UBMD is committed to providing quality health care services in compliance with all applicable laws and regulations. This Code of Conduct is a statement of UBMD’s dedication to upholding the ethical, professional and legal standards we use as a basis for our daily and long-term decisions and actions.
All UBMD employees must understand and comply with all relevant policies, laws and regulations, and are individually and collectively responsible and accountable for upholding these standards of compliance. Supervisors and Compliance Coordinators are responsible for teaching and monitoring compliance, with the guidance and oversight of the UBMD Compliance Office.
Each Practice Plan will designate an employee as their Compliance Coordinator. That person will remain in that position until replaced by another employee. The Compliance Coordinator may have other duties as well as his or her compliance duties.
Relationships with other providers must comply with all applicable laws. Patient referrals are to be made and accepted based on medical needs only. No UBMD employee should ever accept or offer any type of payment or compensation in exchange for patient referrals, patient consultations or the purchase of services to a hospital or other facility. Any such offers should immediately be reported to a supervisor, compliance coordinator, or the UBMD Compliance Officer.
UBMD will only submit claims for reimbursement for services that were provided, documented in the medical record, and medically necessary. Reimbursement claims should never contain false or misleading information.
If an employee becomes aware of a situation in which a false claim has been made or submitted, that employee must report it immediately to a supervisor, compliance coordinator or the UBMD Compliance Officer.
It is a federal crime, in violation of the Federal False Claims Act, to knowingly submit false claims to Medicare, Medicaid or any health care benefit program. All billing activities, therefore, are subject to the federal criminal and civil sanctions, regardless of payer.
Many UBMD employees have access to various forms of sensitive and confidential information in regards to patients and co-workers. Any and all confidential and Protected Health Information (“PHI”) obtained either during the course of assigned duties or accidentally should not be released or discussed with anyone unless the individual is authorized to receive the information. UBMD prohibits the unauthorized seeking, disclosing or selling of such information. Thus, employees should not seek access to confidential information out of curiosity, for malicious purposes or for financial gain.
UBMD employees are prohibited from accessing their own, coworker’s, family member’s or patient’s PHI unless they have a clear requirement to do so, and then may only access the Minimum Necessary PHI as needed to perform their job.
All UBMD employees are prohibited from engaging in any activity, practice or act of financial interest that conflicts with or appears to conflict with the interests of UBMD or any professional setting where the employee engages in the practice of medicine. A conflict of interest may occur if an employee’s outside activities or personal interests influence or appear to influence his or her ability to make objective decisions on the job. A conflict of interest may also exist if the demands of outside activities hinder or distract the employee from the performance of his or her job or cause the employee to use UBMD resources for purposes not related to UBMD business. Therefore, employees should avoid any actions that might lead someone to believe there is a conflict of interest. Questions regarding conflicts of interest should be directed to a supervisor, compliance coordinator or the UBMD Compliance Officer.
In addition to this Conflict of Interest statement, UBMD has a Conflict of Interest Policy for its Officers, Directors and key employees.
UBMD employees may not solicit or accept gifts or payments that exceed $100 individual or $250 in total during one calendar year from individuals or business organizations with business intents, contracts or transactions with UBMD. Such action may appear to influence objectivity in performing our work, or give the appearance of providing personal gain or showing favoritism to an individual and/or current or potential business partner. Any gifts or payments must be reported to the UBMD Compliance Office within thirty days of its receipt. If a situation arises which conflicts with this policy, contact your supervisor or the UBMD Compliance Officer immediately.
UBMD employees shall not obtain proprietary or confidential information about a competitor through illegal or unethical means. Information may be gathered about other organizations, including our competitors, through legal and ethical means, such as public documents and other published and spoken information.
UBMD employees will comply with all applicable disclosure rules and regulations honestly and completely. Employees involved in the negotiation of a contract must ensure that all the data generated, supplied and represented is accurate, current and complete. Failure to follow these guidelines may result in civil or criminal liability for UBMD, the involved employee and any managers or supervisors who condone such a practice. UBMD employees shall not contract to obtain services or products from an individual or company that has been convicted of a criminal offense related to health care and/or is listed by a federal agency as debarred, excluded or otherwise ineligible for participation in federally funded health care programs.
Confirmed violations of this Code of Conduct will result in appropriate disciplinary action against the offending individual(s), up to and including termination from employment.
