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COMPREHENSIVE HEALTH SYSTEMS, INC.Ethical Codes of Conduct
As adopted by the Board of Directors on August 9, 2001And modified as approved by the Board of Directors in January 2024
PURPOSE:
These Ethical Codes of Conduct have been adopted by Comprehensive Health Systems, Inc. (CHS) to provide standards by which employees (including contractors, other providers, and vendors) of the Center will conduct themselves in order to protect and promote organization-wide integrity. These Codes are critical components of our overall Corporate Compliance Program. We have developed these Codes to ensure we meet our ethical standards and comply with applicable laws and regulations.
INTRODUCTION:
Statement of Policy: The Ethical Codes of Conduct sets forth the policy of Comprehensive Health Systems, Inc, which states that all employees and affiliated professional staff will comply fully with all state and federal laws and will conduct themselves in accord with the highest ethical standards. Employees and affiliated professional staff, and where appropriate, contractors and other agents are expected to abide by this Code of Conduct and related Policies and Procedures.
Staff working for Comprehensive Health Systems, Inc. who fail to provide services to people professionally, ethically, and legally will be subject to discipline, which may include termination of employment. Any person who learns of or suspects that someone has violated a state or federal law, or has acted unethically or improperly, should report that information to the Chief Executive Officer and/or Corporate Compliance Officer. Supervisors are charged with the responsibility of ensuring compliance by their staff.
In addition to the standards listed below, all employees and subcontractors for Comprehensive Health Systems, Inc. must adhere to anti-kickback and referral statutes, the False Claims Act as well as Anti-Stark Laws. STANDARDS:
Business–
The business conducted by Comprehensive Health Systems, Inc. will be delivered in an environment with the highest ethical, legal and professional standards. Honesty, integrity and impartiality will be demonstrated when dealing with CHS customers, providers, vendors, regulators, competitors, community and employees. The Governing Board, employees, and contract providers will make every effort to avoid even the appearance of illegal, unethical or unprofessional conduct.
It is against the law and the policy of Comprehensive Health Systems, Inc. to knowingly submit false claims for payment. Submitting a false claim might be using the wrong billing codes, falsifying the medical record, or billing for services that were not provided or are not medically necessary. Violations of these laws can be punished by fines, prison or both. Providers can also be excluded from the Medicare or Medicaid program for submitting false claims. CHS policy is to bill accurately and only for medically necessary services that are provided and documented. Any subcontractors that perform billing services must ensure compliance with billing requirements as well.
We will operate oversight systems designed to verify claims are submitted only for services actually provided and services are billed as provided. These systems will emphasize the critical nature of complete and accurate documentation of services provided. As part of our documentation effort, we will maintain current and accurate medical records.
All consumer information (including medical records) must be kept strictly confidential and not released to anyone outside the Center without written patient consent or lawful court order. Exceptions to this are noted in the Policy and Procedure manual regarding Confidentiality. All personnel must avoid discussing confidential information with outsiders, or where others, including family, can overhear them. Internal access to medical records is not appropriate unless there is a legitimate, work-related need to see the information. All staff will make every effort to comply with HIPAA regulations as outlined in CHS policy, and in the Standards for Privacy of Individually Identifiable Health Information (45 CFR Parts 160 and 164).
Marketing –
A. Marketing strategies are developed at each program site in order to ensure that services are offered to individuals within the community. These strategies are discussed in Quality Assurance Committees and Management Team Meetings.
B. The Chief Executive Officer and Qualified Mental Health Professionals will actively speak to members of the community in each county CHS is responsible to serve. Contact will be made with potential referral sources, potential consumers, and other stakeholders.
C. CHS will use brochures, community fairs (job fairs, Project Community Connect, etc.) news releases, and public presentations in our efforts to make our services known.
D. Community contacts with individuals, groups, and committees, whether one time or on an ongoing basis, will be recognized as contributing to the outreach of CHS.
