INTEGRITY: High standards of business and professional ethics and honesty
INTEGRITY: High standards of business and professional ethics and honesty

STANDARD OF CONDUCT: COMPLIANCE WITH LAWS

OUR COMMITMENT

We are committed to high standards of business and professional ethics and integrity. We will provide patient care and conduct business while following all applicable federal, state, and local laws and regulations.

YOUR RESPONSIBILITIES

  • To promptly report to your supervisors or to the Office of Corporate Compliance any actual or suspected violation of a law, a regulation or a Harris Health policy.
  • To bill payors and patients in accordance with the Federal False Claims Act and the Texas Medicaid Fraud Prevention Act.
  • To never offer, provide, solicit, or receive kickbacks, bribes, rebates, or anything else of value in order to influence the referral of patients or services payable by a government healthcare program in violation of the Anti-Kickback Statute. For more information, please see Harris Health Policy 3.31, Preventing and Reporting Fraud, Abuse, and Wrongdoing.
  • To neither hire nor contract with individuals who have been sanctioned by the Office of the Inspector General of the U.S. Department of Health and Human Services (OIG) or barred from participating in federal and/or state procurement programs.
  • To accept patients based on the patient’s clinical needs and our capacity to render those services and to always comply with the requirements of the Emergency Medical Treatment and Active Labor Act (EMTALA) when individuals seek emergency treatment by ensuring that all patients who present to a Harris Health emergency center receive a medical screening exam and have his or her emergency medical condition (if one exists) stabilized or coordinating the transfer of the patient.
  • To ensure and validate that all workforce members who provide patient care are properly licensed and trained.
  • To ensure that confidential information, including protected health information, is only used and disclosed in accordance with the law.

FAQs

My director and administrative director have told me and my coworkers that we should not contact the Office of Corporate Compliance when we discover non-compliant behavior or inappropriate practices. Instead, we were told that we should contact one of them and only them. Is this okay?

Absolutely not. While it certainly is okay for you to discuss non-compliant behavior or inappropriate practices with your supervisors, you should also always report that behavior to the Office of Corporate Compliance, unless your supervisor is reporting the issue himself or herself.

If a patient is seeking treatment in a Harris Health emergency center but is being disruptive, may Harris Health ask the patient to leave the premises?

Harris Health may ask a disruptive patient to leave an Emergency Center only after the patient has had a medical screening exam completed by a QMP and it has been determined that the patient does not have an emergency medical condition. In almost all cases, it is never appropriate to ask a patient to leave an emergency center prior to receiving a medical screening exam.

POLICIES TO KNOW

  • Harris Health Policy 3.31 Preventing Fraud, Abuse, and Wrongdoing
  • Harris Health Policy 3.58, Non-Retaliation for Reporting Fraud, Abuse, and Wrongdoing
  • Harris Health Policy 3.56, EMTALA Screening, Stabilization, and Transfer
  • Harris Health Policy 3.35, Sanction Screening for Ineligible Persons