The purpose of having a Corporate Compliance Plan is to reduce the likelihood of unwanted events and to reduce the likelihood that an unwanted event creates legal liability. This code of conduct provides the fundamental principles that can serve as a guide to all Affected Individuals when conducting work on behalf of IDCC (“IDCC” or “the Agency”). This Compliance Plan will help IDCC monitor each department, monitor personnel, and identify issues that require corrective action. This Compliance Plan will be publicized and made available on IDCC’s website.
As an integral member of IDCC’s team, employees are expected to accept certain responsibilities, adhere to acceptable business principles in matters of personal and professional conduct, and exhibit a high degree of personal integrity at all times. This not only involves sincere respect for the rights and feelings of others but also demands that both in an employee’s business and in their personal life they refrain from any behavior that might be harmful to themselves, their coworkers, and/or the Agency, or that might be viewed unfavorably by current or potential clients or by the public at large.
Whether employees are on or off duty, their conduct is a reflection of IDCC. They are, consequently, encouraged to observe the highest standards of professionalism at all times.
Listed below are some of the rules and regulations of the Agency. This list should not be viewed as being all-inclusive. Types of behavior and conduct that IDCC considers inappropriate and which could lead to disciplinary action up to and including immediate termination of employment without prior warning, at the sole discretion of the Agency, include but are not limited to, the following:
- Falsifying employment or other Agency records, including, but not limited to, billing documentation, progress notes and contact records;
- Knowingly presenting or causing to be presented a false or fraudulent claim to the Federal or State government for payment;
- Knowingly making, using, or causing to be made or used, a false statement to get a false or fraudulent claim paid by the Federal or State government;
- Improper or fraudulent billing for health care services;
- The preparation of inaccurate or incomplete cost reports;
- The payment or receipt of kickbacks in return for client referrals;
- The misuse of Agency funds;
- Inaccurate documentation;
- Violating the Agency’s nondiscrimination and/or sexual harassment policy;
- Soliciting or accepting gratuities from customers or clients;
- Establishing a pattern of excessive absenteeism or tardiness;
- Engaging in excessive, unnecessary, or unauthorized use of the Agency’s supplies, particularly for personal purposes;
- Reporting to work intoxicated or under the influence of nonprescribed drugs;
- Illegally manufacturing, possessing, using, selling, distributing, or transporting drugs;
- Bringing or using alcoholic beverages on the Agency’s property or using alcoholic beverages while engaged in the Agency’s business off Agency premises, except where authorized;
- Fighting or using obscene, abusive, or threatening language or gestures;
- Stealing property from coworkers, customers, or clients of the Agency;
- Having unauthorized firearms on Agency premises or while on Agency business;
- Disregarding safety or security regulations;
- Engaging in insubordination;
- Failing to maintain the privacy and security of the Agency, customer, or client information;
- There shall be no use of corporal punishment upon patients or clients;
- Engaging in any activity that constitutes abuse of patients or clients as defined in state and federal regulations;
- Modeling inappropriate or unacceptable behavior to a client;
- Failing to maintain patient and client information as confidential and failing to utilize such information in a professional manner at all times. To the extent employees or volunteers obtain HIV related information concerning a patient or client, such information shall be maintained in confidence as required by applicable law;
- Failing to maintain a patient’s or client’s mental health information as required by applicable law;
- Clients shall not carry out the duties of employees unless such tasks are described in their plan of service by their planning team for the purpose of increasing their skills;
- There shall be no personal financial transactions between employees, volunteers, and clients, unless with the express written authorization of the Corporate Compliance Officer; and
- There shall be no smoking in or on IDCC Agency program sites unless there is a specific designated area for such.
If an employee’s performance, work habits, overall attitude, conduct, or demeanor becomes unsatisfactory in the judgment of the Agency, based on violations either of the above or of any other Agency policies, procedures, rules, or regulations, the employee will be subject to disciplinary action, up to and including termination.
It is an expected and good practice, when one is comfortable with it and thinks it is appropriate under the circumstances, for concerns to be raised first with a supervisor or other supervisory staff. If this is not a comfortable or viable option, employees have the option to contact the Corporate Compliance Hotline at 347-909-2717 where reports may be made confidentially and anonymously.