E. CHS maintains a website in order to make its services and information about the organization known to the public. The website is: www.chsservices.net . Policy and Procedure Handbook AS113.00
Contractual Relationships-
Contracted employees will be required to sign and abide by the CHS Ethical Codes of Conduct and follow the professional Codes for their specific professions. CHS is committed to maintaining strong and positive working relationships with contracted employees who practice within the organization. Employees will not offer or provide contracted employees with any benefits, compensation or other inducements in exchange for the referral of consumers. CHS will not enter into financial relationships with contracted employees which could place CHS in a position of violating the prohibitions of the federal Anti-Fraud and Abuse Statute or any other related laws.
Conflicts of Interest –
All personnel associated with Comprehensive Health Systems, Inc. should avoid conflicts of interest and situations that even look like a conflict of interest. This means that personnel should not benefit from doing business with CHS, should not have independent relationships with those who deal with CHS, should not use their employer's property for their personal benefit and should not compete with Comprehensive Health Systems, Inc. Any potential for conflict of interest should be disclosed to your supervisor.
Social Media –
Comprehensive Health Systems, Inc. recognizes that employees may use social networking websites or similar media including, but not limited to, blogs, forums, personal websites, photo sharing, and social networking sites, such as Facebook, X (Twitter), Instagram, etc. CHS respects the rights of employees to use social networking websites as a medium of self-expression and public conversation and does not discriminate against employees who use these mediums for personal interest, affiliations, or other lawful purposes. Regardless of an employee’s choice to identify themselves as a CHS employee, the employee should understand that they may be viewed as a spokesperson for the company by anyone who connects the employee with Comprehensive Health Systems. Employees are expected to refrain from presenting the company in a negative manner when using social media websites for any purpose. The full social media policy can be located in the Policy and Procedure Handbook HR405.00.
Service Delivery-
The following are guidelines for compliance with the Ethical Codes of Conduct: A. Employees (and contract providers) are committed to complying with all federal and state laws and regulations with an emphasis on preventing fraud and abuse.
B. Comprehensive Health Systems, Inc. will conduct audits and other risk evaluations to monitor compliance and assist in the reduction of identified problem areas
C. Comprehensive Health Systems, Inc. will maintain processes to: a. Detect Medicaid/Medicare or other third-party payer compliance offenses b. Initiate corrective and preventive action c. Report to appropriate oversight authorities, both professional and regulatory, when appropriate, and d. Address consequences for employees (and contract providers) for failure to comply with standards, policies, and procedures.
Exchange of Gifts, Money, and Gratuities –
Gifts of entertainment from vendors should be limited to common business courtesies which may include an occasional lunch or dinner or gift of limited value. Monetary gifts or any favors in attempt to gain unfair influence or advantage are never acceptable. Conversely, employees should not seek to gain influence or advantage of a customer, potential customer or business by providing inappropriate gifts or entertainment. Any gift should be limited in value and consistent with common business courtesies. Giving monetary gifts is never acceptable.
Personal Fundraising-
Only fundraisers for not-for-profit organizations, such as schools and nationally recognized charities are allowed on CHS property.
Personal Property-
The organization's physical properties, information, and influence are not to be used for the private advantage of any employee or other person. This includes private correspondence under the entertainment of the organization's name. All personnel shall respect and safeguard the personal property of the consumers, visitors, and other personnel as well as the property of CHS. Employees will not use or allow the use of CHS property or equipment for anything other than activities approved by the organization. Theft and destruction of property may be addressed through treatment planning (consumers), disciplinary action (personnel), and/or by contacting law enforcement, as appropriate. CHS is not responsible for personal property that is not safeguarded or is left unattended.
Setting Boundaries-
Comprehensive Health Systems, Inc. is committed to always setting and maintaining a high standard of professional conduct for its staff. The staff are responsible for maintaining professional boundaries in their day-to-day work with consumers. Professional boundaries enable staff and consumers to engage safely and effectively in a therapeutic relationship. Employees have a duty of care to treat consumers with respect and provide patient-centered support that meets their needs without judgment or bias. Staff must always remember that professional boundaries require the recognition of potential conflicts, risks and complexities of providing care to consumers. Employees must raise any concerns or training needs with their supervisor immediately. Setting boundaries also includes relations with consumers and former consumers.
