Policy Manual sample

MDT Home Health Care Agency, Inc. STATEMENT OF PRINCIPLE RELATING TO DISCLOSURE OF CONFLICTS OF INTEREST No employee or member of the Board of Directors, or other individual committee, or entity shall derive any profit or gain directly or indirectly by reason of their association with the Agency, without the prior knowledge and approval of the Board of Directors. All board members and/or employees, at the discretion of the board, will be required to submit a disclosure statement annually. Full and prompt disclosure to the Board of Directors will be made of any transaction, situation, or event which may place a person(s) in a position in which his or her family, partner or business associate is in conflict with the interest of the Agency. Full disclosure will be made of the names and addressed of individuals or corporations having a combined direct or indirect ownership or controlling interest of 5 percent or more in the Agency or in any subcontractor in which the Agency has a direct or indirect ownership interest of 5 percent or more. Disclosure must be made of conviction of any criminal offense involving Medicare, Medicaid or Title XX programs on the part of any person on the Board of Directors and on the part of any agent or managing employee of the Agency. Disclosure must be made of the names and addresses of any current employees in managerial, accounting, auditing, or similar capacity who were employed by the Agency’s Medicare fiscal intermediary within the previous twelve months. Change of address for parent, subunits or branches must be promptly disclosed. Purchases, sales, leases or other contractual arrangements to, from and with the Corporation shall, except as hereinafter specified, be considered as involving potential conflict, which should be disclosed. Gifts or other favors offered, or received, shall be disclosed. No officer, Director or employee of the Corporation shall have any personal financial interest, direct or indirect, in any contract relating to the business conducted by the Corporation, or the furnishing of supplies or equipment to the Corporation, unless authorized by the concurring vote of two-thirds of the Board of Directors. In matters involving a conflict of interest, a board member must disclose any known significant reasons why a transaction might not be in the best interest of the Agency and a board member shall not participate in discussions unless requested by the board not vote on such transactions. The abstention and the reason for it shall be recorded in the minutes. A director, officer or employee in a policy making position of the Corporation will not, however, be considered to have a conflict of interest with the Corporation if he/her or any member of his/her family: 1. Is an officer, director or employee of a Bank, Savings and Loan Association, or company in which the Corporation has funds on deposit or invested in shares of stock: 2. Is or has been employed (or a member of his family or partner is or have been employed) with the approval of the Board of Directors to render legal, accounting, or other professional services to the Corporation on a fee basis. Home Health Agency Policies A-94