Corporate Compliance & Privacy Practices
CORPORATE COMPLIANCE PLAN SUMMARY
Adopted By The Managers - 2/17/11
Vibra Healthcare, LLC's ("Vibra") Corporate Compliance Plan has been developed in accordance with applicable law and policies issued by state and federal authorities. Through the Plan, Vibra will promote full compliance with all legal duties applicable to it and its employees, foster and assure ethical conduct, and provide guidance to each employee and agent of Vibra for their conduct. The procedures and standards of conduct contained in the Plan are intended to generally define the scope of conduct which the Plan is intended to cover and are not to be considered all-inclusive.
The important provisions of Vibra's Corporate Compliance Plan are summarized in this brochure. If you have any questions regarding these provisions, or wish to view a full copy of the Plan, please contact your Facility Compliance Coordinator or the Vibra Corporate Compliance Officer.
CORPORATE CODE OF CONDUCT
Vibra has a reputation for conducting its activities in accordance with the highest level of business and community ethics, and in compliance with applicable governing laws. The maintenance of extremely high standards of honesty, integrity, impartiality, and conduct is essential to assure the retention of the patients’ and the public’s trust in Vibra. The preservation of that trust and of Vibra’s reputation requires close observance of these standards on the part of its Managers, Officers, employees and agents. Vibra is committed to ensuring that it operates under the highest ethical and moral standards, and that its activities comply with the applicable legal requirements in this Plan.
Vibra has developed a Code of Conduct to provide standards by which all Vibra employees will conduct themselves in order to protect and promote organization-wide integrity, and to enhance Vibra’s ability to achieve its mission. Compliance with the Code of Conduct will be the responsibility of every manager, officer, employee, agent or representative of Vibra. Vibra's Code of Conduct provides the guiding standards for our decisions and actions as members of the Vibra community. The Code cannot cover every situation in the daily conduct of our many varied activities nor substitute for common sense, individual judgment or personal integrity. Listed below are the guiding principles of Vibra’s Code of Conduct.
Principle 1: Integrity. Vibra will strive to ensure integrity in all activities conducted by or on behalf of the organization, and promote honesty in all levels of interaction within the organization.
Principle 2: Legal Compliance. Vibra will strive to ensure all activity by or on behalf of the organization is in compliance with applicable laws.
Principle 3: Business Ethics. Employees, officers and managers will accurately and honestly represent Vibra and will not engage in any activity or scheme intended to defraud anyone, including federal, state or local governments, of money, property or services.
Principle 4: Confidentiality. Vibra employees shall strive to maintain the confidentiality of patient and other confidential information in accordance with applicable legal and ethical standards.
Principle 5: Conflict of Interest. All managers, officers, and other representatives must avoid potential conflicts of interest. A potential conflict exists whenever a manager, officer or other representative has an outside interest, direct or indirect, which conflicts with the individual’s duty to Vibra or adversely affects the individual’s judgment in the discharge of his or her responsibilities to Vibra. The appearance of a conflict of interest may be just as damaging to Vibra’s reputation as a real conflict.
Principle 6: Business Relationships. Business transaction with ancillary providers, vendors, contractors and other third parties shall be transacted free from offers or solicitation of gifts and favors or other improper inducements in exchange for influence or assistance in a transaction.
Principle 7: Protection of Assets. All employees will strive to preserve and protect Vibra’s assets by making prudent and effective use of Vibra resources and properly and accurately reporting its financial condition.
Principle 8: Reporting Suspected Misconduct. All managers, officers, employees and agents have an affirmative obligation to report suspected violations of any statute, regulation, or guideline applicable to any Federal health care program or of Vibra’s own Policies and Procedures.
Principle 9: Relationships with Patients. In furtherance of Vibra’s commitment to its standards of care, employees and agents will demonstrate professionalism, integrity and respect in relating to patients.
CORPORATE COMPLIANCE OFFICER AND COMMITTEE
Vibra's Corporate Compliance Plan will be implemented under the guidance and supervision of the Corporate Compliance Officer and a Committee consisting of the upper-level Managers of the organization. In addition, each Vibra facility will have its own Facility Compliance Coordinator to help put the Plan's provisions into practice. These individuals will be responsible for developing policies and practices designed to ensure that each Vibra facility meets the compliance standards set forth in the Plan. The Facility Compliance Coordinators and the Corporate Compliance Officer will be accessible to all Vibra employees.
