This policy applies to all employees, officers, contractors, and agents of Parker Health, Inc. d/b/a Parker. We are committed to upholding the highest standards of integrity.
1. Healthcare regulatory compliance policy
Policy statement.The organization is committed to full compliance with all federal and state healthcare laws. We maintain a “culture of compliance” to prevent the submission of inaccurate claims and to ensure the integrity of the healthcare system.
Standards of practice
- Accuracy in documentation: All clinical documentation must be contemporaneous, accurate, and reflective of the services actually provided.
- The False Claims Act (FCA): Employees are prohibited from knowingly presenting a false or fraudulent claim for payment. Under the “Qui Tam” provisions, the company protects the rights of whistleblowers who report suspected fraud by encouraging employees to use the confidential reporting channels outlined in the “Reporting and Enforcement” section below.
- Anti-Kickback Statute (AKS): No employee may offer or receive anything of value (cash, gifts, free rent, etc.) in exchange for the referral of a patient or business covered by federal healthcare programs.
- Stark Law: We strictly adhere to physician self-referral prohibitions. Financial relationships with referring physicians must be written, set at fair market value, and not take into account the volume or value of referrals.
2. HIPAA Privacy and Security Policy
Policy statement.We have a strict legal and ethical obligation (a “fiduciary duty”) to protect patient privacy. This policy ensures compliance with the Health Insurance Portability and Accountability Act (HIPAA) and the HITECH Act.
Privacy Rule standards
- Permitted uses: Protected Health Information (PHI) may only be used for TPO (Treatment, Payment, and Healthcare Operations). Any other use requires a signed patient authorization.
- Patient rights: Patients have the right to inspect their records, request amendments, and receive an accounting of disclosures.
Security Rule standards
- Administrative safeguards: All staff must undergo HIPAA training annually. Access levels are granted based on the “Least Privilege” principle.
- Technical safeguards: All portable devices (laptops, USBs) must be encrypted. Unique user IDs and automatic log-offs are mandatory.
- Breach protocol: In the event of a “compromise of privacy or security,” the Compliance Officer must be notified within one hour. We adhere to the 60-day federal notification window for affected individuals and the HHS.
3. Business conduct and ethics policy
Policy statement. Our reputation is our most valuable asset. We expect employees to exercise sound judgment and maintain the highest standards of honesty.
Conflict of Interest (COI)
- Employees must disclose any outside employment or financial interest in a competitor, vendor, or supplier through the annual Conflict of Interest disclosure form provided by the Compliance Department.
- Using company resources for personal gain is strictly prohibited.
Workplace integrity
- Non-discrimination: We provide equal opportunity regardless of race, color, religion, gender, or disability.
- Harassment-free environment: We maintain zero tolerance for any behavior that creates an intimidating or hostile work environment.
External communications
- Only authorized spokespeople may speak to the media or post on behalf of the company on social media. Financial data must never be shared on public forums.
4. Anti-corruption and antitrust policy
Policy statement. We compete on the merits of our products and services, not through bribery or unfair trade practices.
Anti-corruption (FCPA & UK Bribery Act)
- Prohibition of bribes: No employee shall offer, promise, or give anything of value to a government official or private citizen to influence a business decision.
- Facilitation payments: We do not allow “grease payments” to expedite routine government actions (e.g., permits or licenses), even if such payments are local custom.
- Due diligence: We perform background checks on third-party agents and distributors to ensure they also adhere to anti-corruption standards.
Antitrust and fair competition
- Prohibited agreements: You must never enter into an agreement (written or verbal) with a competitor to fix prices, rig bids, or divide territories.
- Information exchange: Do not share sensitive business information, such as future pricing plans or cost structures, with employees of competing firms at trade shows or conferences.
- Tying arrangements: We do not condition the sale of one product on the mandatory purchase of a second, unrelated product if it unlawfully restricts competition.
Reporting and enforcement
Failure to comply with these policies may result in disciplinary action, up to and including termination of employment and legal prosecution.