Missouri Medicare Select. Standards of Conduct

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1 Missouri Medicare Select Standards of Conduct 1

2 Contents INTRODUCTION... 3 BUSINESS ETHICS AND CONDUCT... 3 CONFLICTS OF INTEREST... 4 EMPLOYEE PROCEDURES AND CONDUCT... 4 HIPPA Privacy and Security Plan... 4 Fraud, Waste, and Abuse... 5 General Compliance Training... 5 Violations of the Standards of Conduct... 5 ATTESTATION TO COMPLY WITH STANDARDS OF CONDUCT

3 INTRODUCTION This employee handbook is designed to acquaint you with Missouri Medicare Select Standards of Conduct (Standards). The Standards are designed to provide you with information about the overarching principles and values of the organization. In particular, Missouri Medicare Select expects all employees and business associates to conduct themselves in an ethical manner, and to report all instances of noncompliance and potential fraud, waste, and abuse (FWA) through appropriate mechanisms. The Standards identify how issues can be reported and that such reporting can be done anonymously and confidentially, and without fear of retaliation. Furthermore, reported issues will be addressed and corrected in a timely manner. Compliance is the responsibility of all Missouri Medicare Select employees and business associates. In addition, compliance and ethics are valued at the highest levels of authority within the organization. You should read, understand, and comply with all provisions of the Standards. It describes many of your responsibilities as an employee. As Missouri Medicare Select continues to grow, and as federal and state laws change, the need may arise and Missouri Medicare Select reserves the right to revise, supplement, or rescind any policies or portion of the Standards as it deems appropriate, in its sole and absolute discretion. Employees will be notified of changes to the Standards as they occur. As a condition of employment, all employees will certify that they have received, read, and will comply with all the elements of the Standards within the first thirty (30) days of hire. Furthermore, all Missouri Medicare Select employees must sign the attestation form at the end of the Standards document attesting to their having read and understood the contents of the Standards. All Missouri Medicare Select employees must complete the attestation annually. BUSINESS ETHICS AND CONDUCT The successful business operation and reputation of Missouri Medicare Select is built upon the principles of fair dealing and ethical conduct of our employees. Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulous regard for the highest standards of conduct and personal integrity. The success of Missouri Medicare Select is dependent upon our customers' trust, and we are dedicated to preserving that trust. Employees are expected to conduct themselves in a way that will merit the continued trust and confidence of our customers. Missouri Medicare Select will comply with all applicable laws and regulations and expects its employees to conduct business in accordance with the letter, spirit, and intent of all relevant laws and to refrain from any illegal, dishonest, or unethical conduct. In general, the use of good judgment, based on high ethical principles, will guide you with respect to lines of acceptable conduct. If a situation arises in which it is difficult to determine the proper course of action, the matter should be discussed openly with your immediate supervisor and, if necessary, with Compliance and/or Human Resources. Compliance with this policy of business ethics and conduct is the responsibility of every Missouri Medicare Select employee. Disregarding or failing to comply with this standard of 3

4 business ethics and conduct could lead to disciplinary action, up to and including possible termination of employment. CONFLICTS OF INTEREST Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This policy establishes only the framework within which Missouri Medicare Select wishes the business to operate. These guidelines provide general direction so that employees can seek further clarification on issues related to the subject of acceptable standards of operation. Contact Compliance and/or Human Resources for more information or questions about conflicts of interest. Transactions with outside firms must be conducted within a framework established and controlled by the executive level of Missouri Medicare Select. Business dealings with outside firms should not result in unusual gains for those firms. Unusual gain refers to bribes, product bonuses, special fringe benefits, unusual price breaks, and other windfalls designed to ultimately benefit the employer, the employee, or both. An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for that employee or for a relative as a result of Missouri Medicare Select's business dealings. For the purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage. No "presumption of guilt" is created by the mere existence of a relationship with outside firms. However, if employees have any influence on transactions involving purchases, contracts, or leases, it is imperative they disclose these relationships to Missouri Medicare Select management as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties. Personal gain may result not only in cases where an employee or relative has a significant ownership in a firm with which Missouri Medicare Select does business, but also when an employee or relative receives any reward, bribe, substantial gift, or special consideration as a result of any transaction or business dealings involving Missouri Medicare Select. EMPLOYEE PROCEDURES AND CONDUCT HIPPA Privacy and Security Plan The Health Insurance Portability and Accountability Act of 1996 (HIPAA) rules create a framework to protect the privacy and security of patient s and health plan member s health information. Missouri Medicare Select supports the goals of HIPAA and documents its commitment to comply with these laws in its HIPPA Privacy and Security Plan policy. All employees are required to complete the HIPPA and Health Information Technology for Economic and Clinical Health (HITECH) Compliance Courses on their first day of employment. Employees are also required to complete the training at least once annually. 4

