CODE OF ETHICS AND PROFESSIONAL CONDUCT Mission To provide adults, caregivers and families with programs and services promoting an enhanced quality of life. Family Alliance, Inc. has a clearly stated charitable mission, approved by the governing body, in pursuit of the public good. The mission is responsive to the constituency and communities to be served by Family Alliance. Code of Ethics Given its mission, Family Alliance, Inc. has adopted a code of ethics to guide its board members, committee members and staff in their conduct when acting on behalf of Family Alliance. The Code contains broad principles reflecting the types of behavior Family Alliance expects towards constituents, employees, peers and the public. The Code is intended to provide a framework for ethical decision-making, as no Code can provide specific guidance for all situations. This policy is not intended as a stand-alone policy. It does not embody the totality of Family Alliance s ethical standards, nor does it answer every ethical question or issue that might arise. Rather, it is one element of a broader effort to create and maintain a quality organization that gives ethical conduct the highest priority. This Code shall be reviewed annually. Compliance, Monitoring and Reporting Family Alliance s management is responsible for communicating this Code of Ethics and Professional Conduct to all employees and volunteers and for ensuring its contents are understood and followed. Violations of any of the foregoing provisions may expose Family Alliance, Inc. and the individuals involved to lawsuits and possible criminal action. Staff members who violate this policy are subject to appropriate disciplinary action, up to and including termination. Any alleged violations of this policy will be reviewed by the agency s legal counsel and other appropriate staff members, and they will determine the appropriate action to take. Each employee and officer is responsible for promptly reporting to the agency and circumstances that such person believes in good faith may constitute a violation of this policy in accordance with the Duty to Report Policy. I. AGENCY COMMITMENTS As an employee, you represent Family Alliance, Inc. You have a responsibility to treat the people we serve with respect, courtesy and efficiency.
A. Upon hiring, the following commitment is made to each employee: 1. You will be treated with respect and dignity. 2. The environment will provide the potential for maximum growth. 3. The environment will be conducive to open communication. 4. Challenges will be provided. 5. All employees will be treated equally and fairly. 6. A commitment will be made to work with each individual s strengths. B. Each employee is expected: 1. To work as a team. 2. To not place blame. 3. To remind each of us of our mission and vision. 4. To volunteer rather than be asked. 5. To accept change. 6. To continuously challenge themselves to improve. 7. To serve as a reporter of abuse or neglect and cooperate in any investigation by OIG II. PROFESSIONAL CONDUCT A. Act at all times in accordance with the highest ethical standards and in the best interest of Family Alliance, its constituents and reputation exercising care, good faith and due diligence in organizational affairs. B. Strive for personal growth in the field, excellence and innovation, and demonstrate professional respect and responsiveness to constituents and others. C. Support the mission and values of the agency. D. Work cooperatively with all co-workers. E. Maintain loyalty to Family Alliance, Inc. F. Refrain from developing personal relationships with individuals seeking service at the agency and abide by the Ethical Boundary Policy G. Improve the public understanding of the role of adult care. H. Refrain from using an employment position for personal gain. I. Be responsible for proper care of the environment and equipment. J. Be responsible for honest personnel time records. K. Ensure appropriate use of county, Federal, private grantors, and agency property and funds. L. Adhere to the agency organizational chart, follow proper chain of command, and comply with expectations as defined in job descriptions. M. Contribute to an organizational culture that respects the diverse, individual contributions of staff and leadership. N. Respect the confidentiality of sensitive information about Family Alliance, its clients, constituents, board and employees. Family Alliance respects and protects the confidentiality and privacy rights of individual clients, grantees, employees, donors, volunteers and others in the agency consistent with applicable law. O. Comply with applicable federal, state and local laws, regulations and fiduciary responsibilities and immediately report suspected dishonest or fraudulent behavior. The Board of Directors and staff are educated on and comply with all federal, state and local
