INTEGRITY. It is not always easy to act with integrity, but it is possible. For the Hospice by the Sea, Inc. Community, it is required.

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1 INTEGRITY CODE

2 INTEGRITY It is the first of the four cornerstones upon which Hospice by the Sea, Inc. operates. What is integrity? Integrity is honesty. Having integrity means being honest with yourself; with patients, families, clients, teammates, contractors and payors; and with licensing, accrediting, credentialing and regulating entities. Integrity also means that in the event of a conflict between your own interests and those of Hospice by the Sea, Inc., you must put your personal interests aside and act in the interest of Hospice by the Sea, Inc. And, integrity means that on and off the job, you conduct yourself as an ambassador for Hospice by the Sea, Inc. Illegal or inappropriate behavior, anywhere or anytime, by a member of the Hospice by the Sea, Inc. Community, reflects badly on Hospice by the Sea, Inc. Members of the Hospice by the Sea, Inc. Community should never engage in such behaviors. It is not always easy to act with integrity, but it is possible. For the Hospice by the Sea, Inc. Community, it is required. HOSPICE BY THE SEA, INC. CORNERSTONES The Hospice by the Sea, Inc. four cornerstones are: Integrity Excellence Teamwork Accountability These Hospice by the Sea, Inc. cornerstones guide all of the Hospice by the Sea, Inc. Community s actions. A person who is guided by these cornerstones is not likely to violate the Integrity Code. MISSION STATEMENTS Hospice by the Sea The Mission of Hospice by the Sea is to provide skilled medical care and comfort to patients with life-limiting illnesses, and emotional, social, and spiritual sup 1

3 port to patients as well as their families in Palm Beach and Broward Counties, regardless of age, race, creed, diagnosis, or ability to pay. FocusCare FocusCare is a not-for-profit, Joint Commission accredited, Medicare and Medicaid certified, home health agency providing comprehensive home health services to clients residing in Broward and Palm Beach counties. PURPOSE OF THE INTEGRITY CODE The purpose of the Hospice by the Sea, Inc. Integrity Code is to guide all members of the Hospice by the Sea, Inc. Community in our care-giving and business operations. Hospice by the Sea, Inc. is committed to carrying out its day-to-day functions in compliance with Federal and State laws, with government and private insurer standards, and with the standards of licensing, accreditation and credentialing entities; not only because obeying the laws is required, but also because compliance will result in the delivery of safe, quality care to Hospice by the Sea, Inc. s patients. By using the Hospice by the Sea, Inc. Integrity Code to guide each individual s actions, Hospice by the Sea, Inc. earns and maintains its status as a reliable, honest, and trustworthy health care provider. QUESTIONS? If you have any questions about how the Hospice by the Sea, Inc. Integrity Code applies to you or to a situation, you should discuss your questions with a supervisor, or, for contractors, with your Hospice by the Sea, Inc. contact person. If you still have questions after talking with these persons, please contact the External Compliance Hotline at (888)

4 THE ROLE OF LEADERSHIP The leaders of the organization are essential to establishing and maintaining a culture of compliance and ethical conduct. Those in leadership positions are expected to: Serve as examples by modeling the expected professional communication and behaviors, Create a culture and environment which promotes and reinforces ethical behavior. Ensure that staff are educated regarding applicable laws, regulations, standards and policies relevant to their function, Inform all staff that strict compliance with regulations and policies is a condition of employment, and violation will result in disciplinary action up to, and including, termination, Make available the resources necessary to resolve ethical dilemmas, Encourage the reporting and discussion of concerns related to ethical practice, Report potential non-compliance to a supervisor, the Compliance Officer or the Compliance Committee, or on the External Compliance Hotline, Ensure thorough follow up to reported concerns. OUR PATIENTS AND THEIR FAMILIES Hospice by the Sea, Inc. exists first and foremost for the care of our patients. We dedicate ourselves to their safety, their care, their comfort, their well-being and their dignity. Patients are provided with care that is medically necessary, reasonable and appropriate. Hospice patients meet eligibility requirements at admission and throughout their enrollment in Hospice by the Sea, Inc. FocusCare home health agency patients satisfy the Medicare definition of homebound. All patients have an appropriate plan of care which is adhered to by the respective care team. All individual care givers and 3