Staff/Consumer/Former Consumer Relations-
1. Staff shall maintain an objective professional relationship with consumers at all times. NOTE: All sections included under staff/consumer relations pertain to both persons currently receiving services and those who have received services in the past (former consumers).
2. Staff are aware of their influential position with respect to consumers, and they should avoid exploiting the trust and dependency of such persons. Staff, therefore, will make every effort to avoid dual relationships with consumers that could impair professional judgment or increase the risk of exploitation. When a dual relationship cannot be avoided, staff should take appropriate professional precautions to ensure judgment is not impaired and no exploitation occurs. Examples of such dual relationships include, but are not limited to, business or close personal relationships with consumers.
3. Sexual intimacy with consumers is prohibited (Sexual intimacy with former consumers is prohibited for two years following the termination of therapy). Employees should avoid placing themselves in a vulnerable position such as, entering a room alone with a consumer and not leaving the door open.
4. Staff may not disclose consumer confidences except: (a) as mandated by law; (b) to prevent a clear and immediate danger to a person or persons; (c) where the therapist is a defendant in a civil, criminal, or disciplinary action related to therapy (in which case consumer confidences may be disclosed only in the course of that action); (d) if there is a waiver previously obtained in writing, then such information may be revealed only in accordance with the terms of the waiver. In circumstances where more than one person in a family receives therapy, each such family member who is legally competent to execute a waiver must agree to the waiver required by subparagraph (C). Without a waiver from each family member legally competent to execute such waiver, a therapist cannot disclose information received from any family member.
Witnessing and signing of Legal Documents-
Staff is authorized to witness Release of Information forms and official Comprehensive Health Systems and Missouri Department of Mental Health forms only without the approval of their supervisor.
Professional Responsibilities-
Reporting Violations- In the event you have information about unethical or illegal conduct, you must report this information to the Chief Executive Officer or Corporate Compliance Officer, either by verbal report or through using a Quality Improvement Form. You do not have to leave your name, although you may if you wish. Employees may be required to substantiate any allegations of wrongdoing. Comprehensive Health Systems, Inc. will make every effort to maintain, within limits of the law, confidentiality of the identity of any individual who reports possible misconduct.
Comprehensive Health Systems, Inc. will not tolerate retaliation against staff who reports suspected violations in good faith. Any person who attempts to retaliate will be subject to discipline, up to and including termination.
Human Resources- A. Familiarize employees, agents, or contractors with the ethical codes of conduct and incorporate them into orientation materials. Insure each new employee is given a written copy of this policy.
B. Insure each new employee is given the opportunity to review other specific policies relevant to employment. After reviewing these documents, insure every new employee signs an acknowledgement sheet and employee orientation checklist form indicating their understanding.
C. Maintain any corrective/disciplinary actions that were a result of an investigation in the individual’s personnel file.
D. Schedule training for leaders, supervisors and managers. Provide training or information on an ongoing basis for employees, agents, or contractors.
