Compliance Policy

Details

CORPORATE COMPLIANCE

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.

DIGITAL MEDIA POLICY STATEMENT

Introduction

VillageCare recognizes that digital media may be used by covered persons in the course of their job responsibilities, as well as in their personal lives. The use of digital media while potentially fun and rewarding presents certain risks and carries with it certain responsibilities. VillageCare understands that covered persons must use digital media in a way that is compliant with the organization's Code of Conduct and all other applicable laws, regulations and ethical requirements. To that end, VillageCare has established this policy with the expectation that all covered persons will comply with the requirements delineated herein.

Basic Principles

Adhere to the Code of Conduct. Covered persons are expected to adhere to all existing VillageCare rules and policies when using or participating in digital media. All the rules that apply to other VillageCare communications apply here, specifically: (a) respecting customers, members, clients, residents and one another; (b) protecting the confidentiality, privacy, and security of all individually identifiable information regardless of the owner, PHI and VillageCare information; and (c) safeguarding and proper use of VillageCare assets.
Be respectful. When representing VillageCare in any official capacity, covered persons may not post any material that is or may reasonably be seen as obscene, defamatory, discriminatory, profane, libelous, threatening, harassing, abusive, hateful, or embarrassing to another.
Abide by the law and respect copyright laws. Covered persons 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 covered persons, it is critical that all covered persons abide by copyright laws by ensuring that they have permission to use or reproduce any copyrighted text, photos, graphics, video, or other material owned by others.
VillageCare hosted sites: All VillageCare hosted sites must be created and administrated by the Marketing/Communications Team and receive approval from the leadership team. Employees from other areas may request a social media or blog site from the Marketing/Communications Team but must follow the appropriate approval process before use. The Marketing/Communications Team will monitor said sites to ensure continued compliance with this policy, the Code of Conduct and all other applicable requirements.
Proprietary information. Covered persons 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.
Representative Status: Covered persons may not 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 unless they have been formally assigned such representative status by virtue of their position within the organization.
Resident/Member confidentiality. Covered persons may not disclose any resident/member identifiable information of any kind on any digital media without the express written permission of the resident/member and the VillageCare Privacy Officer and Marketing/Communications Team. 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 policy.
Fraternizing. Friending, linking, following, tagging or sharing with residents, members and/or their families is strictly prohibited.
The Workforce confidentiality. Covered persons 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 residents/clients/members without written approval from the individual or their legal representative/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. Covered persons 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 Marketing/Communications Team.
Employment Information on Social Media: With the exception of professional networks (such as LinkedIn) it is advisable to not list your workplace and title on personal social media pages.
Online Reviews: Only the Marketing/Communications Team will respond to reviews on social media and review platforms including but not limited to Google.
Reporting Violations. Suspected violations of this policy should be immediately reported to your supervisor and/or the Privacy Officer.

Violations

Violations of this policy may subject the violator to disciplinary action up to and 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]

Compliance Hotline
844.348.2664

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.