Code of Conduct
PEMA is committed to providing high quality pediatric healthcare services in an ethical and fiscally responsible manner. PEMA Team Members, including PEMA’s agents, contractors, and vendors, are expected to act in an ethical manner consistent with the principles outlined in this Code of Conduct, PEMA’s Compliance Program, PEMA’s policies and procedures, the policies and procedures of each facility staffed by PEMA, and all applicable laws and regulations. Failure to comply will result in disciplinary action, including oral or written warnings or reprimands, suspensions, terminations, and financial penalties.
All PEMA Team Members are required to report violations or concerns about violations of this Code of Conduct to our Compliance Officer, who will review and handle the matter in a discreet and appropriate manner. PEMA Team Members are assured that no retaliation will occur as a result of an individual sharing concerns with our Compliance Officer. You may reach our Compliance Officer via email at: firstname.lastname@example.org
Compliance with Laws, Regulation and Contract
PEMA is committed to conducting all its activities in compliance with applicable laws, regulations and contractual obligations. PEMA requires that all employees, providers and representatives comply fully with all applicable laws, regulations and other contractual obligations. If there is any doubt as to whether an activity is legal or proper, the individual must contact PEMA’s Compliance Officer.
PEMA is committed to the highest standards of business ethics and integrity. PEMA will fairly and accurately represent itself in all business relationships and will not engage in any activity or scheme intended to defraud anyone of money, property or honest services. PEMA’s Compliance Program and related policies and procedures help ensure that the business activities reflect these high standards.
Fraud, Waste and Abuse
PEMA investigates and reports any potential and real fraudulent activity. Fraudulent activity is deliberate deceptive behavior in order to secure unlawful or unfair gain. PEMA expects its employees, vendors and related entities to refrain from conduct that may violate the fraud and abuse laws.
Any questions related to a billing practice or the legitimacy of a transaction with which PEMA or its Team Members are associated should contact the Compliance Officer who will review all concerns and handle appropriately.
Privacy, Security and Confidentiality of Information
Employees, providers and representatives of PEMA will protect all confidential information received consistent with applicable legal and ethical standards. PEMA will comply with applicable Federal and State laws protecting the privacy and security of patient health information. All employees must comply with PEMA’s Privacy and Security Policies and Procedures
PEMA Team Members are expected to respect the proprietary and confidential information of the Company and others. Such information can include written materials, software and other “intellectual property.”
PEMA Team Members are responsible for ensuring they do not improperly copy or use documents, materials or any applications or programs in violation of applicable copyright laws or licensing agreements.
As healthcare providers, we have an ethical responsibility to make our patients feel secure in our care and to treat patients, and their families, respectfully and with dignity. In addition to an ethical responsibility, we have a legal responsibility to comply with all applicable laws and regulations related to patients’ rights, including those specific policies and expectations established by each facility staffed by PEMA.
Conflicts of Interest
Employees, providers and representative of PEMA are expected to conduct their activities to avoid actual or perceived conflict of interest. A conflict of interest arises when an individual’s own interests influences or appears to influence decisions regarding PEMA. This would include any conflicts of interest between a PEMA Member and any facility.
If a conflict of interest exists, it must be fully disclosed and appropriate action taken consistent with the organization’s policies.
An employee’s personal, social, or other activities or relationships which have the potential to interfere with the employee’s loyalty to PEMA or objectivity in doing business may be a potential for conflict. Your obligation to conduct company business in an honest and ethical manner includes the appropriate handling of actual and apparent conflicts of interest. This sometimes requires that conflicts be avoided altogether, and it always requires full disclosure of any actual or apparent conflicts of interest. It is your responsibility to ensure that you remain free of conflicts of interests in the performance of your role at PEMA. While not all situations cause a conflict, you must obtain the approval of management before taking on a position within an organization which may present a conflict.
As employees of PEMA, we make decisions that affect the Company based on the company’s best interest—independent of personal or other outside influences. We must never use our positions to profit personally or to assist others in profiting in any way at the expense of the organization. Upon new hire and annually thereafter, all PEMA employees must evaluate their relationship and dealings and determine whether a potential conflict may exist and advise the Compliance Officer of any such potential conflict of interest. However, conflicts of interest can be, and should be, reported at any time they are identified.
Protection of Company Assets
PEMA must preserve and protect its assets by promoting the efficient and effective use of its resources. PEMA must use its assets to further its legitimate business activities. Corporate assets to be protected include property, equipment, computers, company records, software, information and telecommunications systems, furniture and supplies.