Prohibition-
Comprehensive Health Systems, Inc. is committed to the prohibition of, deterrence, detection, and elimination of fraud, waste, abuse and other wrongdoing. Each employee of CHS and its stakeholder’s share in this responsibility and has a duty to conserve and to restrict the use of CHS’ resources and property to activities and conduct that comply with this policy. This policy applies to any fraud or suspected fraud, waste, abuse or wrongdoing involving CHS property, resources, employees, consumers, vendors, contractors, consultants, or stakeholders associated with Comprehensive Health Systems, Inc. Individuals or entities shall not perpetrate, engage in, or otherwise facilitate any act or attempted act of fraud, waste, or abuse. All employees, consumers, and affiliates are responsible for reporting suspected or known violations of this policy. CHS will investigate allegations of fraud, waste, or abuse in accordance with established policies and procedures. Definitions: 1. Fraud is defined as a false representation of a matter of fact that is intended to deprive CHS of property or legal right to property. Fraud is also a willful or deliberate act or failure to act with the intention of obtaining an unauthorized benefit, such as money or property, by deception or other unethical means. A fraudulent act may be illegal, unethical, improper, or dishonesty. Other examples may include: (charging personal expenses as business expenses against a CHS account, using petty cash for personal reasons, using a company credit card or other sources of CHS funding for personal use, charging inflated labor costs or hours, or inaccurate time reporting).2. Waste means the expenditure or allocation of resources in excess of need that is often extravagant or careless. Waste is also the thoughtless or careless expenditure, consumption, mismanagement, use, or squandering of resources owned or operated by CHS. 3. Abuse means the intentional, wrongful, or improper use of resources. Abuse can be a form of wastefulness as it entails the exploitation of “loopholes” to the limits of the law, primarily but not always for personal advantage or for the advantage of an individual or entity with which the responsible individual has a personal or professional relationship, including but not limited to a familial relationship. Abuse also means extravagant or excessive use as to abuse one’s position or authority. 4. Wrongdoing means any action or behavior that is morally or legally wrong or a departure from what is ethically acceptable. Employees, consumers, and other individuals associated with CHS who become aware of, or have a reasonable basis for believing that fraud, waste, or abuse has occurred shall promptly report the suspected activity. Reports can be made to the CEO or Corporate Compliance Officer. A CHS employee engaging in any of the prohibited activities as defined above may be subject to disciplinary action up to and including termination. If the violation is identified as a potential crime, it will be reported to the appropriate law enforcement organization. Criminal investigations will be conducted separately from any internal investigation. Information obtained by the internal investigation may be made available to law enforcement to assist in the criminal investigation.
CONCLUSION:
Each employee of Comprehensive Health Systems, Inc. is responsible to act in accordance with the policies as set forth in this document and otherwise. Each employee is expected to maintain the highest standards of business ethics. This includes taking positive action to prevent or correct any improper or inappropriate acts. Violating these policies or failing to report violations could subject an employee to disciplinary action, up to and including termination.
Comprehensive Health Systems’ Board of Directors and Management are committed to providing avenues through which ethical issues may be raised, reviewed and resolved openly and honestly.
Comprehensive Health Systems, Inc., is committed to actively informing the community in which our services are available about what we do and who we serve.
As adopted by the Board of Directors on August 9, 2001And modified as approved by the Board of Directors in January 2024
PURPOSE:
These Ethical Codes of Conduct have been adopted by Comprehensive Health Systems, Inc. (CHS) to provide standards by which employees (including contractors, other providers, and vendors) of the Center will conduct themselves in order to protect and promote organization-wide integrity. These Codes are critical components of our overall Corporate Compliance Program. We have developed these Codes to ensure we meet our ethical standards and comply with applicable laws and regulations.
INTRODUCTION:
Statement of Policy: The Ethical Codes of Conduct sets forth the policy of Comprehensive Health Systems, Inc, which states that all employees and affiliated professional staff will comply fully with all state and federal laws and will conduct themselves in accord with the highest ethical standards. Employees and affiliated professional staff, and where appropriate, contractors and other agents are expected to abide by this Code of Conduct and related Policies and Procedures.
Staff working for Comprehensive Health Systems, Inc. who fail to provide services to people professionally, ethically, and legally will be subject to discipline, which may include termination of employment. Any person who learns of or suspects that someone has violated a state or federal law, or has acted unethically or improperly, should report that information to the Chief Executive Officer and/or Corporate Compliance Officer. Supervisors are charged with the responsibility of ensuring compliance by their staff.
In addition to the standards listed below, all employees and subcontractors for Comprehensive Health Systems, Inc. must adhere to anti-kickback and referral statutes, the False Claims Act as well as Anti-Stark Laws. STANDARDS:
Business–
The business conducted by Comprehensive Health Systems, Inc. will be delivered in an environment with the highest ethical, legal and professional standards. Honesty, integrity and impartiality will be demonstrated when dealing with CHS customers, providers, vendors, regulators, competitors, community and employees. The Governing Board, employees, and contract providers will make every effort to avoid even the appearance of illegal, unethical or unprofessional conduct.
