It is the duty of Affected Individuals to uphold all applicable laws and regulations. All Affected Individuals must be aware of the legal requirements and restrictions applicable to their respective positions and duties. The Agency shall implement programs necessary to further awareness of and to monitor and promote compliance with laws and regulations. Questions about the legality or propriety of any actions undertaken by or on behalf of the Agency should be referred immediately to the Corporate Compliance Officer for clarification.
Affected Individuals shall conduct all activities in accordance with the highest ethical standards of the community and their respective professions at all times and in a manner that upholds the reputation and standing of the Agency. Affected Individuals shall not make false or misleading statements to any client, person, or entity doing business with the Agency.
All Affected Individuals must faithfully conduct their duties in their assigned roles solely for the purpose, benefit, and interest of the Agency and those whom it serves. All Workforce Members and Board members have a duty to avoid conflicts with the interests of the Agency and may not use their positions and affiliations with the Agency for personal benefit. Workforce Members and Board members must consider and avoid not only actual conflicts but also the appearance of conflicts of interest.
See Policy 10: Conflict of Interest Policy
All Affected Individuals must support the Agency’s mission to ensure services are provided in a manner that meets the needs of those served. The services provided by those associated or affiliated with the Agency must be reasonable and necessary to the care of each individual and appropriate to the situation, and such care must be provided by properly qualified individuals. All such care must be properly documented as required by law and regulation, payor requirements, and professional standards.
The Agency is committed to ensuring services are provided for persons, without regard to age, race, color, ethnicity, religion, gender, gender identification, and sexual orientation. We are dedicated to maintaining an environment that respects the dignity of each individual in our organization. Discrimination in any form or context will not be tolerated.
Affected Individuals may have access to sensitive data and proprietary information, depending on access levels, the confidentiality of which must be protected. This information should be shared within Greater New York Nursing Services, only as appropriate, to ensure the optimum care and as provided in established policies regarding matters such as medical records, quality assurance, risk management, utilization review, and administrative functions. All such persons must adhere to the appropriate laws, regulations, policies, and procedures to ensure that confidential information is properly maintained and that inappropriate or unauthorized release is prevented. Affected Individuals, as appropriate, shall create and keep records and documentation which conform to legal, professional, and ethical standards. Workforce Members must sign the Employee Handbook upon hire which includes a section related to confidentiality. Additionally, Greater New York Nursing Services maintains a separate and distinct HIPAA Privacy and Security Policy for Affected Individuals to reference.
The policies and procedures relating to conflicts of interest include, but are not limited to, the following:
Affected Individuals shall ensure that: all requests for payment for all services are appropriately authorized, reasonable, medically necessary, and appropriate; provided by properly qualified persons; and billed in the correct amount with appropriate supportive documentation. Greater New York Nursing Services and Affected Individuals will also ensure compliance with all managed care contracting requirements.
All business practices of the Agency must be conducted with honesty and integrity and in a manner that promotes a positive and professional reputation with clients, payors, vendors, regulatory agencies, and other providers.
All affected individuals shall refrain from conduct, which may violate the fraud and abuse laws. These laws prohibit (1) direct, indirect or disguised payments in exchange for the referral of patients; (2) the submission of false, fraudulent or misleading claims to any government entity or third-party payor, including claims for services not rendered, claims which characterize the service differently than the service rendered or claims which do not otherwise comply with applicable program or contractual requirements; and (3) making false representations to any person or entity in order to gain or retain participation in a program or to obtain payment or excessive payment for any service.
All affected individuals must accurately and honestly represent the organization and should not engage in any activity or scheme intended to defraud anyone of money, property, or honest services.
All financial reports, accounting records, research reports, expense accounts, time sheets, and other documents must accurately and clearly represent the relevant facts or the true nature of a transaction. Improper or fraudulent accounting, documentation, or financial reporting is not only contrary to organization policy, it may be in violation of applicable laws. Sufficient and competent evidential matter or documentation shall support all cost reports.
The organization will make available to employees, assets and equipment necessary to conduct organization business including such items as computer hardware and software, billing and medical records, both hardcopy and in electronic format, fax machines, office supplies, and various types of equipment. Employees should strive to use organizational assets prudently and effectively. The organization’s property should not be used for personal reasons or be removed without approval from a departmental manager. An employee who believes that any medical equipment is not operating properly or has an inaccurate calibration should immediately report the problem to his or her supervisor.
The organization will not engage in anticompetitive conduct that could produce an unreasonable restraint of trade or a substantial lessening of competition. Evaluation of anti-competitive conduct requires legal guidance. Communication by employees with competitors about matters that could be perceived to have the effect of lessening competition or could be considered as collusion or an attempt to fix prices should take place only after consultation with legal counsel.
All affected individuals shall not offer any financial inducement, gift, payoff, kickback, or bribe intended to induce, influence, or reward favorable decisions of any government personnel or representative, any customer, contractor, or vendor in a commercial transaction or any person in a position to benefit the organization or the employee in any way. Employees are strictly prohibited from engaging in any corrupt business practice either directly or indirectly. No employee shall make or offer to make any payment or provide any other thing of value to another person with the understanding or intention that such payment or other thing of value is to be used for an unlawful or improper purpose. Appropriate commissions, rebates, discounts, and allowances are customary and acceptable business inducements provided that they are approved by the Administration and that they do not constitute illegal or unethical payments. Any such payments must be reasonable in value, competitively justified, properly documented, and made to the business entity to which the original agreement or invoice was made or issued. Such payments should not be made to individual employees or agents of business entities.
It is particularly important that coding, billing, and submission of claims to Medicaid and other third-party payers, be appropriate, accurate, and in compliance with applicable laws and regulations. Standards relating to billing will be found in a later section of this Program. These Standards of Conduct apply to all employees, including supervisors, managers, directors, and Administrators. They also apply to temporary and contract employees and where practical to independent contractors doing business with the organization and to physicians. These Standards are not intended to cover every situation which may be encountered and employees should comply with all applicable laws and regulations whether or not specifically addressed in the Standards.
Bills for federally funded health care programs, as well as to other payors, must be true, accurate, and complete and for services believed to be medically necessary, and that were ordered by a physician or other appropriately licensed person. All professional services should be documented timely, correctly, and properly. Patient records and other documentation that support the bills should also be true, accurate, and complete in accordance with professional standards and available for audit and review.
The following should not occur:
Training, education, and documents necessary for accurate code assignment is and will continue to be made available to employees involved in coding. Billing department coders and billing consultants will not be provided any financial incentive to improperly upcode claims or otherwise improperly increase revenue.
To report a compliance issue please contact our confidential compliance hotline at: 718 581 5347
Form 1095-C for an eligible employee may be requested from the company by emailing HR@gnyservices.com, call 212-687-7464 or requesting a copy in person at our main address of 6424 18th Avenue Brooklyn NY 11204. It shall be furnished to the employee within 30 days of the request.
