Page 10 - Asbury Code of Conduct
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iv. False claims
1. We are committed to maintaining accuracy and integrity in all our financial practices. Federal and state laws and regulations prohibit the intentional presentation of a false or fraudulent claim for payment to the U.S. government, including the federal and state health care programs. Accordingly, we prohibit any affiliate or associate from submitting any claim on its behalf for payment or reimbursement to any third party that is knowingly false, fraudulent or fictitious.
2. We will submit claims for payment or reimbursement that are actually rendered, documented in residents’ treatment and/or medical records and use billing codes that accurately describe the services provided.
3. All services provided will be reasonable, necessary and, when required, directed by an appropriate health care provider and signed plan of care.
4. Compensation for billing department personnel and billing consultants/ advisors shall not contain any financial incentive to submit improper claims, or be in any way related to the number of claims submitted or the dollar value of the funds received.
5. We may not waive co-payments or deductibles, except in accordance with applicable regulation and with the approval of appropriate management.
v. Gifts and business courtesies
1. Associates are not permitted to solicit or accept gifts, tips or gratuities from residents.
2. Associates may accept non-cash gifts or business courtesies that do not exceed the total value of $250 in any one year from any vendor, contractor or other business associate. Gifts include anything of value. Business courtesies include meals, transportation, conferences, etc. during which the donor and associate are both present and
the business courtesy is part of the business meeting or facilitates business discussion.
e. Whistleblowers and non-retaliation
i. We will not take any disciplinary
action or other types of retaliation against an associate who, in good faith, reports a concern, issue or problem to their manager or supervisor, Human Resources’ representative, Compliance Officer, General Counsel or the Hotline. “Good faith” means that you are telling the truth, as you know it. Any associate
 CODE OF ETHICS AND BUSINESS CONDUCT
  who believes that he or she has suffered retaliation should report this to the Hotline or any of the individuals noted above.
f. Compliance Hotline 1-877-455-7827
i. Hotline calls are answered by live operators, who are not Asbury associates. Calls cannot be traced or recorded. Following the call, a written report is sent to the appropriate officer or director for follow-up. Any type of problem can be reported to the Hotline and no one will be retaliated against for using the Hotline in good faith.
ii. Associates are encouraged to first report problems through their chain
of command, including the immediate supervisor, manager, director and/or human resources. Callers may remain anonymous but should provide sufficient detail so that the issue can be properly addressed. The confidentiality of callers to the Hotline who provide their identity will be protected to the extent possible and allowed by law.
ii. Intentional misuse of the Hotline,
such as making false accusations,
is a serious violation of policy and may lead to disciplinary action.
The Hotline should never be used for reporting emergencies.
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