It is against the law and the policy of Comprehensive Health Systems, Inc. to knowingly submit false claims for payment. Submitting a false claim might be using the wrong billing codes, falsifying the medical record, or billing for services that were not provided or are not medically necessary. Violations of these laws can be punished by fines, prison or both. Providers can also be excluded from the Medicare or Medicaid program for submitting false claims. CHS policy is to bill accurately and only for medically necessary services that are provided and documented. Any subcontractors that perform billing services must ensure compliance with billing requirements as well.
We will operate oversight systems designed to verify claims are submitted only for services actually provided and services are billed as provided. These systems will emphasize the critical nature of complete and accurate documentation of services provided. As part of our documentation effort, we will maintain current and accurate medical records.
All consumer information (including medical records) must be kept strictly confidential and not released to anyone outside the Center without written patient consent or lawful court order. Exceptions to this are noted in the Policy and Procedure manual regarding Confidentiality. All personnel must avoid discussing confidential information with outsiders, or where others, including family, can overhear them. Internal access to medical records is not appropriate unless there is a legitimate, work-related need to see the information. All staff will make every effort to comply with HIPAA regulations as outlined in CHS policy, and in the Standards for Privacy of Individually Identifiable Health Information (45 CFR Parts 160 and 164).
Marketing –
A. Marketing strategies are developed at each program site in order to ensure that services are offered to individuals within the community. These strategies are discussed in Quality Assurance Committees and Management Team Meetings.
B. The Chief Executive Officer and Qualified Mental Health Professionals will actively speak to members of the community in each county CHS is responsible to serve. Contact will be made with potential referral sources, potential consumers, and other stakeholders.
C. CHS will use brochures, community fairs (job fairs, Project Community Connect, etc.) news releases, and public presentations in our efforts to make our services known.
D. Community contacts with individuals, groups, and committees, whether one time or on an ongoing basis, will be recognized as contributing to the outreach of CHS.
E. CHS maintains a website in order to make its services and information about the organization known to the public. The website is: www.chsservices.net . Policy and Procedure Handbook AS113.00
Contractual Relationships-
Contracted employees will be required to sign and abide by the CHS Ethical Codes of Conduct and follow the professional Codes for their specific professions. CHS is committed to maintaining strong and positive working relationships with contracted employees who practice within the organization. Employees will not offer or provide contracted employees with any benefits, compensation or other inducements in exchange for the referral of consumers. CHS will not enter into financial relationships with contracted employees which could place CHS in a position of violating the prohibitions of the federal Anti-Fraud and Abuse Statute or any other related laws.
Conflicts of Interest –
All personnel associated with Comprehensive Health Systems, Inc. should avoid conflicts of interest and situations that even look like a conflict of interest. This means that personnel should not benefit from doing business with CHS, should not have independent relationships with those who deal with CHS, should not use their employer's property for their personal benefit and should not compete with Comprehensive Health Systems, Inc. Any potential for conflict of interest should be disclosed to your supervisor.
Social Media –
Comprehensive Health Systems, Inc. recognizes that employees may use social networking websites or similar media including, but not limited to, blogs, forums, personal websites, photo sharing, and social networking sites, such as Facebook, X (Twitter), Instagram, etc. CHS respects the rights of employees to use social networking websites as a medium of self-expression and public conversation and does not discriminate against employees who use these mediums for personal interest, affiliations, or other lawful purposes. Regardless of an employee’s choice to identify themselves as a CHS employee, the employee should understand that they may be viewed as a spokesperson for the company by anyone who connects the employee with Comprehensive Health Systems. Employees are expected to refrain from presenting the company in a negative manner when using social media websites for any purpose. The full social media policy can be located in the Policy and Procedure Handbook HR405.00.
Service Delivery-
The following are guidelines for compliance with the Ethical Codes of Conduct: A. Employees (and contract providers) are committed to complying with all federal and state laws and regulations with an emphasis on preventing fraud and abuse.
B. Comprehensive Health Systems, Inc. will conduct audits and other risk evaluations to monitor compliance and assist in the reduction of identified problem areas
C. Comprehensive Health Systems, Inc. will maintain processes to: a. Detect Medicaid/Medicare or other third-party payer compliance offenses b. Initiate corrective and preventive action c. Report to appropriate oversight authorities, both professional and regulatory, when appropriate, and d. Address consequences for employees (and contract providers) for failure to comply with standards, policies, and procedures.