TRAINING AND EDUCATION
The key to maintaining compliance with applicable law is to ensure that Vibra personnel receive training and education to enable them to identify potential fraud and abuse issues, and conform their conduct to the applicable requirements of law. The Plan requires Vibra to provide employees with the training necessary to ensure compliance with applicable federal and state laws and regulations. Accordingly, Vibra will schedule periodic and annual training for employees on the requirements of the Plan itself, as well as other substantive areas relating to their job functions.
POLICIES, PROCEDURES AND PROTOCOLS
Vibra and its Facilities have already adopted numerous policies and procedures to provide the best care possible to our patients and to ensure that operations are conducted in accordance with law. Those policies will continue to remain in place under the Plan. The Corporate Compliance Officer and the local Facility Compliance Coordinators will also coordinate the development of specific policies designed to address recordkeeping, contracting, billing, reimbursement and clinical issues as well. Vibra's policies and procedures will be regularly reviewed to assess their effectiveness. When appropriate or required, the Corporate Compliance Officer will direct revisions to these policies and procedures to correct errors, to make operations more efficient, or to improve the quality of care provided to our patients.
COMPLIANCE REPORTING OBLIGATIONS AND INVESTIGATIONS
As reflected in the Code of Conduct, each and every employee of Vibra is required to report all instances of suspected misconduct or potential violations of law to the Corporate Compliance Officer. This can be done anonymously through the Hotline established by Vibra. The Hotline number is 888-238-7185. Employees may also report potential compliance issues to their supervisors or the Facility Compliance Coordinator. Vibra's Corporate Compliance Officer will review all reports received by the company, and will conduct an appropriate investigation into all instances of claimed misconduct or noncompliance. Vibra employees are required, when requested, to assist the Corporate Compliance Officer in these investigations. At the conclusion of an investigation, the Corporate Compliance Officer, in conjunction with Vibra's legal counsel, will implement corrective action initiatives and, where required, make the appropriate disclosures to governmental agencies. It is important to emphasize that Vibra will not tolerate retaliation against employees or agents who report suspected abuse in good faith, nor will Vibra allow abuse of its reporting processes.
SELF-MONITORING AND AUDITING
Vibra recognizes the need to monitor and audit its operations to determine the effectiveness of this Plan’s implementation and the company's overall compliance with applicable law. The Corporate Compliance Officer will supervise all auditing systems, conducting periodic and annual audits of Vibra's facilities and its employees. Audit procedures will be implemented which are designed to determine accuracy and validity of coding and billing submitted to Medicare and other federal health programs, to ensure compliance with Medicare Conditions of Participation, and to detect other instances of potential noncompliance by Vibra employees and agents as quickly as possible. Auditing techniques will include on-site visits, mock surveys, sampling reviews of claim submissions, and interviews of key personnel. Each audit will generate a Compliance Report, which shall be forwarded to the Corporate Compliance Committee and the Vibra Managers for review and action.
EMPLOYEE, OFFICER AND MANAGER DUTIES UNDER THE PLAN
Promotion of and adherence to the Plan shall be an element of each Vibra employee’s performance standards. Each employee’s compliance performance will be taken into account in connection with performance evaluations. Managers and supervisors have the additional responsibility to ensure that persons under their supervision are advised of their responsibilities under the Plan and under applicable laws and regulations. Conduct in violation of this Plan is outside of the scope of an employee’s job responsibilities and authority and may subject the employee to disciplinary action, including suspension, imposition of monetary penalties or termination. Appropriate disciplinary measures shall be imposed on a case-by-case basis, and shall be consistent with the disciplinary scales contained in the Employee Handbook.
MOST IMPORTANT CONCEPTS UNDER VIBRA'S CORPORATE COMPLIANCE PLAN
Be honest, tell the truth and act in accordance with the provisions of Vibra's Code of Conduct. There are consequences for failing to do so.
Be aware of the laws and regulations that govern your job responsibilities and follow them. Ask questions if unsure of the applicable legal requirements before taking action.
Report suspected misconduct or potential compliance issues to your supervisor, the Facility Compliance Coordinator, or the Corporate Compliance Officer through the Hotline at 888-238-7185.
Assist in the development of policies and procedures designed to enhance Vibra's operations and fully cooperate in all self-auditing and monitoring activities.
Participate in Vibra's educational training sessions on compliance.
Make compliance a part of your day-to-day job performance.
COMPLIANCE HOTLINE NUMBER