RHA Health Services - Code of Conduct

CODE OF CONDUCT RHA’s Corporate Compliance Program

Our Commitment RHA is guided by a strong commitment to our mission, vision, and values, which include a commitment to accountability and ethics. Our compliance program is designed to help fulfill this commitment.

The cornerstone of RHA’s Corporate Compliance Program is our Code of Conduct, which outlines key expectations that every employee must follow every day.

The Code serves to guide each of us as we face complex professional, ethical, and legal decision-making. We must be assured that each decision, policy, and procedure, whether it is clinical or business-related, is developed with absolute integrity and honesty.

As part of the Corporate Compliance Program, you will receive training on how our program operates and how you play a key role as an important team member in ensuring sound and ethical conduct.

If you have a question regarding the Code of Conduct or how it may apply to a particular situation, as a starting point, you should first contact your supervisor and use your local chain of responsibility. Should you ever encounter a situation that concerns you and you feel uncomfortable reporting it to your supervisor, or you would like to remain anonymous, we encourage you to use our Ethics & Compliance Helpline at 866-742-2428. .We are all responsible for upholding the outstanding reputation of RHA and honoring the trust our communities have placed in us. We appreciate your commitment to holding yourself and others accountable for maintaining high standards of conduct and compliance in all we do

Mickey Atkins Chief Executive Officer

RHA’s Mission Statement: To provide a safe and healthy environment while creating opportunities for personal outcomes.

Table of Contents 04 Quality Service

05 Fair Treatment of Employees 06 Accuracy of Records 07 Improper Use of Funds 08 Protecting Property, Assets, and Information 09 Conflict of Interest 10 Billing Practices 11 Ethical Business Practices 12 Government Investigations 13 Personal Fundraising 14 Confidentiality 15 Getting Help

At RHA, being person-centered means that the people we support are the focus of all we do.

Quality Service Code of Conduct Standard Key Statement RHA will deliver appropriate and effective supports and services.

Guiding Principles Supports and services must be appropriate and designed to meet the intended outcomes of each person’s treatment plan.

Treatment plans are developed based on each person’s definition of quality life, desired personal outcomes, and the service definition for each type of service. Services must always be provided with sensitivity, respect, and professionalism.

Our focus is on establishing clear expectations for interactions between our team and the individuals we serve.

Employees are dedicated to using evidence-backed methods for delivering support and services, all while maintaining a focus on cost-effectiveness.

RHA employees are required to observe all applicable standards of professional practice throughout all RHA programs.

Ask yourself

Ask Yourself:

Did I provide excellent support the people I Did I provide excellent support today totoday peopleto consistent with their desired individual goalsdesired and outcomes? served consistent with their individual goals and outcomes?

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Fair Treatment of Employees Code of Conduct Standard Key Statement RHA is dedicated to cultivating a workplace environment that upholds the rights, dignity, and cultural diversity of its employees.

Guiding Principles It is everyone’s responsibility to create and maintain a work environment in which employees are treated with respect, diversity is valued, and opportunities for development are provided.

We hire, train, promote, and compensate employees without regard for race, color, sex, religion, gender, national origin, age, marital status, gender identity, sexual orientation, disability, veteran status, or other classification protected by law.

We maintain an environment free of harassment, discrimination, retaliation and hostility.

Ask yourself Am I careful not to let differences and beliefs affect the work environment? Did I treat others the way I wish to be treated?

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Accuracy and Quality of Records Code of Conduct Standard Key Statement All RHA records shall be prepared accurately, reliably, timely, and in accordance with established policies, regulations, and laws. All records must be stored in a safe and secure location and retained for periods consistent with record retention requirements.

Guiding Principles All employees must ensure that all program records, medical records, and business records are accurate and complete. Documentation should always be preserved and must be properly disposed of in accordance with document retention schedules.

Ask yourself Did I ensure that my documentation was entered timely for each person served?

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Improper Use of Funds Code of Conduct Standard Key Statement RHA employees may not use funds for improper or illegal activities.

Guiding Principles Employees may not use company funds, materials, or property for personal reasons.

Employees are responsible for tracking and maintaining appropriate records for all resident funds and corporate credit card purchases.

All credit card transactions must be supported by a receipt.

Ask yourself If I take a person served shopping for new clothes, did I make certain to log the expense and turn in the receipt?

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Protecting Property, Assets, and Information Code of Conduct Standard Key Statement All personal property of persons supported, visitors, employees, and property owned by the company should be properly cared for and safeguarded. Company property should be used for business purposes only.

Guiding Principles RHA will make every effort to protect the personal possessions of people receiving services from theft, damage, destruction, and loss.

Company property is authorized for RHA business use only and not for personal purposes. This includes office equipment, computers, print materials, digital marketing collateral, software, supplies, records, personnel information, and company data and reports.

Ask Yourself:

Ask yourself

Did I refrain from using RHA business Did I provide excellent support to the people I suppliestoday and equipment for personal use?

Did I accurately report my and time at served consistent with their desired individual goals work? outcomes?

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Conflict of Interest Code of Conduct Standard Key Statement All employees must avoid a conflict of interest, the appearance of a conflict of interest, or a conflict of commitment.

Guiding Principles A conflict of interest occurs if an outside interest or activity may influence or appear to influence your ability to exercise objectivity or meet your job responsibilities at RHA. A conflict of commitment occurs when an employee engages in an outside professional activity, paid or unpaid, that involves a commitment of time that may interfere, or appear to interfere, with the fulfillment of the employee's obligations.

