In addition, the PHT prohibits any employee from accepting, soliciting or receiving any gift having a value of more than fifty dollars ($50.00) from patients, relatives or friends of patients, or from firms or individuals doing business with or soliciting business from the PHT. In accordance with Miami-Dade County Code 2-11.1 (e) (3), it is the policy of the Public Health Trust (PHT) to prohibit employees from soliciting or demanding any gift. Receiving Business Courtesies from Patients, Affiliates, Vendors or Agents PHT/JHS does not seek to gain an improper advantage by offering business courtesies such as entertainment, meals, transportation or lodging to customers, referred sources, or purchasers of PHT/JHS services. PHT/JHS’s success as a health care provider results from providing quality services. Providing Business Courtesies to Patients or Sources of Affiliates, Vendors or Agents Advance Directive and Patient and Resident RightsĮmployees shall comply with all PHT/JHS policies and procedures and Federal and State laws and regulations governing advance directives and patient and resident rights. An individual may only be transferred from PHT/JHS to another facility in limited circumstances only after the individual has been stabilized and in accordance with the requirements set forth under governing Federal and State laws. PHT/JHS employees may not delay such treatment or the provision of an appropriate medical screening in order to inquire about the individual’s method of payment or insurance coverage. PHT/JHS will provide treatment to all individuals, regardless of the ability to pay, who have an emergency medical condition. Further, we are dedicated to ensuring that all bills are accurate and reflect current payment methodologies, that all patients and customers receive timely bills, and that all questions regarding billing are answered timely, accurately and directly. PHT/JHS is committed to ensuring that its billing and reimbursement practices comply with all Federal and State laws, regulations, guidelines and policies. Submitting a claim containing information you know to be false.Įmployees must be particularly careful to ensure that hours worked and costs incurred are applied to the account for which the effort was required.Filing a claim for services that were rendered but were medically unnecessary.Filing a claim for services that were not rendered at all or were not rendered as described on the claim form.Examples of the types of action that could violate the Federal False Claims Act and other Federal false billing laws include, but are not limited to, the following: PHT/JHS has adopted various policies designed to ensure compliance with Federal and State anti-kickback laws. Promptly refer any questions to the Compliance Office. These are highly complex areas of the law and employees must take special care in their respective area. In addition, there are laws that prohibit filing false claims. It is the policy of PHT/JHS to comply with applicable anti-trust, trade, and similar laws that regulate competition.įederal and state laws prohibit PHT/JHS and its employees from offering payments or any items of value to induce anyone to purchase services from or to refer a patient to PHT/JHS. In conducting all marketing and advertising, PHT/JHS will provide honest information to the general public. PHT/JHS has an affirmative duty to disclose current, accurate and complete cost and pricing data where disclosure of such data is required under appropriate Federal or State laws or other regulations. PHT/JHS is committed to providing services that meet all contractual obligations and PHT/JHS standards. PHT/JHS is committed to making employment decisions and providing services without regard to race, color, creed, national origin, political beliefs, sex, gender or sexual preference or in any way participate in any unlawful discrimination. Any actual or perceived violation of this Code must be immediately reported to the PHT/JHS Office of Compliance. All PHT/JHS employees must comply with all Federal, State, and local laws as well as all other government regulations.
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