Emergency Services and Patient Transfers Cape Cod Healthcare (CCHC) provides emergency care to all individuals, regardless of ability to pay, at Cape Cod Hospital and Falmouth Hospital. Medical Screening & Care • Every patient must receive a prompt medical screening exam. • Emergency care cannot be delayed to assess insurance or financial status. • Patients with emergency medical conditions—including active labor, psychiatric disturbances or acute substance use—must be treated until stabilized. Transfers • Transfers of unstable patients are permitted only if a physician certifies the benefits outweigh the risks, the receiving hospital is qualified and has agreed to accept, and appropriate space is available. • Prior to transfer, necessary treatment must be provided to minimize risks, including care for pregnant individuals and unborn children. • Transfers must be performed by qualified personnel with appropriate transportation, life support measures and complete medical records sent to the receiving facility. Reporting Requirements • Suspected inappropriate transfers must be reported immediately to a supervisor, the Chief Compliance Officer or the Chief Medical Officer. • Receiving hospitals must report suspected violations within 72 hours. • On-call physicians who fail to appear in a timely manner to provide stabilizing treatment must also be reported.
Conflict of Interest
Confidential Information
CCHC employees and physicians must always act in the best interests of the organization, our patients and our mission—not for personal gain. Employees Employees (including employed physicians) must avoid interests, influences, or relationships that conflict—or appear to conflict—with CCHC’s best interests. This applies to their own interests, those of immediate family members and anyone acting on their behalf. Examples of potential conflicts include: • Employment, directorship or ownership in a CCHC competitor, supplier or payor • Consulting relationships with competitors, suppliers or payors • Outside business activities that compete with CCHC • Significant outside activities that impair job performance • Supervising or evaluating a close relative, significant other or household member Any such relationships or activities must be disclosed in writing to a supervisor or manager. When in doubt, consult the Compliance Officer or disclose the interest. Employed Physicians Physicians must also avoid interests or relationships that conflict— or appear to conflict —with CCHC’s best interests, including those of immediate family members. Examples include: • Employment, directorship or ownership in a competi- tor, supplier or payor • Consulting relationships with competitors, suppliers or payors • Outside activities that could inappropriately affect— or appear to affect — responsibilities at CCHC Such relationships or activities must be disclosed in writing to the Chief Compliance Officer. When uncer- tain, physicians should consult the Chief Compliance Officer or err on the side of disclosure.
Cape Cod Healthcare (CCHC) requires all employees, medical staff and representatives to safeguard Confidential Information at all times. Confidential Information includes non-public business, financial, patient, fundraising and marketing information, as well as personnel records, salary and benefit data, and patient-specific information. These obligations continue even after your relationship with CCHC ends. General Obligations • Do not disclose Confidential Information outside CCHC without written authorization. • Use Confidential Information only for legitimate CCHC business purposes, never for personal gain. • Avoid discussing Confidential Information in public or with unauthorized individuals (including family or friends). • Protect confidential and proprietary information provided by third parties (vendors, partners) with the same care. Patient Information • CCHC is committed to protecting patient privacy under HIPAA , the HITECH Act and applicable state and federal laws. • Employees, medical staff and business associates must comply with CCHC’s privacy and security policies and the standards in its Notice of Privacy Practices . • Medical records and Protected Health Information (PHI) must only be accessed, used or disclosed as permitted by law and policy. • Any suspected data breach or unauthorized disclosure of PHI must be reported immediately to the Chief Compliance Officer , Privacy Officer or Chief Legal Officer . • All personnel are required to cooperate fully in investi- gations of such matters.
9 | Cape Cod Healthcare
Code of Conduct | 10
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