| Business Ethics and
- To commit the Agency to maintaining compliance with all laws, regulations, program
requirements and guidelines and operating the agency in an ethical manner.
- To provide the Agency with a mechanism to ensure compliance to all laws, regulations,
program requirements and guidelines and ethical business practices.
- It is the determined policy of Visiting Homemaker Service of Passaic County, Inc. and
its employees to adhere to sound and lawful business practices and comply with all program
requirements, regulations and guidelines. Therefore, the Agency will cooperate with all
reasonable and lawful demands made by governmental investigations or law enforcement
agents. Written, copied or electronic documentation is not to be altered or destroyed in
anticipation of a request or as a result of a request for those documents by any
authorized, lawful investigation.
- The Board of Trustees shall have final authority on all business ethics and compliance
decisions. The Board of Trustees shall appoint an independent Compliance Officer and
assign a Compliance Committee of the Board with the charge of establishing and advising
the organization on business ethical issues and practices and for overseeing compliance
with all laws, regulations, program requirements and guidelines.
- The Compliance Committee shall review, at least annually, all reported violations or
incidents of misconduct and compliance and business ethics policies, and report to the
Board of Trustees the activity of the Committee. Minutes shall be kept of all Compliance
- The Agency shall adopt a Code Of Business Ethics that clearly outlines expected conduct
and is to be displayed in each office and included in new hire orientation.
- The Agency will on an annual basis conduct internal audits on admissions, payments and
reimbursement, accounts receivable, delinquent accounts, and staff expenses to ensure
adherence to all laws, regulations, program requirements and guidelines and policies. The
results of these audits are to be reported at least annually to the Compliance Committee
for their review and recommendations to the Board of Trustees.
- It is the policy of VHSPC to prohibit kickbacks from being paid or received. The
administrative staff and the members of the governing body will sign a No Kickback Policy
statement annually. The statement will include a list of any payments, income, gifts,
special consideration, or remuneration of any kind that results from any vendor
relationship with VHSPC. These disclosure statements will be reviewed each year by the
- It is the policy of VHSPC to comply with all Federal HIPAA and State HINT regulations
regarding confidentiality of patient information. All Agency staff and volunteers shall
sign a Confidentiality Agreement in this regard. Each patient will receive a privacy
statement that will be explained to them and that they will acknowledge on the Informed
- This policy shall be part of new hire orientation and be signed, dated and kept in the
individual personnel record. All staff shall have access to current program regulations
and requirements at all times.
- The Agency shall communicate the Business Ethics and Compliance policy to the public and
referral sources annually. All clients will be informed of methods to report misconduct.
Reports of any misconduct,
unethical business practice or violation of program regulation or
guidelines can be made by anyone. These occurrences must be
reported, in writing or verbally, to a Supervisor or Agency
Executive Director immediately and will be kept in strict
confidence. This report must include the name of the person(s),
act(s), and date(s) of the suspected violation(s). The person
reporting the incident can also make the initial report to the
Compliance Officer: (Nancy Eberhardt., c/o Pro Bono Partnership,
973-240-6955, fax 973-240-6966, 300 Lanidex Plaza., Suite 3203,
Parsippany, NJ 07054) in writing, in person or by phone or fax.
Upon receipt of a reported
incident the Supervisor and Agency Executive Director must
investigate the allegation within five (5) days of the report. The
Compliance Officer must make a referral to the Agency Executive
Director or appropriate staff member for an investigation within
five (5) days of the report or investigate the allegation
independently within five (5) days of the report.
If, in the judgment of the
Executive Director or Compliance Officer, an incident is a
significant event a report to the Board of Trustees may be made
immediately upon the completion of the investigation. Otherwise,
all reported violations and their resolutions will be reported to
the Compliance Committee immediately for presentation to the Board
Failure, by any employee, to
report unethical business practices or unlawful actions by the
organization and its employees is misconduct warranting disciplinary
action up to and including termination. The Board of Trustees has
the final determination on appropriate disciplinary action for the
failure to report.
The Agency abides by the
Conscientious Employee Protection Act (Whistleblower Act) and
provides notices to employees as per the Act, upon hire and annually
Compliance Committee with revisions: 7/14/99
Approved by Board of
2/25/02 6/18/04 3/20/06 3/6/07 8/10/07 5/24/10