Gifts, Favors and Entertainment Employees and representatives of Cape Cod Healthcare (CCHC) must not accept anything of value from individuals or organizations doing business with CCHC—or whose services are subject to CCHC’s review—if the gift or favor is, or could appear to be, offered in exchange for favorable treatment.
Government Investigation Cape Cod Healthcare (CCHC) will cooperate fully with government investigations, but all cooperation must be coordinated through appropriate CCHC representatives and legal counsel. Government inquiries often arise from complaints that agencies are legally obligated to investigate. While the government has the right to conduct investigations, CCHC has the right to insist that they be carried out in an orderly, proper and lawful manner. If you are contacted in connection with an investigation, you should: • Confirm the investigator’s identification and obtain a business card. • Determine the general subject of the inquiry without providing details, documents or data. • Immediately contact CCHC’s Chief Legal Officer, who is available 24/7 through the Cape Cod Hospital operator, to determine next steps. The following is a list of some of the state and federal agencies that might be involved in an investigation at CCHC: • United States Department of Justice (DOJ) • United States Department of Health and Human Services (HHS) • Federal Bureau of Investigation (FBI)
• Nominal Items Only : Acceptable items of nominal value include pens, notepads, mugs or similar promotional items generally priced under $100. • Meals and Entertainment: May be accepted only if unsolicited, infrequent, reasonable in scope and cost and directly connected to legitimate business discussions. • Travel and Lodging: Reimbursement or compli- mentary lodging/travel requires advance written approval from your supervisor or manager. Discounts or promotional premiums available to the general public (not specific to CCHC employees) may be accepted. Fundraising • Cape Cod Healthcare (CCHC) conducts all fund- raising 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 super- vision 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.
• When in Doubt: If accepting a gift or favor could cause embarrassment to you or CCHC if publicly disclosed, decline it and consult your supervisor or the Chief Compliance Officer. • Bribes and Kickbacks: Offers of money or anything of value that could be viewed as a bribe or kickback must be refused and promptly reported to the Chief Compliance Officer.
• Massachusetts Board of Registration in Medicine • Massachusetts Department of Public Health (DPH) • Office for Civil Rights (OCR) • United States Department of Labor (DOL) • Medicare Administrative Contractors/DMERCs (MACs) • Massachusetts Medicaid Fraud Control Unit (MFCU) • United States Attorney’s Office (USAO) • Massachusetts Board of Registration in Nursing
• HHS Office of the Inspector General (OIG) • Occupational Safety and Health Administration (OSHA) • United States Coast Guard • Drug Enforcement Administration (DEA) • Massachusetts Attorney General’s Office
• It is strictly prohibited for any employee or representa- tive 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.
• You are not obligated to speak with investigators if you choose not to, and you are entitled to have representation present. CCHC will arrange for the Chief Legal Officer or another appropriate representative to attend any interview or meeting at no cost to you, even if you are no longer employed by CCHC. • Under no circumstances should you destroy, alter or falsify records; provide misleading information or attempt to influence others to do so. Such actions may result in civil or criminal penalties for both CCHC and individuals involved. • If employees, physicians, suppliers or members of the press inquire about an investigation, do not discuss the matter. All press inquiries must be referred to the Chief Legal Officer, and the only appropriate response is to direct questions to that office. • Finally, nothing in this Code of Conduct prevents you from communicating directly with government authorities to make a good faith report of suspected violations of law or regulation, or from testifying or participating in legal proceedings related to such matters.
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