Exchange of Gifts, Money, and Gratuities –
Gifts of entertainment from vendors should be limited to common business courtesies which may include an occasional lunch or dinner or gift of limited value. Monetary gifts or any favors in attempt to gain unfair influence or advantage are never acceptable. Conversely, employees should not seek to gain influence or advantage of a customer, potential customer or business by providing inappropriate gifts or entertainment. Any gift should be limited in value and consistent with common business courtesies. Giving monetary gifts is never acceptable.
Personal Fundraising-
Only fundraisers for not-for-profit organizations, such as schools and nationally recognized charities are allowed on CHS property.
Personal Property-
The organization's physical properties, information, and influence are not to be used for the private advantage of any employee or other person. This includes private correspondence under the entertainment of the organization's name. All personnel shall respect and safeguard the personal property of the consumers, visitors, and other personnel as well as the property of CHS. Employees will not use or allow the use of CHS property or equipment for anything other than activities approved by the organization. Theft and destruction of property may be addressed through treatment planning (consumers), disciplinary action (personnel), and/or by contacting law enforcement, as appropriate. CHS is not responsible for personal property that is not safeguarded or is left unattended.
Setting Boundaries-
Comprehensive Health Systems, Inc. is committed to always setting and maintaining a high standard of professional conduct for its staff. The staff are responsible for maintaining professional boundaries in their day-to-day work with consumers. Professional boundaries enable staff and consumers to engage safely and effectively in a therapeutic relationship. Employees have a duty of care to treat consumers with respect and provide patient-centered support that meets their needs without judgment or bias. Staff must always remember that professional boundaries require the recognition of potential conflicts, risks and complexities of providing care to consumers. Employees must raise any concerns or training needs with their supervisor immediately. Setting boundaries also includes relations with consumers and former consumers.
Staff/Consumer/Former Consumer Relations-
1. Staff shall maintain an objective professional relationship with consumers at all times. NOTE: All sections included under staff/consumer relations pertain to both persons currently receiving services and those who have received services in the past (former consumers).
2. Staff are aware of their influential position with respect to consumers, and they should avoid exploiting the trust and dependency of such persons. Staff, therefore, will make every effort to avoid dual relationships with consumers that could impair professional judgment or increase the risk of exploitation. When a dual relationship cannot be avoided, staff should take appropriate professional precautions to ensure judgment is not impaired and no exploitation occurs. Examples of such dual relationships include, but are not limited to, business or close personal relationships with consumers.
3. Sexual intimacy with consumers is prohibited (Sexual intimacy with former consumers is prohibited for two years following the termination of therapy). Employees should avoid placing themselves in a vulnerable position such as, entering a room alone with a consumer and not leaving the door open.
4. Staff may not disclose consumer confidences except: (a) as mandated by law; (b) to prevent a clear and immediate danger to a person or persons; (c) where the therapist is a defendant in a civil, criminal, or disciplinary action related to therapy (in which case consumer confidences may be disclosed only in the course of that action); (d) if there is a waiver previously obtained in writing, then such information may be revealed only in accordance with the terms of the waiver. In circumstances where more than one person in a family receives therapy, each such family member who is legally competent to execute a waiver must agree to the waiver required by subparagraph (C). Without a waiver from each family member legally competent to execute such waiver, a therapist cannot disclose information received from any family member.
Witnessing and signing of Legal Documents-
Staff is authorized to witness Release of Information forms and official Comprehensive Health Systems and Missouri Department of Mental Health forms only without the approval of their supervisor.
Professional Responsibilities-
Reporting Violations- In the event you have information about unethical or illegal conduct, you must report this information to the Chief Executive Officer or Corporate Compliance Officer, either by verbal report or through using a Quality Improvement Form. You do not have to leave your name, although you may if you wish. Employees may be required to substantiate any allegations of wrongdoing. Comprehensive Health Systems, Inc. will make every effort to maintain, within limits of the law, confidentiality of the identity of any individual who reports possible misconduct.