laws, regulations and fiduciary responsibilities, seeking professional legal and accounting advice when needed to support compliance. P. Adhere to document retention policy Q. For the Board of Directors, provide credible and effective oversight to the organization s work. The governing body members have the requisite skills and experience to carry out their duties. The Board of Directors regularly assesses Family Alliance s mission and the effectiveness of the agency and its leadership in achieving it. R. Abide by the governing documents and policies of Family Alliance, including the Conflict of Interest and Corporate Compliance policies. Family Alliance staff and Board of Directors are educated about what constitutes conflict of interest and prevent or manage any actual, potential or perceived conflicts through disclosure, abstention or other means. S. Be accountable for adhering to this Code of Ethics. III. Clinical Ethics Family Alliance, Inc. has an obligation to its clients, third party payers and the state and federal government to exercise diligence, care and integrity when submitting claims for payment. Family Alliance, Inc. is committed to maintaining the accuracy of every claim it processes and submits. Any false, inaccurate, or questionable claims should be reported immediately to the employee s supervisor or the Compliance Officer. False billing is a serious offense. Medicaid rules prohibit knowingly and willfully making or causing to be made any false statement or representation of the material fact in an application for benefits or payment. It is also unlawful to conceal or fail to disclose the occurrence of an event affecting the right to payment with the intent to secure payment that is not due. With respect to the submission of claims, a claim must: A. Be accurate and submitted in a timely manner, B. Be only for items or services that are 1. medically necessary, 2. fall within the coverage guidelines contained in applicable laws, rules and regulations, and 3. are documented in the clients clinical record In this regard, prior to submitting a claim for payment, it is necessary to verify that all documentation for services reflected on the claim, such as physician orders and prior approvals, are available in a proper and timely manner. Claims may only be submitted when appropriate documentation supports the claim and only when such documentation is maintained and available for audit and review. Documentation which serves as the basis for a claim must be appropriately organized in legible form so that such documentation may be audited and reviewed. Diagnosis and procedures reported on reimbursement claims must be based on the clinical record and other documentation. Documentation necessary for accurate code assignment must be made available to all employees with coding responsibility. It is strictly prohibited to:
Bill for items or services not provided Bill for services with the belief that the bill may be denied Duplicate billing Upcode Fail to monitor medical necessity on an on-going basis Falsify information on the claim form and/or accompanying documentation Alter medical records Manipulate the client s diagnosis in an attempt to receive improper payment Fail to maintain medical necessity documentation Falsify use of location of service codes Improperly solicit a client with activities and high-pressure marketing of noncovered or unnecessary services IV. FINANCIAL ETHICS A. Financial Record-Keeping It is the policy of Family Alliance, Inc. to fully and fairly disclose the financial condition of the agency in compliance with the applicable accounting principles laws, rules and regulations and to make full, fair, accurate, timely and understandable disclosure in our periodic reports. Honest and accurate recording and reporting of information is critical to our ability to make responsible business decisions. Family Alliance s accounting records are relied upon to produce reports for the agency s management, rating agencies, creditors, governmental agencies and others. Therefore, financial statements and the books and records on which they are based must accurately reflect all corporate transactions and conform to all legal and accounting requirements. The system of internal control is designed to provide this information. All employees have a responsibility to ensure that Family Alliance s accounting records do not contain any false or intentionally misleading entries. Information on which our accounting records are based is the responsibility of all employees. Family Alliance, Inc. does not permit intentional misclassification or transactions as to accounts, departments or accounting periods. In particular, Family Alliance, Inc. requires that: All agency accounting records, as well as reports produced from those records, are kept and presented in accordance with the laws of each applicable jurisdiction All records fairly and accurately reflect the transactions or occurrences to which they relate All records fairly and accurately reflect in reasonable detail the agency s assets, liabilities, revenues and expenses The agency s accounting records do not contain any intentionally false or misleading entries No transactions are misclassified as to accounts, departments or accounting periods All transactions are supported by accurate documentation in reasonable detail and recorded in the proper account and in the proper accounting period
All agency accounting financial reports be prepared in accordance with generally accepted accounting principles The agency s system of internal accounting controls, including compensation controls, to be followed at all times B. Improper Payments No payment or transfer of the agency s funds or assets shall be made that is not authorized, properly accounted for and clearly identified in the agency s books. Payment or transfer of the agency s funds and assets are to be used only as specified in the supporting documents. No employee or officer may authorize any payment or use any funds or assets for a bribe, kickback, or similar payment that is directly or indirectly for the benefit of any individual (including any government official, agent, or employee anywhere in the world,) company or agency in the United States or any foreign country, and