PROGRAM CODE OF CONDUCT
The Corporate Integrity Program is effective only if it has the full understanding
and support of all Bio¨Reference employees. Since the Code of Conduct is the core
of our Integrity Program, it is vital that all personnel read the Code of Conduct
carefully. The Code of Conduct clarifies the high standards of our professionalism
expected under the Corporate Integrity Program. A written version of our Code of
Conduct is necessary to ensure that all personnel share our commitment to producing
accurate high quality services in an honest and ethical fashion.
CODE OF CONDUCT
All personnel are required to adhere to the following Code of Conduct
Be straightforward and honest in all of your dealings. It is necessary to accurately
and thoroughly provide all information necessary to clients enabling them to fully
understand the services that Bio¨Reference offers and the full financial consequences
of these services to Medicare/Medicaid and other third party payers. Therefore,
when you prepare any document, never misrepresent any information, never make a
false statement, and never omit material information. Dishonesty is strictly prohibited.
It includes, but limited to, theft of services, theft of any materials belonging
to the company (even in small amounts) and employee time theft.
It is vital that you comply with all applicable laws and regulations. Therefore,
if any question should arise, it is your responsibility to consult with the Chief
Compliance Officer before engaging in the questionable activity.
Do not divulge any confidential BioReference information pertaining to: pending
or contemplated business transactions, trade secrets, or medical records. In particular,
the results of laboratory tests are considered strictly confidential and must not
be discussed with any persons without prior authorization.
According to the Stark Statute, there is an exception for compensation relationships
with physicians or physicianís family members, which involve de minimums amounts
of compensation. The exception applies only to non-cash items or services that do
not exceed $75 per gift and an aggregate of $380 per year if the entity providing
the compensation makes it available to all similarly situated individuals referring
patients to the entity for services, and the compensation is not determined in any
way that takes into account the volume or value of the physicianís referrals to
Therefore, as a general rule, do not accept and/or give gifts or favors to anyone
outside of BioReference that could influence actions or decisions pertaining to
BioReference. This does not preclude you from giving and/or accepting items of nominal
value that are clearly tokens of friendship or business hospitality.
Since there are not clearly defined answers under the law, if you have any questions
pertaining to the propriety of a gift, you must raise the issue with the Chief Compliance
Officer prior to giving any gifts of substantial value.
SALES AND MARKETING
Be honest and truthful in all representations that you make about BioReference and
never agree to give anything of value in return for referrals. Do not give anything
of value, including bribes, kickbacks, gifts in violation of the above rules.
Any technical question pertaining to the proper CPT code selection, remaining after
scrutiny from our technical employees should be directed to our Medicare Carrier.
In addition, billing employees are expected to make a concerted effort to handle
all credit balances (over payments) generated by the receipt of duplicate payments
in an expedient manner.
Phlebotomist must never provide free services in return for physicianís referrals.
Phlebotomist must never perform clerical or medical services that are normally the
responsibility of the physicianís office staff.
THE CORPORATE INTEGRITY
Read your departmentís employee training materials and attend your employee training
sessions when scheduled.
You are encouraged to voice any questions or concerns about the Integrity Program
to the Chief Compliance Officer, Howard Dubinett. In addition, you are expected
to report possible violations of the program to the compliance officer, either in
person, through an email, voice mail, regular U.S. mail or through our toll free
number 1 866 ITíS WRONG.