Comprehensive Health Systems, Inc. will not tolerate retaliation against staff who reports suspected violations in good faith. Any person who attempts to retaliate will be subject to discipline, up to and including termination.
Human Resources- A. Familiarize employees, agents, or contractors with the ethical codes of conduct and incorporate them into orientation materials. Insure each new employee is given a written copy of this policy.
B. Insure each new employee is given the opportunity to review other specific policies relevant to employment. After reviewing these documents, insure every new employee signs an acknowledgement sheet and employee orientation checklist form indicating their understanding.
C. Maintain any corrective/disciplinary actions that were a result of an investigation in the individual’s personnel file.
D. Schedule training for leaders, supervisors and managers. Provide training or information on an ongoing basis for employees, agents, or contractors.
Prohibition-
Comprehensive Health Systems, Inc. is committed to the prohibition of, deterrence, detection, and elimination of fraud, waste, abuse and other wrongdoing. Each employee of CHS and its stakeholder’s share in this responsibility and has a duty to conserve and to restrict the use of CHS’ resources and property to activities and conduct that comply with this policy. This policy applies to any fraud or suspected fraud, waste, abuse or wrongdoing involving CHS property, resources, employees, consumers, vendors, contractors, consultants, or stakeholders associated with Comprehensive Health Systems, Inc. Individuals or entities shall not perpetrate, engage in, or otherwise facilitate any act or attempted act of fraud, waste, or abuse. All employees, consumers, and affiliates are responsible for reporting suspected or known violations of this policy. CHS will investigate allegations of fraud, waste, or abuse in accordance with established policies and procedures. Definitions: 1. Fraud is defined as a false representation of a matter of fact that is intended to deprive CHS of property or legal right to property. Fraud is also a willful or deliberate act or failure to act with the intention of obtaining an unauthorized benefit, such as money or property, by deception or other unethical means. A fraudulent act may be illegal, unethical, improper, or dishonesty. Other examples may include: (charging personal expenses as business expenses against a CHS account, using petty cash for personal reasons, using a company credit card or other sources of CHS funding for personal use, charging inflated labor costs or hours, or inaccurate time reporting).2. Waste means the expenditure or allocation of resources in excess of need that is often extravagant or careless. Waste is also the thoughtless or careless expenditure, consumption, mismanagement, use, or squandering of resources owned or operated by CHS. 3. Abuse means the intentional, wrongful, or improper use of resources. Abuse can be a form of wastefulness as it entails the exploitation of “loopholes” to the limits of the law, primarily but not always for personal advantage or for the advantage of an individual or entity with which the responsible individual has a personal or professional relationship, including but not limited to a familial relationship. Abuse also means extravagant or excessive use as to abuse one’s position or authority. 4. Wrongdoing means any action or behavior that is morally or legally wrong or a departure from what is ethically acceptable. Employees, consumers, and other individuals associated with CHS who become aware of, or have a reasonable basis for believing that fraud, waste, or abuse has occurred shall promptly report the suspected activity. Reports can be made to the CEO or Corporate Compliance Officer. A CHS employee engaging in any of the prohibited activities as defined above may be subject to disciplinary action up to and including termination. If the violation is identified as a potential crime, it will be reported to the appropriate law enforcement organization. Criminal investigations will be conducted separately from any internal investigation. Information obtained by the internal investigation may be made available to law enforcement to assist in the criminal investigation.
CONCLUSION:
Each employee of Comprehensive Health Systems, Inc. is responsible to act in accordance with the policies as set forth in this document and otherwise. Each employee is expected to maintain the highest standards of business ethics. This includes taking positive action to prevent or correct any improper or inappropriate acts. Violating these policies or failing to report violations could subject an employee to disciplinary action, up to and including termination.
Comprehensive Health Systems’ Board of Directors and Management are committed to providing avenues through which ethical issues may be raised, reviewed and resolved openly and honestly.
Comprehensive Health Systems, Inc., is committed to actively informing the community in which our services are available about what we do and who we serve.