’t actively use them. Also, be mindful that social media sites sometimes are used to distribute malicious software or code, or “malware”. If you think a link sent to you might be malware, don’t click on it, as it could result in software or code being downloaded or installed on your own computer, mobile device and/or the company’s networks.
Special Guidelines: Official Use
- Official company use of social media. Official use of external VillageCare - sponsored blog, website, podcast, account, page, group, etc. related to our business, products or services, is managed by the VP of Branding & Marketing Communications.
Special Guidelines: Personal Use
- Your personal use of social media use shouldn’t interfere with your responsibilities at VillageCare. Our computer systems are to be used primarily for business purposes. While incidental personal use of our systems at work may be acceptable under certain circumstances, excessive use of our computer systems for your personal use of social media and social networks could result in the company limiting your ability to engage in these activities during work time and/or taking disciplinary action.
- If needed, clarify in a post or comment that you’re expressing your own views and opinions and not those of our company. While this type of clarification probably won’t be needed for most posts and comments, sometimes it will be important or necessary to distinguish between personal views and company views, depending on the topic.
- Don’t host personal blogs, websites or other types of online content on property owned or leased by VillageCare.
If you violate this policy, we may require you to correct, edit or remove a post or statement. In addition, violations of these guidelines by employees can result in disciplinary action, including termination of employment.
This Policy Statement will be administered in accordance with applicable laws, rules and regulations.