Policy Manual sample

MDT Home Health Care Agency, Inc. CONFLICT OF INTEREST POLICY Scope: This policy applies to all affected and interested persons, as defined below, who are in positions that have influence over the affairs of MDT Home Health Care Agency, Inc. and who have a direct or indirect financial interest in MDT Home Health Care Agency, Inc.. Purpose: To establish MDT Home Health Care Agency, Inc. standards addressing conflicts of interest or unethical or unlawful practices and to ensure that health care, education, investment and other activities are conducted free from undue influence or the perception of such influence arising from outside obligations. Definitions: 1.“Affected person” refers to any employed or contracted: executive; administrators; department head in a leadership position within MDT Home Health Care Agency, Inc.; marketing and community liaison staff; referral sources, those on committees that recommend or approve services; those who recommend or approve investments by MDT Home Health Care Agency, Inc.; and consultants acting on behalf of MDT Home Health Care Agency, Inc. in any of the aforementioned positions. 2.“Interested person” refers to customers or patients, family members or paid caregiver, any MDT Home Health Care Agency, Inc. Board member or member of a Clinical or QAPI Department, all other committee members, or committee volunteers with board-delegated powers. If a person is an interested person with respect to any entity of which MDT Home Health Care Agency, Inc. is a part, he or she is an interested person with respect to all entities in MDT Home Health Care Agency, Inc. 3.“Conflict of interest (COI)” refers to a situation in which the personal and/or professional interests of a person performing duties on behalf of MDT Home Health Care Agency, Inc. might appear to influence the objectivity of that person in carrying out her/his official duty to MDT Home Health Care Agency, Inc. 4. “External compensation” refers to any direct or indirect remuneration in any form, including gifts, favors, loans or discounts when receipt is related to the performance of duties on behalf of MDT Home Health Care Agency, Inc.. Any kickback, bride to a referral sources, patients, clients, families is strictly prohibited. 5. “Immediate family member” – the following relationships constitute a family member: Spouse, partner or similar relationship Children ( and their spouses/partners) Parents Grandparents Grandchildren Siblings Legal Guardians Cousins Nieces Nephews Aunts Uncles Step and in-law relatives of all of the preceding categories 6. “Financial Interest” refers to a situation where an affected or interested person or his/her immediate family member has a financial relationship with MDT Home Health Care Agency, Inc.. In general a financial relationship is a direct or indirect ownership interest, investment interest or compensation arrangement with MDT Home Health Care Agency, Inc. and/or any entity that conducts transactions with MDT Home Health Care Agency, Inc.. Specifically for purposes of this policy, a financial interest includes: a. An ownership or investment interest in any entity or business in which MDT Home Home Health Agency Policies A-181