Corporate assets also include intellectual property such as facility agreements, financial documents, business plans and other proprietary information of PEMA, information related to any of its subsidiary entities, its arrangements or agreements with employees or contractors, and any other company information.
All PEMA Members will report any situation that could lead to loss, misuse or theft of Company assets to a member of management or the Compliance Officer.
PEMA will not knowingly employ or contract with any individual, person or entity, who has been convicted of a criminal offense related to health care or who is listed by a Federal or State agency as debarred, excluded or otherwise ineligible for participation in a government funded health care program. The Compliance Officer will ensure PEMA routinely checks the OIG’s List of Excluded Individuals/Entities to ensure that potential and existing employees, providers, contractors, consultants and any other person or entity with which PEMA may enter into a relationship have not been excluded from participating in federal programs. Employees and contracts will be terminated if an individual or a company with which PEMA does business has been excluded.
PEMA and its Team Members do not offer or accept inducement, bribes or kickbacks. These can be money, gifts, or special treatment given to someone in exchange for a favor. The favor may be many things, from a promise to make patient referrals to a promise to use a particular vendor’s product.
PEMA and its Team Members also do not offer or accept “something of value” for patient referrals. “Something of value” includes money, services, gifts, entertainment, or anything else of value to the recipient.
As this is a highly complex area of the law, employees must take special care and promptly refer any questions to the Compliance Officer.
Fair Business Dealings
PEMA is committed to achieving its success by fair and ethical means. PEMA prohibits any unethical, non-competitive and illegal business practices. In addition, PEMA will deal fairly with its members, providers, and other business associates. PEMA will not take unfair advantage of anyone through manipulation or concealment of information, abuse of confidential information, misrepresentation of facts or any other unfair business practice.
PEMA selects contractors, suppliers, and vendors based on quality, price, delivery, technical and service excellence. Selections are not made based on personal or self-serving relationships but rather based on the needs of the organization. PEMA will employ those with high ethical standards in business practices.
Every employee is responsible for ensuring that all documentation, including patient records, charting for coding and billing for services, accounting records, expense accounts, time sheets and other documents are accurate and clearly represent the relevant facts or the true nature of a transaction. Employees should never make false or misleading entries in reports or other records. Business records will be kept in an accurate, true and complete manner, in accordance with all PEMA Policies and Procedures. If someone becomes aware of inaccuracies, s/he should immediately notify a member of management so that the error can be corrected. If problems with documentation for claims are found and not corrected, the PEMA Team Member should contact the Compliance Officer.
PEMA is a culturally diverse organization and it believes that the fair and equitable treatment of employees, patients and staff within the facilities we support is critical to fulfilling its vision and goals. PEMA will treat everyone with dignity and respect regardless of race, color, creed, religion, sex, national origin, disability, marital status, age, sexual orientation, or financial status. PEMA will conduct its employment practices free from discrimination.
Harassment and Workplace Violence
PEMA employees have the right to work in an environment free of hostility and harassment. PEMA will not tolerate any conduct that is disrespectful, hostile, intimidating, threatening, belittling or harassing.
Employees who observe or experience any of these types of inappropriate conduct should report the incident to a member of management or the Compliance Officer. PEMA maintains a zero tolerance to these types of behavior.
Document, Code and Bill Appropriately
PEMA handles claims for payment of services with integrity to avoid fraud, waste and abuse in healthcare. Everyone within PEMA is expected to comply with federal healthcare program requirements, including, but not limited to, Medicare/Medicaid rules and federal and state False Claims Acts.
PEMA will bill only for medically necessary services rendered by eligible providers and properly documented and coded. Medical necessity requires us to be prudent in the utilization of our resources, being mindful not to over utilize or underutilize the services provided to our patients.
Management will respond to patient and payer questions concerning charges in an accurate and timely manner. Billing errors, of which management becomes aware, will be corrected and the Company will refund payments received in error to third party payers and patients, with appropriate documentation.
PEMA will train its Team Members to provide care to patients, and document, code and bill with accuracy and in compliance with all applicable billing rules and guidelines.
Under no circumstances will retaliatory actions be taken against any employee or other person making a report of suspected misconduct to the Compliance Officer, a member of management, Human Resources or the Practice Manager. Employees are protected from retaliation by Federal law. However, in no circumstance will protection or immunity from disciplinary action or prosecution to those employees who have engaged in misconduct be provided merely because the employee or individual reported the misconduct. PEMA will rigorously enforce this no retaliation policy.