which is designed to secure favorable treatment for the agency. Under federal legislation, it is a felony to make payments of this kind to foreign government officials. C. Political Contributions It is Family Alliance s policy not to contribute any agency funds or assets to any political party, committee, organization or candidate for any office (federal, state or local,) in the United States or any foreign country. Employees may, on their own time, support individual candidates or political committees, all subject to applicable laws, and may make voluntary contributions to such candidates or committees, including any agency-related political action committee. D. Acceptance of Payments Employees and officers may not seek or accept either directly or indirectly, any payments, fees, services, or other gratuities (irrespective of size or amount) outside the normal course of the employee s business duties from any other person, company or organization that does or seeks to do business with Family Alliance. Gifts of cash or cash equivalents of any amount are strictly prohibited. The receipt of common courtesies, sales promotion items of nominal value, occasional meals, and reasonable entertainment appropriate to a business relationship and associated with business discussions are permissible. E. Business Entertainment All solicitations or dealings with suppliers, customers, or others doing or seeking to do business with Family Alliance shall be conducted solely on a basis that reflects both the agency s best interests and its high ethical standards. The agency does permit the providing of common courtesies, entertainment, and occasional meals for potential or actual suppliers, customers, or others involved with the agency s business, in a manner appropriate to the agency s relationship and associated with business discussions. Expenses in this connection must be reasonable, customary and properly authorized.
F. Confidentiality All employees and officers are responsible for safeguarding and keeping confidential any information that Family Alliance considers to be of a confidential or sensitive nature. Such information includes, but is not limited to, financial records and reports, marketing and strategic planning information, employee-related documents, unpublished manuscripts as well as information relating to potential mergers and acquisitions, and other materials that Family Alliance would not want disclosed to a competitor or any unauthorized recipient, or that might be harmful to the agency if disclosed, whether or not such information is marked confidential. Confidential information also includes information concerning possible transactions with other companies or information about the agency s clients, suppliers or joint venture partners, which Family Alliance is under an obligation to maintain as confidential. Employees and officers may not use confidential information for their own personal benefit or the benefit of persons or entities outside the agency, and must exercise caution and discretion with respect to any appropriate temporary removal of confidential or sensitive information from Family Alliance s premises, and should safeguard the information from unintended disclosure or loss. G. Fair Dealing Each employee and officer should endeavor to deal fairly with Family Alliance s suppliers, competitors and employees. No one should take unfair advantage of another through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair-dealing practice. Information about the agency s competitors must be used in an ethical manner and in compliance with the law. Under no circumstance should information be obtained through theft, illegal entry, blackmail or electronic eavesdropping, or through employees misrepresenting their affiliation with Family Alliance or their identity. Any proprietary or non-public information about the agency s competitors should not be used if it is suspected that such information has been obtained improperly.
V. MARKETING ETHICS A. The Family Alliance, Inc. Development Department will not solicit from the following foundations or corporations who: 1. Require a position on abortion or right-to-life issues 2. Require a political position 3. Want Family Alliance, Inc. to run on their model of service 4. Are on the McHenry United Way Do Not Solicit list 5. Do not fund unsolicited proposals, as listed in the Donor s Forum database 6. Do not fund seniors, adults, healthcare or some combination of Family Alliance s programs/services/activities, (i.e. food service, animals, music, art, horticultural, etc.) B. Family Alliance, Inc. will professionally and accurately represent its services, programs, staffing, funding, and community support in all printed marketing materials and verbal presentations. C. Family Alliance, Inc. strives to prepare its marketing materials without discrimination to age, gender, sexual preference, race, ethnicity, religious affiliation, etc. D. Family Alliance, Inc. requires a client/family signed release prior to photographic or written (testimonial) publication. E. Family Alliance, Inc. solicits funding from all McHenry County religious organizations, regardless of affiliation. F. Family Alliance, Inc. will not utilize any materials, printed or premiums, which could be deemed as sexually explicit or containing sexual innuendo, containing references to alcohol or drug use, or those that prescribe to any religious or political affiliation. G. Family Alliance, Inc. will use positive, person-centered language when describing its programs, services, clients, etc.