5 team members provide accurate, timely and complete documentation of care provided. Patients are treated without regard to age, race, creed, sexual orientation, diagnosis or ability to pay. Patients are informed of the care they can expect to receive, as well as any rights to care they may waive as a result of electing the Medicare hospice benefit. We respect the patient s right to privacy of his or her health information, and release only as much information as is required and permitted by law absent the patient s written consent. Hospice by the Sea, Inc. educates its staff that any employee who has concerns about the safety or quality of care provided in the organization may report these concerns to The Joint Commission. REFERRALS Hospice by the Sea, Inc. works hard to build a solid reputation, and seeks to educate those within its service area with respect to the benefits of hospice care, home care and palliative care. Hospice by the Sea, Inc. s referrals are the result of the care we offer, the education we provide, and the reputation we have earned. Hospice by the Sea, Inc. does not: Pay for referrals, Accept payment for referrals, Compensate any contractors above or below fair market value as a means of inducing referrals, Pay nursing facilities in excess of the Medicaid allowable room and board rate, Or provide staff to nursing facilities to perform duties that otherwise should be performed by the staff of the nursing facilities. 4

6 GIVING AND RECEIVING GIFTS The Hospice by the Sea, Inc. Community adheres to Hospice by the Sea, Inc. Personnel Policy and Procedures (section HR15-VI: Gifts) on giving and receiving gifts. BILLING Hospice by the Sea, Inc. bills in accordance with State and Federal laws, payor agreements and internal procedures. Hospice by the Sea, Inc. does not: Bill for items and services not rendered or not medically necessary, Misrepresent the type or level of service rendered, File false cost reports, Fail to refund credit balances, Bill Medicare for non-covered services, Knowingly bill for services rendered by other providers or other duplicate services, Misrepresent a diagnosis in order to obtain payment, Or bill for home health care provided without physician orders. CONFLICTS OF INTEREST What is a conflict of interest? A conflict of interest means that you have a choice to make between doing what is best for Hospice by the Sea, Inc. and getting a benefit for yourself. The conflict could involve use of work time, use of Hospice by the Sea, Inc. s resources, getting a benefit above and beyond your Hospice by the Sea, Inc. compensation for doing your job, or using your position to obtain a financial benefit for someone else in exchange for additional compensation. Some examples of conflicts of interest are: Using Hospice by the Sea, Inc. time and computers for personal business, 5

7 Working - whether for pay or as a volunteer - for a hospice or other business that competes with Hospice by the Sea, Inc., Selecting, or recommending that Hospice by the Sea, Inc. select, a particular contractor because, either directly or indirectly, you will benefit personally. And accepting money or valuable gifts from patients. OTHER ETHICAL PRINCIPALS Personnel In addition to the Hospice by the Sea, Inc. Integrity Code and Compliance Program, all employees and applicable independent contractors must adhere to the Standards of Conduct set forth in the Hospice by the Sea, Inc. Personnel Policy and Procedures (section HR15: Standards of Conduct). Governing Body In addition to the Hospice by the Sea, Inc. Integrity Code and Compliance Program, the Hospice by the Sea, Inc. governing body members must adhere to the Conflicts of Interest Policy set forth in the Hospice by the Sea, Inc. Personnel Policy and Procedures (section HR20: Conflict of Interest). WHEN IN DOUBT, CHECK IT OUT If you have any questions about how the Hospice by the Sea, Inc. Integrity Code applies to you or to a situation, you should discuss your questions with a supervisor. Contractors with Hospice by the Sea, Inc. should address issues with their contact person. If you still have questions after talking with these persons, please contact the External Compliance Hotline at (888)

8 (561) (800) W. Palmetto Park Rd., Boca Raton, FL Washington St., Hollywood, FL External Compliance Hotline (888) Floral artwork designed by Jerry Gotkin.