VisionQuest Code of Conduct Code of Conduct The Code of Conduct guides all employees and contractors by establishing minimum mandatory standards of conduct for individual decision-making while performing their duties. Since ethical conduct begins at the top and filters throughout, the Code includes additional standards applicable to professional, management and administrative personnel. All employees and contractors are to know the Code of Conduct. Standards of Conduct The Code of Conduct is comprised of six Standards of Conduct. Standard 1: Employees will be aware of the requirements of their job descriptions and the appropriate standards for their conduct The Compliance Officer ensures the development of timely staff training programs that are based upon applicable laws, regulatory requirements, contractual obligations and internal policies and operating procedures. The Vice President for Human Resources, in conjunction with the Compliance Officer, will annually review the curriculum. Training will be conducted under the auspices of Human Resources, which may request the participation of such employees or consultants as may be necessary to provide effective training Supervisors are responsible to ensure that employees under their supervision attend scheduled trainings and know the Code of Conduct. A list of applicable laws and regulations that need to be incorporated into the training program will be maintained by the Compliance Officer. Standard 2: Training programs will define and clarify fraudulent or abusive practices, clearly inform employees that such practices are prohibited and communicate that employees are obligated to report suspected fraud or abuse through available internal, external and anonymous channels Employees are to be instructed that federal and state laws require them to provide accurate documentation to support billings by VisionQuest and that falsifying any reports or documentation, whether intentionally or negligently, may lead to criminal prosecution and/or civil liability. Employees will also be informed that fraudulent completion of reports or documentation will result in termination of employment. Employees are to understand that they
are responsible to request additional training if they do not fully understand how to comply with any policies and procedures. The training program will reinforce employee responsibility to report wrongdoing. Employees will be told about the various internal, external and anonymous channels through, which wrongdoing can be reported. Standard 3: Retaliation against employees reporting misconduct is prohibited Retaliation against persons reporting misconduct, often times referred to as whistle blowing, is prohibited. The Director of Human Resources will develop procedures for an employee to utilize if the employee believes that someone is retaliating against him/her for reporting misconduct. Managers and supervisors will promote an open environment that is conducive to open communication and dispels concerns about retaliatory conduct. Employees will be encouraged to report conduct that they consider to be retaliatory. Persons found to have engaged in retaliatory conduct will be subject to disciplinary procedures, which include employee sanctions up to termination. Standard 4: Employees will acknowledge and respect the rights of clients VisionQuest adheres to youths rights under applicable statues and regulations. Employees are to treat each client as a valued person, deserving of respect. The same dignity and respect will be given to the parents and family members of each client. The treatment program is designed to enable all involved to feel better about themselves and to have confidence in their own judgments. Services are provided to clients without regard to race, religion, sex, ethnicity, sexual preference, age (within licensed ranges) and handicap (with the exception of those that would make a client's participation in the treatment program unsafe or without benefit). The rights will be reviewed with all new employees during orientation. Standard 5: Client records and information will remain confidential All client information is confidential, regardless of whether it is maintained in electronic or paper format. Employees will protect and preserve that confidentiality. Information about clients will not be released to or discussed with other employees or persons unless it is necessary for the client's care or is required or permitted by law. Discussions of confidential information will be private, and individuals not involved in the client's care must have the client's permission in order to be present. Client records will be kept secure and access is only available to those persons who are involved with the client's care. (Management and administrative employees auditing records or conducting quality assurance activities may review youth files.) Confidential
information obtained either during assigned duties or by accident should not be released or discussed with anyone unless that individual is part of the child s treatment team. Employees should not seek access to confidential information out of curiosity, for malicious purposes or for financial gain. Standard 6: Unacceptable Business Practices and Conflicts of Interest Employees and contractors will be honest in their business dealings and with information that they report. This requirement applies to information related to youths, other employees and finances. False Statements Employees will not make false statements when reporting information related to business activities. Employees will also not selectively report facts or omit information that is known to them. False claims Employees should never submit false or misleading information to support reimbursement claims. VisionQuest will not provide unnecessary services and will not request reimbursement for such services. Employees must immediately report any knowledge or suspicions about false claims to the designated Quality Assurance representative or one of the hotlines. Gifts and Gratuities Employees may not accept, pay or offer to receive or pay compensation of any kind in exchange for client referrals or compensation. An employee who is offered a gift or gratuity will immediately report the incident to his/her supervisor or the designated Quality Assurance representative. Employees families, and businesses in which employees or their families have a controlling interest, are also prohibited from making or accepting gifts or gratuities. Political Contributions Employees may not contribute or donate VisionQuest funds, products, services or other resources to any political cause, party or candidate. Employees may make voluntary personal contributions to political causes, parties or candidates. However, employees cannot represent that such contributions came from VisionQuest and may not obtain money from VisionQuest for the sole purpose of making such a contribution. Solicitation of political contributions shall not be made during working hours and will not be conducted on company premises. Employees will not be forced or pressured into making political contributions.