5 Fraud, Waste, and Abuse Missouri Medicare Select is committed to the responsible stewardship of our resources, and maintaining a comprehensive plan for detecting, preventing, and correcting fraud, waste, and abuse (FWA). To that end Missouri Medicare Select encourages any individual who is aware of or suspects acts of fraud, waste or abuse of Missouri Medicare Select resources in any departmental area, by any provider or with any entity that Missouri Medicare Select contracts with, such as in the Medicare program, to report such acts to the Missouri Medicare Select Compliance Officer. Missouri Medicare Select employees can use the following information to submit questions or reports of suspected or detected noncompliance or potential FWA. Methods for Reporting Potential and Detected Fraud, Waste, and Abuse (FWA) and Noncompliance Anonymous Hotline (844) Confidential Mailing Address Corporate Compliance Officer Missouri Medicare Select P.O. Box 5849 Glen Allen, VA Missouri Medicare Select does not tolerate fraudulent or other dishonest behavior and will take appropriate investigative and corrective action upon receiving such reports. Missouri Medicare Select will not take punitive action against any employee reporting FWA in good faith. All employees are required to complete the Fraud, Waste, and Abuse training within 90 calendar days of the start of their employment. Employees are also required to complete the training at least once annually. General Compliance Training General compliance training will address preventing, detecting, and correcting noncompliance issues, a description of the compliance program, and methods for reporting potential issues of noncompliance that ensure confidentiality and anonymity (see table in previous section). Moreover, such training efforts will highlight that Missouri Medicare Select adheres to a standard of non-retaliation for compliance-related questions or reports of potential noncompliance or FWA. In compliance with Centers for Medicare and Medicaid Services (CMS) requirements, all employees and governing body members must receive general compliance training within 90 days of initial hiring, and annually thereafter. Violations of the Standards of Conduct Violations of the Standards are grounds for discharge or other disciplinary action, adapted to the circumstances of the particular violation and having as a primary objective furtherance of 5

6 Missouri Medicare Select's interest in preventing violations and making clear that violations are neither tolerated nor condoned. Disciplinary action will be taken, not only against individuals who authorize or participate directly in a violation of the Standards, but also against: Any employee who may have deliberately failed to report a violation of the Standards; Any employee who may have deliberately withheld relevant and material information concerning a violation of the Standards and The violator's managerial superiors, to the extent that the circumstances of the violation reflect inadequate leadership and lack of diligence. 6

7 ATTESTATION TO COMPLY WITH STANDARDS OF CONDUCT I have reviewed the Missouri Medicare Select Standards of Conduct. I understand that it is my responsibility to read and comply with the Standards of Conduct and ALL Missouri Medicare Select policies and procedures. I understand that I should consult with the Chief Compliance Officer (Eric Messick) regarding questions I have about the Missouri Medicare Select Standards of Conduct, policies, and procedures. I understand that there are additional Missouri Medicare Select policies, procedures, and rules; and it is my responsibility to read and comply with ALL policies and revisions made to them. Because the information within these policies may change, I acknowledge that revisions to policies may occur at any time, with or without prior notice, and in the sole discretion of Missouri Medicare Select management. I understand that revised information may supersede, modify, or eliminate existing policies. Printed Name Date Signature Date 7

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