Code of Ethics

PURPOSE: All employees, contractors and  advisors meet the highest standards of legal and ethical conduct.

POLICY:

  1. This policy and procedure for Organizational Ethics Statement and Code of Conduct is a part of our Corporate Compliance Program and establishes the general procedures with which all employees and contractors must comply as a condition of employment with this organization in order to ensure that their conduct conforms to the highest ethical standards and is in accordance with all applicable laws, rules and regulations.               
  2. This policy and procedure is not meant to cover all situations. Any doubts whatsoever as the propriety of a particular situation, whether or not the situation is described within this policy and procedure should be submitted by the employee either to immediate supervisor or the General Manager, or the Corporate Compliance Officer.
  3.  We are dedicated to the principle that all patients (regardless of ability to pay), employees, physicians and visitors deserve to be treated with dignity, respect, and courtesy.  This organization will constantly strive to adhere to these principles.
  4.  Any employee violating any provision of this policy and procedure will be subject to disciplinary action, up to and including discharge from employment.  In addition, promotion of and adherence to this policy and procedure and to the Corporate Compliance Program will be one criteria used in evaluating the performance of supervisors. 
  5.  In the event of inconsistency between this and any other policy and procedure statement, this statement shall govern.

PROCEDURE:

  1. RESPECT FOR PATIENT:
    1. Patients (or their legal representatives) will be involved in decisions regarding the service/equipment  we deliver to the extent that such is practical and possible.
    2. We will seek to inform all patients about risks associated with the service/equipment.
    3. In all circumstances, we will attempt to serve patients in manner giving reasonable thought to their background, culture, religion, and heritage.
    4. All employees shall comply with all standards set forth in the Policy for Patient’s Rights and Responsibilities.
  2. RESOLUTION OF CONFLICTS:    
    1. Occasional conflict will arise among those who participate in organization and patient decisions.  We will seek to resolve all conflicts fairly and objectively.
    2. In cases where mutual satisfaction cannot be achieved, the General Manager will be involved to oversee resolution of the conflict.
  3. AVOIDING ABUSE OF TRUST:
    1. We expect employees to avoid engaging in any activity that might interfere or appear to interfere with the independent exercise of the employee’s judgment.
    2. To avoid even the appearance of conflict of interest, employees shall not accept any gifts or promotional items whose value is in excess of $50.  If a gift is received which is valued in excess of $50, it must be reported to and approved by the General Manager.
    3. Under no circumstances should an employee accept money from a patient other than for payment of an invoice or as a gratuity, not to exceed $25.00.
    4. Under no circumstances should an employee engage in work for the patient on a private basis.
  4.  RESOLUTION OF POTENTIAL CONFLICTS OF INTEREST:
    We request disclosure of potential conflict of interest so that appropriate action may be taken to ensure that important decisions are not inappropriately influenced.
  5. FAIR BILLING PRACTICES:
    1. We are committed to ensuring that our billing and reimbursement practices comply with all federal and state laws, regulations, guidelines and policies and that all bills are accurate and reflect current payment methodologies.
    2. We are committed to full disclosure of all reimbursement issues to our patients including informing patients of price (except as may be denied by contract) or reimbursement changes, 30 days prior to date of proposed change.
    3. We are committed to ensuring that all patients and customers receive timely bills and that all questions regarding billing are answered.
  6.  ANTI-KICKBACK:
    Federal and state laws prohibit the organization and its employees from offering a kickback and/or financial incentive to an entity or person to induce the customer or potential customer to purchase services.
  7. CONFIDENTIALITY:
    1. We maintain patient, employee and other information in a confidential manner. Employees must strictly safeguard all confidential information with which they      are entrusted and shall never discuss such information outside the normal and necessary course of this organizations business.
    2. Employees have an obligation to respect and protect the confidential nature of records regarding drug abuse, alcoholism or alcohol abuse and other personal information of other employees.
  8. COMPLIANCE WITH ALL LAWS AND REGULATIONS:
    All employees must comply with all federal, state and local laws and government regulations as applicable, including: local and state licensure, professional licensure/certification, practice standards, the Americans with Disabilities Act (ADA), Equal Employment Opportunities Act (EEOC), Fair Labor Standards act, Title VI of the Civil Rights Act of 1964, Occupational Safety and Health Standards (OSHA), Medicare Regulations/Conditions of Participation, Medicaid Regulations, Public Health Regulations, Food and Drug Administration (FDA), Drug Enforcement Agency (DEA), Department of Transportation (DOT), Department of Agriculture (DOA), Compressed Gas Association (CGA), National Fire Protection Agency (NFPA), Board of Pharmacy, Omnibus Budget Reconciliation Act 1987 (OBRA), Balanced Budget Act of 1997, Health Care Portability and Accountability Act, 1996 (HIPAA). Information regarding these laws is available on posters and/or in reference material throughout the organization.
  9. REPORTING VIOLATIONS AND DISCIPLINE:
    1. Supervisors are responsible for ensuring that employees are aware of and adhere to the provisions in this policy and procedure.  The General Manager should be consulted when clarification and/or guidance is needed on any point.
    2. Employees are expected to immediately and directly report actual or perceived violations of the Code of Ethics, Corporate Compliance program or any other policy and procedure to their supervisor or to the General Manager or Corporate Compliance Officer.  The Corporate Compliance Office will report ethical issues to the General Manager on a quarterly basis starting Q3, 2005.
    3. No adverse action or retribution of any kind will be taken by the organization against any employee because he or she reports in good faith a suspected violation.
    4. Should an investigation substantiate a violation, appropriate disciplinary action will be taken in accordance with the Policy for Disciplinary Action.

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