2 or more sections of company's code of ethics. Are those sections of the code working well or should be revised? Be specific in your recommendations. Also discuss ways you could "incentivize" the code.
here's code of ethics for hospital:
OUR PRINCPLES OF ETHICAL CONDUCT INCLUDE:
LEGAL & ETHICAL REQUIREMENTS
???? Compliance with applicable laws, rules and regulations governing Lenox Hill Hospital and
???? Adherence to high ethical standards and use of good judgment.
???? Provision of patient care that is medically necessary and appropriate in a respectful and
dignified manner, without regard to race, color, creed, sex, ethnic origin, age, disability,
sexual orientation, source of payment, or other classification prohibited by law.
???? Recognition of the patient’s right to make informed decisions about medical treatment and
advanced directives and respect for patient choice.
???? Responsibility to protect patient privacy and confidentiality.
???? Compliance with laws and regulations relating to the provision of emergency care to patients.
PHYSICIAN AND PROVIDER RELATIONSHIPS
???? Acceptance of patient referrals and referrals of patients without regard to the direct or
indirect payment or receipt of remuneration, based on each patient’s medical need and the
provider’s ability to render the service.
???? Adherence to legal requirements of contractual arrangements or joint ventures with
???? Proper supervision of allied health care professionals and residents and other house staff.
MANAGED CARE RELATIONSHIPS
???? Avoidance of improper financial incentives under managed care contracts that would result
in underutilization of medically necessary services.
???? Truthful, accurate, and legible completion of medical records, billing records, business
records and regulatory and financial reports.
???? Retention, storage and disposal of patient and business records and information in
accordance with legal and business requirements.
PRIVACY AND CONFIDENTIAL INFORMATION
???? Protection and safeguarding of information created in the conduct of Lenox Hill Hospital and
its affiliates business including patient information, staff data, financial data, research data,
strategic plans, statistical information, purchasing agreements and contracts.
???? Protecting and enhancing the rights of patients by providing them access to their information
and controlling the inappropriate use of that information pursuant to the Health Insurance
Portability and Accountability Act of 1996 (HIPAA).
BILLING FOR SERVICES
???? Accurate coding and billing for medical services rendered in accordance with legal
requirements and agreements with third party payors.
???? Compliance with applicable legal, regulatory and program requirements in the preparation
and submission of claims for reimbursement and reports concerning the costs of the hospital
and its affiliates operations.
???? Avoidance of improper waivers and write-offs of patient costs.
???? Selection of supplies, vendors, contractors and consultants based upon fair, competitive
practices and objective factors including quality, price, service and delivery.
???? Avoidance of transactions that excessively benefit private individuals in contravention of
laws and regulations applicable to tax-exempt organizations.
???? Adherence to Lenox Hill Hospital policies on solicitation and acceptance of charitable
???? Compliance with laws respecting the use of intellectual property.
???? Safeguarding of proper internal financial controls in compliance with established accounting
control standards and procedures.
???? Maintain the integrity of the Hospital’s financial statements and its financial reporting
CONFLICTS OF INTEREST
???? Avoidance of situations or conduct that may involve a conflict between personal interests and
the interests of Lenox Hill Hospital and its Affiliates.
???? Observance of laws and regulations relating to reporting, use of grant and private research
funds, audits, informed consent and reimbursement in clinical research.
???? Compliance with IRB policies, procedures and directives.
???? Integrity in the research process, avoidance of conflicts of interest, improper inducements,
and other forms of scientific misconduct.
???? Protection of the privacy of health information of research subjects.
???? Conduct of research in compliance with approved protocols.
???? Fair and respectful treatment of employees, staff and co-workers.
???? Prohibiting discrimination based on race, color, religion, gender, national origin, age,
citizenship status, disability or sexual orientation and prohibiting sexual harassment.
???? Compliance with environmental laws and regulations including the proper storage, handling
and disposal of hazardous material and infectious waste.
???? Proper handling and dispensation of controlled substances in accordance with applicable law.
???? Avoidance of the use of Lenox Hill Hospital and its Affiliates resources to influence the
MARKETING AND ADVERTISING
???? Truthful and accurate marketing and advertising of medical services for educating the public,
reporting to the community and increasing awareness of the Hospital’s mission of the
Hospital and its Affiliates.
???? Compliance with rules applicable to marketing to Medicare and Medicaid beneficiaries.
HOW TO USE THE COMPLIANCE PROGRAM
All employees and staff have a part to play in ensuring that the business of the Hospital and its
affiliates is conducted legally and ethically. All employees and staff are responsible for
performing their assigned duties in accordance with the principles of ethical and legal conduct
and are obligated to report suspected violations of laws, regulations or the Code of Ethics to their
immediate supervisors or the Compliance Officer. The Compliance Officer is responsible for
coordinating the dissemination of information on new laws or regulations that govern the
activities of the Hospital and its affiliates or information related to changes in existing laws or
regulations. All communications will reinforce the employee’s responsibility to comply with
applicable laws and policies and to report a suspected violation to the Compliance Office.
The Compliance Office may be reached 24 hours a day, seven days a week by calling: (212)
434 - 2126. The Hospital and its Affiliates prohibit any retaliation against an employee who, in
good faith, reports a question or concern about a compliance matter.
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