Integrity and Compliance

Code of Conduct

The standards outlined in the Code of Conduct apply to the Clinically Integrated Network’s (CIN) relationships with patients, member providers, affiliated physicians, third party payers, subcontractors, independent contractors, vendors, consultants and others.

1. Access Care’s employees, Governing Body, participants and providers as well as any other related entities will strive to operate in accordance with the highest ethical, legal and moral standards and in accordance with all federal, state and local statutes, regulations and requirements.
   
   
2. Access Care employees, Governing Body, participants and providers, as well as any other related entities, will not engage in any corrupt practices, pay any bribes or kickbacks. Neither will we offer, give, solicit or receive anything of value in an effort to induce network physician referrals or induce Medicare beneficiary participation in the CIN. We will strive to avoid any situations in which an excluded individual or entity is employed or contracted with, or any other situation in which state or federal fraud and abuse laws are violated.
    
3. While Access Care is not directly involved in billing Medicare for clinical services, the Network will not tolerate false, fraudulent or inaccurate billing by Participants within the Network.
   
   
4. Beneficiaries / Members may be encouraged, but not required, to work with Network Participants to improve care coordination and achieve program goals. Patients retain the right to express a preference for a different healthcare provider, and the Participant retains the right to refer outside of the Network if the referral is in the patient’s best interest based on the provider’s clinical judgment.
   
   
5. Beneficiaries will not be offered gifts or remuneration as inducements for receiving items or services from Network Participants or Providers / Suppliers. In-kind incentives may be permissible under specific conditions related to preventive care, advancing clinical goals, adherence to drug regimens, management of a chronic condition, etc. Financial incentives may be allowed only under certain payer initiatives, as outlined in regulations.
   
   
6. Access Care expenses will be transparent, tracked accurately and reviewed by the Governing Body. 
   
   
7. Access Care will strive to respect our patients' right to privacy and security of their protected health information and will strive to maintain confidentiality and abide by all applicable privacy laws, including the HIPAA privacy and security rule.
   
   
8. Any non-compliant behavior, fraud, or waste should be reported to the Compliance Officer, Denise Vladovich (dvladovich@icmhealth.com), or report anonymously by calling the Compliance Hotline at 1-800-399-3168. The CIN will not take any action in retaliation against an individual for reporting non-compliant behavior, fraud, or waste. The Compliance Officer and CIN legal counsel will promptly investigate alleged violations of this code of conduct, this compliance plan, state law or federal law. The CIN will take action on any verified non-compliance or violations of the law and impose appropriate discipline on any individuals who are involved in verified violations, which may include termination from CIN participation.