The University Hospital of Arkansas
Code of ConductThe University Hospital of Arkansas ("University Hospital") has a policy of maintaining high professional and ethical standards in the conduct of its educational, research, public service, and clinical care missions. The Hospital places the highest importance upon its reputation for honesty, integrity, and high ethical standards. This Code of Conduct and the University Hospital Corporate Compliance Program are a reaffirmation of the importance of high ethical conduct and standards.
Employees must be educated and follow to the best of their abilities all federal and state laws and regulations applicable to their responsibilities at University Hospital.
The standards of this Code of Conduct are achieved and sustained through the actions and conduct of all personnel of the Hospital.
Each and every person associated with University Hospital, including management employees, is responsible for conducting himself/herself in a manner to ensure adherence to these standards.
Any University Hospital administrator, employee or agent who violates federal or state laws and regulations applicable to their responsibilities at University Hospital or who ignores or disregards the principles of the compliance programs, will be subject to disciplinary action which may include termination of his or her employment or affiliation with University Hospital.
Any University Hospital administrator, employee or agent who violates federal and state laws and/or regulations applicable to their responsibilities at University Hospital not only risks individual indictment, criminal prosecution and penalties, but also may be liable in civil actions for damages, penalties and administrative exclusion.
Each administrator or employee or agent who is materially involved in any of the Hospital's documentation, coding, billing or competitive practices must familiarize himself or herself with applicable laws and regulations, and must adhere at all times to the requirements thereof.
Where any question or uncertainty regarding the requirements of applicable laws or regulations exists, each administrator or employee should seek guidance from the University Hospital Compliance Officer or his or her designee.
As examples, and without limitation, this Code of Conduct and compliance program prohibit University Hospital, its administrators, employees and agents from directly or indirectly engaging or participating in certain proscribed conduct or acts described below:
Improper Claims: Improper claims include a person presenting or causing to be presented to the United States government or any other health car payor a claim for a[n]:
Item or Service Not Provided as Claimed. This involves a claim for a medical or other item or service that such person knows or should know was not provided as claimed, including a pattern or practice of presenting or causing to be presented a claim for an item or service that is based on a code that such person knows or should know will result in a greater payment to University Hospital than the code such person knows or should know is applicable to the item or service actually provided.
False Claim. This involves a claim for a medical or other item or service and such person knows or should know the claim is false or fraudulent;
Service by Unlicensed Physician. This involves a claim for a physician's service (or an item or service incident to a physician's service) when such person knows or should know the individual who furnished (or supervised the furnishing of) the service:
Was not a licensed physician;
Was licensed as a physician, but such license had been obtained through a misrepresentation of material fact;
Represented to the patient at the time the service was furnished the the physician was certified in a medical specialty by a medical specialty board when the individual was not certified;
Excluded Provider. This involves a claim for a medical or other item or service furnished during a period in which such person knows or should know the claimant was excluded from the program under which the claim was made;
Not Medically Necessary. This involves a claim for a pattern of medical or other items or services that such person knows or should know are not medically necessary.
False Records. No false records shall be made or caused to be made or used. No false statements or representations of material fact for use in determining rights to any benefit or payment under any health care program shall be created or used;
Conspiracy to Defraud. No University Hospital administrator, employee or agent shall conspire to defraud the United States government or any other health care payor by getting a false claim paid;
Health Care Fraud Relating to Health Care Masters. No hospital administrator, employee or agent shall obtain, by means of false, fictitious or fraudulent pretenses, schemes, representations or promises, anything owned by, or under the control of any health care benefit program; Nor shall any University Hospital administrator, employee or agent receive any kickbacks, bribes, or anything of value, offered to influence decision making.
Improper Referrals are Prohibited. No University Hospital administrator, employee or agent shall knowingly and willfully solicit or receive any remuneration, directly or indirectly, overtly or covertly, in cash or in kind, in return for referring an individual for services payable under the Medicare or Medicaid programs or purchasing, leasing, ordering or arranging for or recommending any good, facility, service, or item for which payment may be made under these programs.
All administrators and employees of University Hospital will be evaluated in pay and promotion by their adherence to the Code of Conduct.
All administrators and employees of the University Hospital will promptly notify their supervisor, an administrator, the Compliance Department, or the toll-free confidential Compliance Line at 888-511-3969 of any possible violations of law or improper activity by employees and agents of University Hospital. All reports will be assured of confidentiality to the extent permitted by law. Under no circumstances shall the good faith reporting of any such information or possible impropriety serve as a basis for any retaliatory actions to be taken against any employee, administrator, patient or other person making the report. Employees shall not make intentionally false statements or otherwise misuse the compliance line.
University Hospital employees shall conduct all transactions with vendors, contractors and other third parties free from offers, solicitation or receipts of gifts and favors or other improper inducements in exchange for influence or assistance in a transaction.