Insider Trading Employees may not trade in the securities of any company or buy or sell any property or assets based on nonpublic, confidential information acquired through their employment at VisionQuest. This information is confidential, whether it comes from VisionQuest itself or from any other source with which the company has a confidential relationship. Insider trading is a crime that violates both federal and states securities laws and is strictly prohibited. Conflict of Interest Employees are prohibited from engaging in any activity, practice or act that conflicts with the financial interests of VisionQuest, its clients, or placing agents. Transactions that create the appearance of impropriety are also prohibited. A conflict of interest occurs if an employee's personal or family financial interests may benefit by action of the employee takes on behalf of VisionQuest. A conflict of interest also may exist if outside personal or business activities hinder or distract the employee from the performance of his or her duties or if the employee uses VisionQuest resources for purposes not related to VisionQuest s business activities. Questions regarding conflicts of interest should be directed to Conflicts Committee of the Board of Directors. An employee may seek prior approval from Board of Directors for any activity that may involve a conflict of interest or creates the appearance of impropriety. When seeking such approval, the employee must provide full disclosure of all pertinent details regarding the transaction and must demonstrate that VisionQuest, its clients or placing agents would not obtain a greater benefit from a transaction with another party. Debarment of Contractors VisionQuest will not hire or contract with any person or entity that is currently excluded, suspended, debarred or otherwise ineligible to participate in state or federal healthcare programs. In addition, VisionQuest will not hire or contract with any person who has been convicted of a prohibited criminal offense related to the provision of healthcare items or services and who has not been reinstated in state or federal healthcare programs after a period of exclusion, suspension, debarment or ineligibility. Competitor Information Employees are prohibited from obtaining proprietary or confidential information about other businesses or persons through surreptitious, deceptive, illegal or unethical means. Employees may not misrepresent themselves to obtain information about a competitor. Information may be gathered about other organizations by reviewing public documents, public records and other published information.
Contract Negotiation Employees involved in the negotiation of a contract must ensure that all the data generated, supplied and represented is accurate, current and complete. Failure to follow these guidelines may result in civil or criminal liability for VisionQuest, the employee and any managers or supervisors who condone such a practice. VisionQuest will not knowingly contract to obtain services or products from any individual or company that has been convicted of a criminal offense related to healthcare and / or is listed by a state or federal agency as debarred, excluded or otherwise ineligible for participation in federally funded healthcare programs. All contracts for services to be provided to VisionQuest will include a provision that the contractor providing the service shall comply with any applicable federal, state or local laws prohibiting discrimination. Only the President, Vice-Presidents, State Directors or other persons authorized under specific policies or by a resolution of the Board of Directors of VisionQuest may sign contracts. Kickbacks and Improper Payment for Referrals Federal and state laws prohibit the receipt of payments for referral of members for services. VisionQuest, its employees, and providers are prohibited from knowingly and willfully soliciting, offering to pay or make payments (kickbacks, bribes, or rebates) for increased referrals for services. In addition, the receipt of payments for purchasing, leasing, ordering or for recommending the purchase, lease, or ordering of goods, facilities, or services is also prohibited. A managed care organization or contractor is prohibited from offering a reduced rate for its items or services in the Federal capitated arrangement in order to have the opportunity to participate in other product lines that do not have stringent payment or utilization constraints. This process is termed, swapping ; low capitation rates could be traded for access to additional fee-for-service lines of business in exchange for discounts. The definition of payments includes, but is not limited to, Cash; Payment for goods, services, or rentals in excess of fair market value; Free goods or services; Paying the salary of an employee; Waiving or non-collection of co-payments or deductibles. VisionQuest employees are prohibited from engaging in any activity that could be construed as an improper referral or payment, even if the activity appears to fit within a legal safe harbor exception, without prior approval by Legal Counsel and other corporate officers (CEO, CFO, COO, CMO, etc.) as appropriate.
Reporting a Known or Suspected Violation of the Code of Conduct When and how do I report a known or suspected violation? Employees should report any actual or potential violations of the Corporate Code of Conduct immediately. Employees can directly report known or suspected violations to VisionQuest s anonymous hotline ReportIt - easily accessible from both VisionQuest s public website, www.vq.com, and intranet site - Feather, the designated Compliance / Quality Assurance representative in each program, or the Executive Vice President at 610-486-2280 x3242. Reports of suspected or alleged child abuse or neglect must be reported directly to the NJ Child Abuse Hotline at 1-877-NJ-ABUSE. Will my confidentiality be maintained? If requested, every effort will be made to keep your identity confidential, but confidentiality cannot be guaranteed. However, no adverse action or retaliation of any kind will be taken against an employee reporting a known or suspected violation of the Code of Conduct. What happens after a report is filed? Internal reports are forwarded to the designated Compliance / Quality Assurance representative. The representative begins a detailed investigation upon receiving sufficient information to act on a credible report of a suspected violation. All employees are required to cooperate fully with investigations. What happens after the investigation is complete? The Compliance / Quality Assurance representative reports the results of the investigation to VisionQuest s Corporate Compliance Officer, the Executive Vice President. Corrective action will be taken when needed. The Executive Vice President, in collaboration with the Vice President for Human Resources, will institute appropriate disciplinary action. Specific examples include, but are not limited to the following: (note that these examples are to be intentional, and malicious attempts, but not accidental intents on the part of the employee engaged in the act) Billing for a more expensive service than actually rendered (upcoding) Billing more than once for the same service (double billing) Billing for services never performed or ordered by the practitioner Billing for separate services that should be combined into one billing code Performing or providing inappropriate or unnecessary services Providing substandard care not consistent with current standards of practice Offering free services, equipment or supplies in exchange for a recipient s MA ID number
Giving or accepting something of value in return for providing medical services (kickbacks) Dispensing generic drugs and billing for brand name drugs Falsifying medical or clinical records Over utilizing or abusing the use of medical services by a MA recipient.