Unless otherwise permitted by policy, RHA employees should not accept or give any type of gift (cash, gift card, etc.) to or from a person supported or any member of their family.

Ask yourself Did I disclose any business relationship that may be a conflict of interest or commitment to my supervisor prior to entering into any agreement? Did I ensure that my relationship with a vendor does not influence my choice to use that vendor?

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Billing Practices Code of Conduct Standard Key Statement RHA employees are responsible for ensuring that documentation for services is accurate and supports the services provided.

Federal and State laws, MCOs, and LMEs prohibit all employees from making or submitting a false or improper claim for payment.

Guiding Principles RHA will only bill for services after they have been rendered and appropriately documented. All billing must comply with state and federal payer requirements and conform with all applicable contracts and agreements.

Services will be provided based on accurate and appropriate assessment and medical necessity of the person supported.

Billing and cost report data must be collected, submitted, and retained as defined by law and RHA policies. Policies and procedures have been developed, approved by management, appropriately updated, and made available to all employees involved in the billing process.

Employees who suspect improper billing or documentation are required to immediately alert their supervisor or a higher-level manager or call the Ethics and Compliance Helpline.

Ask yourself

Ask Yourself:

Do I have the appropriate documentation to support billing and Did I provide support to the peopleaI claim submit the claim excellent for this service?

If I amtoday ever asked to process served consistent desiredclarification individual that is different thanwith policy,their did I request togoals avoid and outcomes? improper billing?

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Ethical Business Practices Code of Conduct Standard Key Statement Employees are responsible for acting honestly and with integrity, following the rules, understanding the difference between right and wrong, and choosing to do the right thing.

Guiding Principles To ensure compliance with state and federal laws and to prevent and monitor fraud, waste, and abuse, RHA routinely audits services for regulatory compliance and quality.

We are all responsible for acting in an ethical and honest manner. All employees must consider the following: In all things, follow our Vision, Core Values, and Code of Conduct.

Employees should have a basic understanding of the rules and follow them.

Know what to do when help is needed to determine if there is a problem.

Report any known or suspected violations of the Code of Conduct, laws, or regulations.

Acting with integrity is the responsibility of every member of the team, regardless of their work location or job.

Ask yourself

Ask Yourself:

Is this action consistent with RHA Did I Did provide support today to the people I policy?

I treatexcellent persons supported served consistent with their desired individual goals and with dignity and respect?

outcomes?

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Government Investigations Code of Conduct Standard Key Statement RHA cooperates with all government investigations.

Guiding Principles If anyone is approached or an individual enters the workplace identifying themselves as a government representative or investigator, the employee should immediately contact the Administrator/Director or the Chief Compliance Officer immediately.

Examples of Government Officials are the OIG, FBI, NCDOJ, MFCU, Attorney General, etc…(not an inclusive list). Do not feel pressured to talk with the investigator without first contacting your Administrator/Director or the Compliance Office.

It is important to note that routine and complaint driven surveys by state agencies such as the MCO, DHSR, ODP, DDD, DIDD, or DBHDD are routine. Routine and complaint surveys should be reported to your supervisor.

Ask yourself Do I appropriately seek advice from my supervisor before dealing with government agencies?

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Personal Fundraising Code of Conduct Standard Key Statement Employees may not engage in personal fundraising, such as selling cookies or candy, or raising funds for schools, churches, or any for-profit or not-for-profit endeavor.

Guiding Principles Employees should not be pressured by a co-worker to purchase or make donations to non-RHA-related activities in the workplace.

Ask yourself Do I refrain from personal fundraising activities in the workplace?

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Confidentiality

Code of Conduct Standard Key Statement RHA safeguards confidential information, including details concerning the individuals we support. Information may be disclosed and shared for purposes related to individual treatment, daily operations, and payment for services rendered or when other appropriate permissions are obtained.

Guiding Principles We should never disclose confidential information to any unauthorized person or entity. Additionally, taking pictures, texting, and sharing photographs of individuals receiving services on websites or social media platforms is prohibited and subject to corrective action, up to and including termination.

We respect and maintain the confidentiality of employees and people we support. Some examples include: Person-supported records (identity, diagnosis, treatment, treatment plan, services provided, financial, psychosocial, and other personal or family information).

Employee-related information such as social security numbers, birth dates, and medical information.

Financial, marketing, planning, and other types of business-related information.

RHA has implemented policies and procedures that help guide employees on the appropriate uses and disclosures of protected health information. The confidentiality of Alcohol and Drug abuse is further protected under 42 CFR, Part 2, and applicable state laws.

Ask Yourself:

Ask yourself

Did I provide excellent support today to the people I

Am I careful not to leave individual files, reports, or other information served consistent with their desired individual goals and in areas that can be viewed by others who do not have a need to see outcomes? it? Did I keep my computer passwords confidential?

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Getting Help What to do when you believe there may be a problem?

Whenever possible, you are encouraged to resolve issues by contacting your Supervisor, Home Manager, or the Administrator/Director. If you are uncomfortable using this approach or wish to remain anonymous, the Ethics & Compliance Helpline is available 24/7.

Every compliance concern brought to RHA’s attention will be promptly and thoroughly evaluated and investigated for proper resolution.

It is against RHA policy to retaliate against any individual who makes a good-faith report. Any individual who engages in retaliation or retribution is subject to discipline up to and including termination.

1-866-742-2428 (1-866-RHA-CHAT) For HR-related issues, employees are encouraged to contact HR Solutions at 833-742-4748 or email HR4U@rhanet.org, or contact their regional business manager.

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