Jones Memorial Hospital Health Care Compliance Code of Conduct
Jones Memorial Hospital Health Care Compliance Code of Conduct
Purpose
The purposes of this Code of Conduct policy are:
- to clarify the expectations of the JMH community during interactions with any individual at Jones Memorial Hospital
- to encourage the prompt identification and resolution of alleged inappropriate conduct
- to encourage identification of concerns about the well-being of a member of the JMH community whose conduct is in question
Policy
The Medical Staff, Board of Directors, Directors and Coordinators, staff, contracted employees/workers and volunteers (the JMH community) at Jones Memorial Hospital are committed to supporting a culture that values integrity, honesty, ethical practices and fair dealing with each other. We believe that caring and compassionate personal behaviors are at the core of our organization's commitment to delivering quality patient care. Our customers include, but are not limited to, patients and their families, providers, co-workers, visitors, volunteers and our generous benefactors.
In addition, this institution will admit, provide services, transfer, and/or discharge patients based solely upon their clinical needs and without regard to cost of services rendered, race, religion, gender, gender identification, age, ability to pay for services rendered, national origin, disability, political affiliation, veteran status, sexual orientation or preference.
Towards these goals, the JMH community maintains a workplace that is free from behaviors that are or could be perceived as inappropriate, harassing, or that do not endeavor to meet the highest standards of professionalism.
Following is a list of behavioral standards that have been developed to reflect Jones Memorial's commitment to service excellence. These standards provide useful guidelines for treating our customers in a considerate and respectful manner. By making an official commitment to practice these standards, we reinforce them, acknowledge that they are expected behaviors and encourage employees to practice them diligently. Our organization's daily commitment to these standards of behavior will ensure a healing environment that is pleasant, comfortable and non-threatening for all of our customers.
General Expectations
- Consider first the well-being of the patient.
- Interactions with patients, visitors, employees, providers, volunteers, or any other individual shall be conducted with courtesy, honesty, respect and dignity.
- Conduct will be ethical, professional and appropriate at all times.
- All members of the Jones Memorial Hospital community are expected to refrain from conduct that may reasonably be considered offensive to others or disruptive to the workplace or patientcare. Offensive conduct may be written, oral or behavioral. Examples of inappropriate conduct would include, but are not limited to:
Inappropriate Words/Actions/Inaction
- Profane, disrespectful, insulting, demeaning or abusive language
- Arguments with patients, family members, staff or other care providers (respectful discussion in private in which disagreement is expressed are not arguments)
- Rudeness
- Boundary violations with patients, family members, staff or other care providers
- Gratuitous negative comments about another staff member's care (orally or in chart notes)
- Passing severe judgment or censuring colleagues or staff in front of patients, visitors or other staff
- Outbursts of anger; throwing or breaking things
- Behavior that others would describe as bullying and/or intimidating
- Insensitive comments about the patient's medical condition, appearance, situation, etc.
- Jokes or negative comments about race, ethnicity, religion, sexual orientation, age, physical appearance or socioeconomic or educational status
- Refusal to comply with known and generally accepted practice standards such that the refusal inhibits staff or other care providers from delivering quality care.
- Use or threat of unwarranted physical force
- Repeated failure to respond to calls or requests for information or persistent lateness in responding to calls for assistance when on-call or expected to be available.
- Not working collaboratively or cooperatively with others.
- Creating rigid or inflexible barriers to requests for assistance/cooperation.
Retaliatory Behavior: JMH will not tolerate retaliation against employees and professional staff who report suspected violations in good faith. Any person who retaliates is subject to disciplinary action up to and including termination.
Obligation to Report: Any person who learns, knows of, or suspect violations or that someone has violated a state or federal law, or has acted unethically or improperly are/is obligated to report that information to their supervisor, manager or the Compliance Officer. Supervisors are also responsible for ensuring compliance by their staff.
If you are uncomfortable discussing your concerns or feel your concerns are being ignored, call the Integrity Hotline or Corporate Compliance Officer (585-275-1824) to report unethical, illegal or unprofessional conduct
Note: Comments that are or may be perceived as being sexually harassing which are directed at patients may fall under the definition of sexual abuse. Such comments which are directed at non-patients may be professional misconduct.
Jones Memorial Hospital will follow JMH Human Resource policies and procedures, Medical Staff bylaws, rules and regulations and policies and procedures or Board of Director Bylaws as appropriate when corrective/disciplinary action is indicated.
Disciplinary action up to and including suspension, termination and or cancellation of a contract, restriction or non-renewal of privileges may occur.
The establishment and maintenance of control for the patient billing process is the responsibility of the Finance area. Ethical billing practices will be followed at all times as established by the Jones Memorial Hospital Compliance Plan. Revenue producing departments and the patient accounting areas will ensure that the patient bills will only include charges for those services rendered. Staff and resources are available to patients, payors, and service areas to respond to inquiries and to resolve problems.
Commitment to the JMH Community
As a member of the JMH Community with the mutual goal of providing excellent care to our patients, it is expected that all commit to the following:
- Accept responsibility for establishing and maintaining healthy interpersonal relationships with every member of the JMH community.
- Talk directly to the person I am having a problem with. The only time I will discuss it with another person (a manager) is when I need advice or help in deciding how to communicate appropriately.
- Establish and maintain a relationship of functional trust with every other member of this team. My relationships with everyone will be equally respectful, regardless of job titles or levels of educational preparation.
- Not engage in the "3 B's" (bickering, back-biting and blaming). I will practice the "3 C's" (caring, committing and collaborating) in my relationship and ask to be treated the same.
- Not complain about another team member. If I hear someone doing so, I will ask them to speak directly to that person.
- Accept members of the JMH Community as they are today, forgiving past problems and askyou to do the same with me.
- Be committed to finding solutions to problems rather than complaining about them or blaming someone for them.
- Affirm contribution to quality patient care.
- Remember that no one is perfect, and that human errors are opportunities, not for shame or guilt, but for forgiveness and growth.
All members of the JMH Community will be required to sign the attached Commitment to Coworkers statement.
Jones Memorial Hospital Policy for Detection and Prevention of Fraud, Waste and Abuse
JMH employees shall conduct all activities in compliance with applicable laws and regulations, including fraud and abuse laws, self-referral, and anti-kickback prohibitions.
In compliance with the Deficit Reduction Act of 2005, JMH provides detailed information to Affected Individuals on the federal and state False Claims Acts, federal administrative remedies for false claims, New York laws pertaining to civil and criminal penalties for false claims, and whistleblower protections contained in such statutes.
JMH requires employees and agents to report suspicions of fraud, waste, or abuse and educates all employees and agents to enable them to detect, prevent, and report suspected incidents of fraud, waste, and abuse.
JMH prohibits any employee from intentionally or recklessly submitting a claim which includes fraudulent information or is based on fraudulent documentation to any federally funded or state-funded program for payment approval.
A summary of Federal and State False Claim Laws is attached to this Code of Conduct.
Please also refer to JMH Deficit Reduction Act Policy: Fraud, Waste, and Abuse.