Code of Conduct
Utopia Home Care, Inc. (the agency) takes health care fraud and abuse very seriously. It is our policy to provide information to all our employees, contractors and agents about the Federal False Claims Act and the steps Utopia has in place to detect and prevent health care fraud and abuse.
Utopia relies upon its directors, officers and employees to comply with all state and federal health care fraud, waste and abuse laws. In the Corporate Compliance Code of Conduct you will find clearly defined policies and procedures designed to prevent, deter and detect criminal and suspicious activity within the company.
The following is an abbreviated version of Utopia Home Care’s Corporate Compliance Code of Conduct. The entire Code and the Corporate Compliance Program Manual is available for your review, upon request, at each branch office.
Compliance can be described as conducting a business or oneself in an ethical, moral, and legal manner. All Utopia employees must comply with all federal, state and local laws, and government regulations related to the company’s business and must report to Utopia’s Compliance Officer any actual violation or anything thought to be a violation of the Code of Conduct, the Compliance program, or the False Claims Act. In addition, all employees must comply with company policies and procedures including Patients’ Rights and all policies governing patient care.
The company will maintain an open line of communication between the compliance officer and all employees. Individuals are encouraged not to guess whether certain conduct is proper or improper bur rather are encouraged to ask the compliance officer when there is any confusion or question.
No retaliation of any kind will ever be taken against an employee who, in good faith, reports an actual or suspected violation of fraud, waste, and / or abuse. All information can be submitted anonymously and confidentiality will be maintained at all times.
Fraud is defined as knowingly making false statements or false representations of material facts to obtain some benefit or payment. Fraud can also be committed by withholding important information that should be made known. Fraud by an officer or employee of the company is strictly prohibited. The federal government has enacted criminal and civil laws pertaining to the submission of false or fraudulent claims for payment and has the authority to investigate and prosecute potentially fraudulent activities.
Examples of Fraud:
- Falsifying a patient’s signature.
- Submitting claims for services not rendered.
- Submitting duplicate claims.
- Submitting false annual cost reports to Medicaid.
To avoid allegations of fraud:
- Clinical and financial information must be completed accurately and submitted in a timely manner.
- Always tell the truth.
- Do not omit any material facts.
Offering, promising, giving, or soliciting anything of value to a public or corporate official is strictly prohibited.
The giving, receiving or offering of payment, services or anything of value in exchange for or to induce referrals of patients is strictly prohibited.
OBSTRUCTION OF JUSTICE
Any conduct that obstructs or impedes the administration of justice is prohibited.
Example: Destroying, hiding or altering records during an investigation.
PATIENT ABUSE / EXPLOITATION
Any conduct that could be construed as patient abuse, neglect or exploitation is strictly prohibited and will be subject to being disciplined by Utopia and / or the appropriate authorities.
CONFIDENTIALITY OF PATIENT INFORMATION
All Utopia employees shall protect the rights of the patients and the confidentiality of patient clinical information and records. Routine quality assurance audits of clinical records will be conducted on an ongoing basis to determine compliance with state and federal laws and regulations.
Utopia Home Care will not discriminate in its employment or patient care practices on the basis of age, ethnicity, gender, marital status, veteran status, disability / medical condition, race, religion, sexual orientation or national origin.
CONFLICT OF INTEREST
A conflict of interest is any business, financial, or personal activity that might affect an employee’s responsibilities to Utopia Home Care.
REFRAINING FROM SUBSTANCE ABUSE
The use and abuse of controlled substances and the abuse of alcohol are strictly prohibited. The agency has the right under federal law to request random drug / alcohol testing of any employee where “reasonable suspicion” of drug / alcohol use exists either on the job or affecting job performance. If the employee refuses testing or treatment the agency has the right to terminate employment.
BILLING AND REIMBURSEMENT
All billing and reimbursement practices will be accurate and comply with all laws and regulations. Routine audits of the billing and payroll practices will be conducted on an ongoing basis by the agency staff and at least annually by an outside auditor.
MAKING A REPORT
Reports of misconduct can be made orally or in writing to the Compliance Officer.
Via Phone - (203) 466-3050
Utopia Home Care, Inc.
Attn: Corporate Compliance Officer
444 Foxon Road
East Haven, CT 06513
Copies of the Compliance Program Report Form are also available at your branch office. All employees are encouraged to seek the assistance of the Compliance Officer when questions or concerns arise related to compliance issues.
All credible reports of Utopia policies or state or federal laws and regulations will be fully investigated. The results of the investigation will be reported to the Board of Directors and all reports will be maintained in a secure location in the corporate office.
If a violation of the compliance program is confirmed, the company will take steps to stop and/or correct the defective practice or procedure as soon as is reasonably possible. Self-reporting to any appropriate authorities will be done and appropriate disciplinary action of the person(s) will be implemented.
Violation of the Compliance Program will result in disciplinary action up to and including termination. Notification to the appropriate authorities may also be necessary. The extent of the discipline will be determined on a case-by-case basis by the Board of Directors.