Using a Code of Conduct as a Cornerstone for Healthcare Compliance
September 27, 2019
Have you ever asked yourself, "What is a Code of Conduct and why do we need one?"
There are plenty of laws on the books to mandate good behavior, but even laws cannot force one to always engage in ethical conduct. Obeying the law is a minimal standard of behavior — but in an industry such as healthcare, where public trust and expectations are extraordinarily high—we must be held to a higher standard. An organization's Code of Conduct, hereafter referred to as the Code, does just that.
The Code is the cornerstone of any healthcare organization's compliance program and is an essential and integral component of the institution's culture. With the passage of the Affordable Care Act, it is also a requirement. According to the U.S. Sentencing Guidelines, an effective compliance program shall "exercise due diligence and the promotion of an organizational culture that encourages ethical conduct and a commitment to compliance within the law." But what does that mean, exactly?
About the Code of Conduct
A Code of Conduct encourages each employee, physician, contractor, vendor, or other stakeholder to think about their actions and the consequences of behavior in the workplace. It provides broad organizational guidance with ethical and compliance principles that will guide the entity's operations and decision-making. Senior leadership, along with the Board of Directors, has committed to it, and all staff members probably signed a statement of understanding, promising to abide by it when they were hired and then doing so annually thereafter.
While they can vary widely, the typical values outlined in healthcare providers' Codes of Conduct are:
- To provide quality, cost-efficient, and medically necessary patient care
- Conduct organizational business with integrity and transparency
- Be of service to the organization’s community
- For its employees and affiliates, to exemplify ethical behavior by doing what is right and reporting what is wrong
The Code of Conduct as a Reference Point
Not every situation or challenge you may encounter will be addressed in your Code of Conduct, but it can serve as a reference point in the event you find yourself with an ethical dilemma. As always, you should contact your Compliance Officer in the event that you are unsure of what to do. You may also report concerns to your organization's hotline. Make coding education the core of your revenue integrity program within your healthcare compliance strategy.
Let HCCS (hyperlink) help your organization with a Code of Conduct Program