Seven Summary Statements of the Code of Conduct are listed below, click on the statement to view more specific details or scroll through to read all of the statements in detail:
LHM's employees and agents shall engage in ethical business relationships.
LHM's employees and agents respect each other as human beings and health care professionals.
The Code of Conduct is not, and may not be construed as, a contract of employment or any other type of contract. Failure to comply with this Code of Conduct will result in disciplinary action up to and including termination of the relationship with Lutheran Homes of Michigan, Inc. (LHM). Employees are asked to refer also to their Personnel Policies & Procedures handbook. All are asked to refer to the expanded explanation of each of the above Codes of Conduct (available in the business offices & at the nurses' stations with the emergency manuals).
Approved: April 16, 2001
A. LHM's employees and agents shall respect a resident/client's dignity and treat resident/clients with consideration, courtesy and respect.
B. LHM shall only employ or work with persons with proper credentials, experience and expertise. Employees and agents are expected to have those credentials and experience, and should expect other agents to have them.
C. It is everyone's job to maintain LHM's integrity and reputation.
D. Residents/clients have the right to choose what is done to their body, and by whom. This includes the choice of health care providers.
E. Residents/clients have the right to know what they need to know to make intelligent decisions. That includes receiving information about LHM and its policies, procedures and charges, and who will provide services on behalf of LHM.
F. LHM employees and agents will provide residents/clients appropriate and sufficient treatment and services based upon an accurate comprehensive assessment and plan of care that address their clinical conditions.
G. LHM will assure its employees and agents have sufficient education, licenses, background experience, on the job training and supervision to render services to its residents/clients.
H. No deficiency or error should be ignored or covered up. Every problem should be brought to the attention of those who can properly assess and resolve it.
I. Any incident of resident mistreatment, neglect or abuse will be reported to the Administrator and other officials as required by law.
J. Employees and agents deserve clear instructions about what is expected of them.
K. LHM's highest priority is the health and safety of our residents/clients and ourselves. We shall strive to do our jobs so that no harm is caused to our residents/clients, the public, or ourselves.
A. LHM's employees and agents will assure that each resident is protected from verbal, mental or physical abuse, corporal punishment and involuntary seclusion.
B. LHM's employees and agents will assure that residents/clients are protected against the inappropriate use of physical or chemical restraints.
C. LHM's employees and agents will ensure that residents/clients have personal privacy and access to their personal records.
D. LHM's employees and agents shall safeguard each resident's financial affairs.
A. LHM, by and through its employees and agents, shall comply with all applicable laws, regulations, standards and other requirements imposed by any level of government, including all requirements of the Medicare and Medicaid programs.
B. LHM will not pursue any business opportunity that requires engaging in unethical or illegal activity.
C. Neither LHM, its employees or agents shall pay employees, physicians, or other health care professionals, directly or indirectly, in cash or by any other means, for referrals of residents/clients. Every payment to a referral source must also be supported by documentation that the services contracted for were in fact provided.
D. No employee or agent of LHM is authorized to enter into any joint venture, partnership or other risk sharing arrangement with any entity that is a potential or actual referral source unless the arrangement has been reviewed and approved by LHM's lawyers and CEO.
E. Employees or agents who perform billing and/or coding of claims must take every reasonable precaution to ensure that their work is accurate, timely, and in compliance with federal and state laws and regulations and LHM's policies.
F. No claims for payment or reimbursement of any kind that are false, fraudulent, inaccurate or fictitious may be submitted. No falsification of medical, time or other records that are used for the basis of submitting claims will be tolerated.
G. LHM will bill only for services that are medically indicated, ordered by the resident's physician, actually rendered and which are documented in residents/clients' medical records. If the services must be coded, then only billing codes that accurately describe the services provided will be used.
H. LHM's employees and agents will only submit claims for covered items and services.
I. LHM shall act promptly to investigate and correct the problem if errors in claims that have been submitted are discovered.
J. LHM shall maintain complete and thorough medical and billing records.
K. LHM's employees and agents shall respect and protect the confidentiality of resident records and other personal information.
L. All drugs or other controlled substances shall be maintained, dispensed and transported in conformance with all applicable laws and regulations.
M. Employees and agents shall promptly report to LHM administration all suspected violations of the Code of Conduct, Compliance Policies, operational policies, laws or regulations.
A. LHM seeks positive relationships with government programs and third party payers. Positive relationships require ongoing communication about resident progress and billing.
B. Employees or agents shall not use or reveal any confidential information concerning LHM or use, for personal gain, confidential information obtained as an employee or agent of LHM.
