Social Media When your social media content or public statements reflect an affiliation with Cape Cod Healthcare (CCHC), you must not: • Post harassing, defamatory or discriminatory comments about co-workers or colleagues. • Reference any CCHC patient or patient condition. • Imply that you are authorized to speak on behalf of CCHC (all statements must be personal). • Share CCHC confidential or proprietary information. • Publish false or misleading content about CCHC, its executives, employees, physicians, patients or services. • Use CCHC logos, trademarks or images of its facilities, employees, or representatives. Skilled Nursing • As a Medicaid-participating skilled nursing facility, the JML Care Center must comply with the federal Nursing Home Reform Act (NHRA) , which estab- lishes standards for resident quality of life, required services, management of personal funds and other resident rights. These requirements are enforced by both the state Medicaid agency and the federal government. • Any deficiencies related to NHRA compliance should be reported promptly to the Chief Compliance Officer or JML’s Executive Director so corrective action can be taken. JML and CCHC are committed to strict com- pliance with all state and federal licensing requirements and to maintaining the dignity of every patient. • Effective June 14, 2012 , JML implemented its own Corporate Compliance and Ethics Program to prevent and detect criminal, civil and administrative violations and to promote quality care for residents and families. This program supplements and aligns with CCHC’s Code of Conduct. More information is available from JML’s Executive Director or Chief Compliance Officer.
Clinical Laboratory
Documentation (Proper recording) Cape Cod Healthcare (CCHC) requires strict compliance with generally accepted accounting principles and established internal controls in recording all assets and transactions. • No Undisclosed Funds or Assets: Secret or unrecorded accounts are prohibited. • Honest and Accurate Reporting: All transactions—including payments, expense accounts, time records, and reimbursement requests—must be recorded truthfully, timely and completely. False or misleading entries are strictly forbidden. • Supporting Documentation: Payments on CCHC’s behalf must be supported by adequate documentation and used only for the purposes reflected in that documentation. • Prohibited Practices: Employees and providers may not engage in undisclosed or unrecorded transactions, falsify or conceal information, create false documents, or participate in bribes, kickbacks or political contributions on CCHC’s behalf. • Accountability: Failure to promptly report violations of these standards to the Chief Compliance Officer may result in disci- plinary action, up to and including termination. Political Contributions • Cape Cod Healthcare (CCHC) conducts all fundraising through the Cape Cod Healthcare Foundation (“the Foundation”). The Foundation is responsible for complying with all state and federal registration, record-keeping and reporting requirements. • All solicitations of charitable contributions for CCHC must be carried out under the Foundation’s supervision and direction. No employee, physician or other individual is authorized to use CCHC’s name in fundraising activities unless the Foundation has provided prior approval. • It is strictly prohibited for any employee or representative to make false, deceptive or misleading statements in connection with fundraising or the sale of goods or services benefiting CCHC. In addition, federal law generally prohibits the use or disclosure of patient Protected Health Information (PHI) for fundraising purposes without the patient’s written authorization. Employees must consult with CCHC’s Privacy Officer before initiating any fundraising activities that could involve PHI.
• In October 1998, Cape Cod Healthcare (CCHC) established a service-line specific compliance program for its clinical laboratory services (“C-Lab”). The program was created to ensure the quality of C-Lab’s services and to prevent and detect illegal or unethical activities involving patients, customers and referring physicians. • The C-Lab compliance program is designed to supplement and remain consistent with CCHC’s overall Code of Conduct. More information about the program is available from C-Lab’s Compliance Officer.
Assets and Resources
• CCHC’s materials, supplies, facilities and equipment must be used solely for CCHC business purposes. Employees may not use CCHC resources—including the internal email system—for personal convenience or profit during work time. • All staff are expected to comply with CCHC’s policies on social media use during work hours. Use of CCHC assets for any unlawful or improper purpose is strictly prohibited. • Bribes, kickbacks or similar payments or remunera- tion may never be offered or accepted in connection with CCHC business.
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