Code of Conduct

Connections affirms the commitment to provide client-friendly, quality behavioral health care in compliance with all federal, state and local laws and regulations governing our operations.  We pledge to do so within the highest moral and ethical standards required by our leadership role.

Connections must provide services and conduct business in a manner that will reflect our values.  To achieve our mission, our conduct must be legal in regard to rules and regulations.  Our conduct in business, marketing, service delivery, professional responsibilities must also be moral and ethical in regard to our obligations to others.

It is an obligation, then, of each Board Member, Employee, Physician, Student, Volunteer, Vendor, and Affiliate to fulfill the mission of Connections by acting in accordance with this Code of Conduct.

It is the responsibility of the leadership of Connections to evidence the values embodied in this Code of Conduct, by personal example, and their management practices.  The following are some of the core principles of the Connections Code of Conduct:

    1. Excellence as the standard of quality for our services;
    2. Honest communications;
    3. Respect for client rights, including confidentiality and privacy;
    4. Fairness in our business dealings including disclosure to address conflicts of interest, and financial management, which is cost-effective;
    5. Equal opportunity and a positive work environment;
    6. Partnership with our clients and families;
    7. Civic duty to comply with federal, state and local laws, rules and regulations;
    8. Zero tolerance of criminal activity, or conspiracy to commit a crime.

Honest Communications.  One of the most important elements of an effective Corporate Compliance Program is an honest communication. 

    1. Marketing efforts shall not mislead the public or misrepresent the Agency as to the types of service available.  Should the client require or request services not available or inconsistent with the Agency mission, referrals will be given to the client for appropriate options.
    2. An integral part of the Compliance Program is the establishment of a mechanism in which employees, volunteers, students, physician, contracted providers, and other stakeholders may, anonymously, if so desired, report violations of the Code of Conduct or other non-compliant activity.  If any person sees or experiences potential misconduct, including inappropriate business practices, the first avenue of reporting should be their Supervisor, Human Resources, or the Corporate Compliance Officer.
    3. It is a violation of the Corporate Compliance Program and this Code of Conduct to initiate or allow any type of retaliation or reprisal against anyone making a good faith report of a concern or potential violation of the Code of Conduct.

Personal and Professional Ethical Standards.  Ethical conduct by all those affiliated with Connections is vital to maintaining an effective Compliance Program.  All members of Connections should adhere to a high level of personal and professional ethical standards.

    1. An Ethics Committee has been established to serve as an advisory body to the Agency’s medical staff, other health care professionals, as well as clients and their families on matters relating to bioethical decisions arising during the provision of client and treatment, as well as organizational ethical issues.
    2. Connections is a non-profit corporation dedicated to the provision of quality health care services.  All members of the Agency must act with loyalty in their conduct for the purpose, benefit and interest of the Agency and those served by its members.  As a result, all employees have a corresponding duty to avoid conflicts of interest with those of the Agency, and may not use their position and affiliation with the organization for their personal benefit.

Respect for Others.  Respect must be demonstrated at all times to our clients, fellow employees and all those that we come in contact with on a daily basis.  Connections is committed to respecting our clients’ privacy and confidentiality through compliance with all related laws and standards, particularly the HIPAA (Health Insurance Portability and Accountability Act of 1996) regulations regarding privacy of protected health information.

    1. Confidentiality of client and employee records is the cornerstone of our Corporate Compliance Program.  For our clients this means that all information collected for the provision of medical care belongs to them.  IT will not be released without their permission, and if released, only according to the applicable laws and regulations.  For our employees this means that all disciplinary activity and compliance issues will remain confidential and restricted to the employee and those members who are directly involved.
    2. Connections is an equal opportunity employer for all persons without regard to race, color, national origin, sex, age, religion, marital status, sexual orientation, veteran status, or handicap, including persons known to have HIV and/or AIDS.  It is also our policy to adhere to all relevant provisions of the Americans with Disabilities Act (ADA).  We will make reasonable accommodations wherever necessary for all employees or applicants with disabilities, provided that the individual is otherwise qualified to safely perform the duties and assignments required, and that the accommodations made to not require unreasonable difficulty or expense.  Additionally, Connections is committed to providing a dignified work environment, free from any form of harassment or discrimination and will thoroughly investigate any alleged instances and take corrective action if warranted.

Compliance with Applicable Laws, Regulations and Other Obligations.  It is the duty of Connections and all of its employees to uphold all relevant Federal, State and local laws, rules and regulations.  Each employee must develop an awareness of the impact of legal requirements and restrictions on their position and duties.

    1. Any questions about legality or ethical nature of any actions by or on behalf of Connections should be referred to the appropriate supervisory or management representatives.  If there is a continued uncertainty after an internal review, then an employee has the right to contact the CCO.
    2. Connections shall work to ensure a workplace which conforms to all laws and regulations regarding occupational health and safety.  Connections is committed to proper maintenance of the environment, and all medical waste, hazardous materials, and other products shall be utilized and disposed of in an manner that conforms to all applicable environmental laws and regulations.

Excellence as the Standard for the Quality of our Services.  Connections is one of the leaders in Community Mental Health Care and has the duty to put forth their best effort in providing excellent services.  We take pride in our work and expect service excellence.

    1. Contracted providers or vendors of health care or related services must meet quality and ethical standards established by Connections and follow this code of conduct.

Highest Level of Cost-Effective Client Care.  To maintain our role as leaders, our services must be reasonable, necessary and medically appropriate for the care of each client.  To that end, it must be provided by properly qualified caregivers who share our values.  That care must also be cost effective and affordable by the communities that we serve.  Clinical decisions will be based on identified client health care needs and not solely on financial issues.

    1. Admission, discharge and transfer policies will be in compliance with all applicable laws and regulations and will not be solely based on client or Agency economics.
    2. Unless requested by the client, only clients whose specific condition cannot be at Connections will be referred to another Agency.
    3. All employees and agents of Connections, both clinical and non-clinical staff, shall support Connections in the establishment and maintenance of medical records and other documents which conform to legal, professional and ethical standards.  Connections shall also ensure that claims submitted for payment or reimbursement for services will only be for such care that is provided by properly qualified persons and that such care is billed accurately and documented.
    4. Clients or other payors who have questions about their bill for services will be provided an opportunity to discuss charges and resolve disputes without real or perceived harassment.
    5. All client care and its corresponding records must be completed to meet the standards of documentation as required by laws and regulations, payor requirements, and professional standards.  Connections and all of its members will take affirmative steps necessary to protect the confidentiality of those records.

The Code of Conduct was prepared for the benefit of Connections, its members and affiliates, as well as their employees and all other members of our community.  The Code is a dynamic document, which shall develop through time with the efforts and contributions of all employees.  Each of the following issues shall be considered in connection with the Code of Conduct and its application to the daily activities of Connections.

    1. The Code of Conduct is in addition to, and not instead of, specific policies and procedures of Connections for each clinical discipline Code of Ethics.  It shall remain the duty of each employee to perform their respective duties in accordance with those policies and procedures.
    2. The Code of Conduct is an evolving document, and all employees are encouraged to suggest changes or additions to the Code of Conduct for the benefit of Connections and its employees.
    3. It is the duty of each employee within Connections to uphold the standard set forth in the Code of Conduct and to report violations through procedures outlined in the Corporate Compliance Plan.
    4. Disciplinary action for violations of the Code of Conduct and the Compliance Plan shall be enforced through the disciplinary policies of each member on a case-by-case basis, and may include termination.  If Connections determines that such a violation has included criminal violation of law or regulation, Connections will cooperate with appropriate law enforcement authorities in connection with the investigation and prosecution of the offender.

 

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