These standards apply to the agency’s staff, leadership, caregivers, and other personnel according to their roles. They summarize the agency’s existing compliance manual; employees and contractors must also follow the complete policies applicable to their work.
Accurate records and billing
Prepare visit verification, timesheets, payroll records, and other documentation honestly and accurately. Records and claims must reflect the services actually ordered and provided. Follow the required record-management, correction, and retention processes.
Confidentiality and information security
Protect patient, personal, employee, and proprietary information. Use and disclose information only as authorized or permitted by law, safeguard documents and devices, and protect access credentials. These duties continue after employment and do not restrict legally protected reporting.
Conflicts of interest
Avoid and disclose actual or potential conflicts between personal interests and agency responsibilities. Follow Heritage’s disclosure requirements and maintain appropriate boundaries in outside employment and dealings with patients and families.
Gifts and professional boundaries
Maintain professional relationships. Follow agency gift restrictions; do not solicit gifts, borrow money from patients or their families, or sell them goods. Agency gift limits do not create an exception to applicable law or payer rules.
No bribery or kickbacks
Do not give or receive something of value to improperly influence business, referrals, or decisions. Raise questionable financial arrangements with the Compliance Officer.
Reporting and cooperation
Promptly raise suspected unethical, improper, or illegal conduct through the compliance reporting routes. Seek guidance when unsure, participate in applicable compliance training, and cooperate truthfully with authorized investigations.
Protection from retaliation
Heritage prohibits intimidation or retaliation for good-faith compliance reports. Concerns may be reported to government agencies as well as through Heritage’s internal routes.
Reporting routes and protectionsFor the complete applicable policies, interpretation of a standard, or further guidance, contact Heritage’s Compliance Officer through 718-750-3550.
Source text from Heritage’s manual
This excerpt reproduces the five conduct-standard sections from the existing agency manual. Source wording is preserved; repeated page headers and line wrapping were cleaned. It is not verification of the complete, currently approved Code of Conduct.
Read all five source sections
Accuracy And Management Of Records
All employees of Heritage Homecare Services must accurately prepare and submit Electronic Visit Verification data, manual vouchers, payroll sheets and all other documentation, including business records. The obligation as an employee of Heritage Homecare Services is to ensure compliance with laws and policies requiring honest, accurate documentation and records management. All records will be retained for a protracted time period, as defined in the regulations.
Confidentiality
An important principle of our work at Heritage Homecare Services is the protection of a client's right to privacy. All information, including medical and personal information, is confidential. This means that employees do not talk about our clients to others. This includes our families, friends, neighbors, coworkers or strangers. It doesn't matter how the employee came to know the information; the employee does not share the information with anyone outside of the organization unless authorized to do so. Heritage Homecare Services always maintains a “privacy culture” within the organization. There are laws prohibiting the disclosure of confidential client information and special laws about the disclosure of HIV-related client information. Documents containing sensitive data are handled properly during work hours and properly secured at the end of the business day. Computer terminals containing confidential information should not be left unattended or "on" for any extended period. Screensavers are used to facilitate this compliance. Computer security is enforced in relation to passwords and allowing other staff members to use other employees’ terminals. Computers are turned off at the end of the business day. Fax documents shall be safeguarded, and all fax machines will be secure within the business site. Heritage Homecare Services personnel may have access to information that the organization considers "proprietary" (that Heritage Homecare Services owns) and confidential. This may include and not be limited to computer software, forms, financial information, employee information, and other confidential matters. Upon employment with Heritage Homecare Services employees are required to protect such information to the best of his/her ability. This will continue even after the employee leaves the Agency.
Conflict Of Interest
A conflict of interest is defined as a situation that presents an actual or potential problem between the interest of the employee and that of Heritage Homecare Services. Employees of Heritage Homecare Services must avoid a conflict of interest or the appearance of having engaged in a conflict of interest. You may not become involved in any business, commercial activity or behavior with the patient, their family or friends, even if the patient, their family or friend wishes you to do so. Additionally, any outside employment or interests with a designated competitor may result in a conflict of interest. Conflict of Interest Forms will be signed by each employee at the beginning of employment and at the beginning of every year. All involvement in any organization by each employee must be disclosed.
Receiving And Giving Gifts
Professional relationships with clients, their family and friends must be maintained at all times. For the employee's protection and for the protection of the client, no employee may neither give nor accept gifts of any kind from clients, their family or friends except for gifts of an inconsequential monetary value of less than $10.00. Receipt of gifts and entertainment may present potential conflicts of interest. Should this occur, the employee will courteously explain that they may not accept any gifts. Additionally, no employee of Heritage Homecare Services may sell anything to clients, their family or friends. Borrowing money from clients, their family or friends is prohibited and creates a serious conflict of interest.
Bribery And Kickbacks
Heritage Homecare Services employees are strictly prohibited from engaging in bribery or kickbacks. These are situations where an individual gives or receives something of value for the purpose of influencing the outcome of a decision. Engaging in these activities may violate federal, state or local laws and regulations. Heritage Homecare Services will assist in prosecuting any individual violating this standard to the fullest extent of the law.
Agency gift limits are not legal exemptions. Confidentiality obligations do not prevent legally protected reporting. Contact the Compliance Officer for the current complete policies.