Notice to Vendors, Contractors and Agents

PeaceHealth's Code of Conduct is based on our Core Values.

It combines our concern for fulfilling the requirements of the law with an emphasis on responsible conduct, a renewed commitment to excellence, stewardship of our resources, and a supportive work environment.

The Code of Conduct represents a reaffirmation of our long-term commitment to ethical and legal business practices, high quality care, and services to the communities where our facilities are located. It illustrates how these values should be applied to our daily work lives.

This Code of Conduct applies to all PeaceHealth employees, as well as physicians, board members, students, volunteers, contractors, and vendors.

PeaceHealth Core Values:

Respecting Individual Human Dignity and Worth

We respect the dignity and appreciate the worth of each person as demonstrated by our compassion, caring, and acceptance of individual differences.

To live out this value, we will:

• Respect the inherent dignity and value of every person.
• Listen to and respect the suggestions and ideas of our co-workers.
• Communicate honestly. We will prepare and maintain all patient and organization data, records, and reports accurately and truthfully. We will adhere to applicable standards in maintaining all records. We will be honest in our communication with each other, as well as with patients, vendors, and payers, and with the communities in which we serve.
• Ensure safety and well-being. We will strive to provide a hazard-free working environment consistent with national standards and established federal, state, .and local regulations.
• Maintain and protect the confidentiality of patient, employee, and organizational information.
• Treat each other equally and avoid discrimination against any person for any reason.
• Refuse to tolerate any form of harassment or workplace violence.

Stewardship

We choose to serve the community and hold ourselves accountable to exercise ethical and responsible stewardship in the allocation and utilization of human, financial, and environmental resources.

To live out this value, we will:

• Exercise responsible stewardship of human, physical, financial, and environmental resources.
• Provide accurate and truthful information in all transactions including but not limited to the completion of time sheets, patient bills, and tax returns.
• Protect PeaceHealth's assets for the good of the healthcare ministry. Prevent misuse, loss, or theft, and report when we observe inappropriate use of assets.
• Refrain from using PeaceHealth business information for our personal gain or for the advantage of our family and/or friends.
• Strive to make contracts conform with appropriate rules and regulations, policies, and procedures.
• Identify inadequate work processes and continually work to improve them.
• Obey all antitrust and similar laws that regulate competition.
• Disclose ownership in any organization that does business with PeaceHealth.
• Work for a competitor, supplier or potential supplier of PeaceHealth only with the approval of our supervisor.
• Refuse any type of gift (for example, meals, money, or sporting event tickets) that influences our decision-making or creates the appearance of influencing it.
• Never solicit gifts for ourselves from parties who do business with PeaceHealth.
• Refuse any kind of payment for referral of patients; refuse any kind of payment in exchange for business with PeaceHealth.

Collaboration

We value the involvement, cooperation, and creativity of all who work together to promote the health of the community.

To live out this value, we will:

• Promote employee participation. We will promote a working environment that encourages new ideas and the sharing of those ideas.
• Foster the pursuit of knowledge and skills among all those who serve in order to provide quality healthcare.
• Exercise good faith and honesty in all dealings and transactions.
• Share our knowledge and expertise with others.
• Support and respond to organizational needs.
• Encourage a team approach in accomplishing objectives.
• Involve those affected in decision-making.
• Be a good community citizen.

Social Justice

We build and evaluate the structures of our organization and those of society to promote the just distribution of health care resources.

To live out this value, we will:

• Advocate for a just system.
• Create a workplace that fosters community and promotes the common good.
• Not use any of PeaceHealth's resources to benefit any political candidate, party, organization, committee, or individual.
• Provide care for all persons regardless of their ability to pay.
• Refuse to transfer patients to another provider because of their inability to pay for healthcare services.
• Use our financial resources to benefit the community and not for personal gain. We should use our financial resources in a way that is consistent with the charitable purpose of PeaceHealth, a not-for-profit 501(c)(3) corporation.

