Jeannine LeCompte, Publishing and Research Coordinator
Medicare- and Medicaid-approved long-term care facilities (LTCs) are under a legal obligation to provide compliance training to all frontline staff, administrative personnel, service providers and subcontractors—and the very first principle which must be established is that of “ethics.”
In a nutshell, ethics can be described as doing the right thing, and following the correct course of action in any situation. Staff should be taught to act fairly and honestly; adhere to high ethical standards in all they do; comply with all applicable laws, regulations, and Centers for Medicare & Medicaid Services (CMS) requirements; and to report all suspected violations to the relevant authorities.
In this regard, a facility’s Code of Conduct can be very helpful. It should be part of the written compliance program, and prominently displayed where all personnel, staff, volunteers, subcontractors, and service suppliers can see it—and in such a manner where they cannot claim later to have been unaware of its existence.
A Code of Conduct must state the overarching principles and values by which the company operates, and define the underlying framework for the compliance policies and procedures. A Code of Conduct should describe the facility’s expectations that all employees conduct themselves in an ethical manner; that issues of noncompliance and potential fraud, waste, and abuse are reported through appropriate mechanisms; and that reported issues will be addressed and corrected.
It is important that this code should be continually updated to incorporate changes in applicable laws, regulations, and other CMS and Office of Inspector General (OIG) program requirements. The Code of Conduct is therefore the most fundamental statement of the LTC’s governing principles, and should be formally approved by the full governing body.
Ensuring that all personnel are aware of the contents of this Code of Conduct, and of the ethical principles which form the basis of the organization’s operations, is something which should not be taken lightly, or ignored.
