PROCEDURES
1. Employees, managers, contractors and agents should avoid conducting transactions or
establishing any relationship with others if their loyalty and diligence to the Agency is
negatively affected or may be negatively affected.
2. Clients shall be advised of their rights to be free from Conflicts of Interest behaviors
and conducts which take advantage of them and/or their situations.
3. Employees, managers, contractors and agents shall not do anything that could result in
a Conflicts of Interest for the Agency such as buying and selling activities..
4. Employees, managers, contractors and agents shall be advised of the situations that the
Agency considers to be Conflicts of Interest, as identified under the “Definitions”
section of this policy.
5. Employees, managers, contractors and agents are to be provided with information on
how to report potential/actual conflicts of interest, in accordance with the Agency’s
Policies:
a. Compliance; and,
b. Compliance with Federal deficit Reduction & False Claims Acts.
6. Employees, managers, contractors and agents may not accept gifts, money, discounts
or favors including a benefit to family members, friends or business associates for
doing work that the company pays them to do.
7. Employees, managers, contractors and agents may not use, or permit the use of the
Agency’s property, facilities, equipment, supplies or other resources for activities not
associated with their work without authorization first from the Agency,
8. Employees, managers, contractors and agents may not disclose confidential or
privileged information for any purpose about the Agency, co-workers, clients/families,
or use confidential information to advance personal or others' interests as per the
Agency’s “Confidentiality and Privacy of Client Information Policy”.
9. Employees, managers, contractors and agents shall not violate federal, state or local
laws. Strict adherence is required to laws established for the detection and prevention
of fraud, abuse and waste in the federal health care systems, particularly the Federal
Deficit Reduction Act of 2005 – Section 6032 and False Claim Act, which require that
they be:
a. encouraged to:
i. be familiar with the laws regarding fraud, abuse and false claims;
ii. assume responsibility for their role in the prevention of fraud, abuse and waste
in the federal health care system; and,,
iii. assume responsibility for recognizing and reporting known and suspected cases
of fraud, abuse, and/or false claims in the federal health care system.
b. protected from retaliation and retribution, if they report known or suspected cases
of fraud, abuse and/or false claims, as per the “qui tam” provision of Section 6032.
(Refer to Policy #160 – Compliance with Federal Deficit Reduction & False Claims
Acts).