PeaceHealth is required by federal law to provide information to all its contractors and agents regarding the federal false claims act, administrative remedies for false claims and statements, the state false claims act and whistleblower protections under these laws. The federal and state false claims acts play an important role in detecting fraud, waste and abuse in federal health care programs. Please provide this information to all employees.

The False Claims Act – A Federal Law That Protects Whistleblowers

The law. The federal False Claims Act (31 USC 3729-33) makes it a crime for any person or organization to knowingly make a false record or file a false claim with the government for payment. “Knowing” means that the person or organization:

• knows the record or claim is false, or
• seeks payment while ignoring whether or not the record or claim is false, or
• seeks payment recklessly without caring whether or not the record or claim is false.

Under certain circumstances, an inaccurate Medicare, Medicaid, VA, Federal Employee Health Plan or Workers’ Compensation claim could become a False Claim. Examples of possible False Claims include someone knowingly billing Medicare for services that were not provided, or for services that were not ordered by a physician, or for services that were provided at sub-standard quality where the government would not pay.

A person who knows a False Claim was filed for payment can file a lawsuit in Federal Court on behalf of the government and, in some cases, receive a reward for bringing original information about a violation to the government’s attention. Some states have a False Claims Act that allows a similar lawsuit in state court if a False Claim is filed with the state for payment, such as under Medicaid or Workers’ Compensation. Penalties are severe for violating the federal False Claims Act. The penalty can be up to three times the value of the False Claim, plus from $5,500 to $11,000 in fines, per claim.

Whistleblower protections. The federal False Claims Act protects anyone who files a False Claim lawsuit from being fired, demoted, threatened or harassed by their employer for filing the suit. An employee who was harmed by their employer for filing a False Claims lawsuit must file a lawsuit against their employer in Federal Court. If the employer retaliated, the court can order the employer to re-hire the employee, and to pay the employee twice the amount of back pay that is owed, plus interest and attorney’s fees.

Our Policy. PeaceHealth’s Organizational Integrity Program includes monitoring and auditing for compliance that helps prevent or detect errors in coding or billing. 

• PH expects that our employees who are involved with creating and filing claims for payment for services that we provide will only use true, complete and accurate information to make the claim.
• PH expects that anyone with a concern about a possible False Claim at a PH facility will use the OI Reporting Process immediately so that PH can investigate and correct any errors.
• PH’s policy on non-retaliation protects our employees from adverse action when they do the right thing and report any genuine concern via the OI Reporting Process.
• PH will investigate any allegation of retaliation against an associate for speaking up, and will protect and/or restore rights to anyone who raised a genuine concern.

Our Promise. Our employees work hard to ensure that every claim for payment for the care we provide is correct and accurate, so that we do not violate the law, or break the trust we maintain with our patients and communities.

Fraud, Waste and Abuse Job Aid. For more information regarding Fraud, Waste and Abuse please see the FWA Job Aid.

If you have any questions about this information or wish to report a concern or view policies related to our Organizational Integrity Program, please contact Gary Chiodo, vice president of Organizational Integrity, at 360-729-1891 or e-mail: GChiodo@peacehealth.org

Notice to Visitors

PeaceHealth’s Organizational Integrity (OI) Program is designed to establish an ethical culture within PeaceHealth that promotes prevention, detection, and resolution of conduct that does not conform to federal and state laws and regulations or PeaceHealth’s policies.

To meet its business needs, PeaceHealth may enter into agreements that require compliance with PeaceHealth’s Privacy and Security policies and procedures.  Unless specified otherwise, the following policies apply to such agreements.

• Use PeaceHealth Confidentiality Agreement
• Information Privacy and Security Incidents 
• Use of PeaceHealth E-Mail
• Use of PeaceHealth Internet Services
• Access to PeaceHealth Information Systems
• Password Standards
• Institutional Conflict of Interest

PeaceHealth reserves the right to review and amend these policies in accordance with applicable laws and regulations or to address its business needs.