C. No employee or agent should subordinate his or her professional standards, judgment or objectivity to any individual. If significant differences of opinion in professional judgment occur, then they should be referred to management for resolution.
D. Employees and agents should be honest and forthright in any representations made to residents/clients, vendors, payers, other employees or agents, and the community.
E. All reports or other information required to be provided to any federal, state or local government agency shall be accurate, complete, and filed on time.
F. Employees and agents must perform their duties in a way that promotes the public's trust in LHM.
G. The source or amount of payment does not determine the quality of care that we deliver.
H. Employees and agents shall be honest in doing their jobs.
I. If an employee or agent knows of or suspects a practice or incidents that may violate this Code of Conduct, LHM's Compliance Policies, operational policies, any law or regulation, then he or she must report it to appropriate levels of management.
A. Employees and agents should not have other jobs that interfere with their ability to perform their duties at LHM.
B. Employees and agents should avoid any activity that conflicts with the interests of LHM or its residents/clients. They should try to avoid even the appearance of an impropriety. If an employee or agent suspects that a conflict may exist or be created, then he or she should consult with management.
C. Placing business with any firm in which there is a family relationship may constitute a conflict of interest. Advance disclosure and approval by the CEO are required in such a situation.
D. Employees and agents should not become involved, directly or indirectly, in outside commercial activities that could improperly influence their actions. For example, an employee or agent should not be an officer, director, manager or consultant of a potential competitor, customer, or supplier of LHM without first disclosing that relationship to management and receiving approval of the CEO.
E. Employees and agents should not accept or provide benefits that could be seen as creating conflict between their personal interests and LHM's legitimate business interests. This includes accepting expensive meals, gifts, refreshments, transportation, or entertainment provided or received in connection with the job.
F. Gifts and benefits to clinicians or referral sources are not appropriate. Occasional non-cash gifts that are limited to reasonable meal expenditures or entertainment or that are of nominal value, although not expressly prohibited, are discouraged.
G. Employees and agents should report any potential conflicts of interest concerning themselves or their family members to management.
A. All employees and agents are personally responsible and accountable for the proper expenditure of LHM funds and for the proper use of company property.
B. All employees and agents must obtain authorization prior to committing or spending LHM's funds.
C. Medical waste or other hazardous materials shall be disposed of properly.
D. Employees and agents may not use LHM's or a resident's resources for personal or improper purposes, or permit others to do so.
E. Surplus, obsolete or junked property shall be disposed of in accordance with LHM's procedures. Unauthorized disposal of property is a misuse of assets.
F. Employees and agents have a duty to be productive during the time that is paid for by LHM.
G. Employees and agents may only use computer systems, networks, and software consistent with LHM's license(s) and/or rights. They shall take all reasonable steps to protect computer systems and software from unauthorized access or intrusion.
H. Any improper financial gain to an employee through misconduct involving misuse of LHM's or a resident's property is prohibited, including the outright theft of property or embezzlement of money.
I. LHM's confidential and proprietary information is valuable, and should be protected from unauthorized use or exploitation. Employees and agents are expected to respect the intellectual property rights of others with whom we do business.
J. Drugs and other pharmaceuticals shall be safely stored, secured, inventoried, and missing supplies shall be reported promptly to supervisors.
K. Employees and agents are expected to report any observed misuse of LHM's or residents/clients' property to management.
A. All employees and agents shall show proper respect and consideration for each other, regardless of position or station. Discriminatory treatment, harassment, abuse, or intimidation will not be tolerated.
B. Quality resident care can only be delivered through the use of qualified, competent staff. LHM will contribute to an employee's or agent's competence by making available continuing job-related education and training (within the limits of its resources).
C. Applicants and employees shall be afforded equal employment and advancement opportunities, pursuant to LHM's policies.
D. Employees and agents are expected to conform to the standards of their respective professions and exercise sound judgment in the performance of their duties. Any differences of opinion in professional judgment should be referred to appropriate management levels for resolution in accordance with standard grievance procedures.
E. Work and safety rules were created to protect us all. Employees and agents are expected to comply with those rules.
F. As defined further in its policies, LHM strives to maintain a working environment free from all forms of sexual harassment or intimidation. By way of example, unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature are serious violations of the standards of conduct and will not be condoned or permitted.
G. LHM promotes a drug and alcohol free workplace in accordance with its policies.
H. LHM shall not permit any action of retaliation or reprisal to be taken against an employee who reports a violation of law, regulation, standard, procedure, or policy.
Questions or comments about the above Code of Conduct for Lutheran Homes of Michigan may be directed to our Compliance Officer at compliance@LHMINC.org
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