Policy Manual sample

MDT Home Health Care Agency, Inc. Health Care Agency, Inc. has a transaction or arrangement, including any entity, business, investment fund, convertible debt or equity investment in early stage companies, limited partnerships or joint ventures. b. A compensation arrangement with MDT Home Health Care Agency, Inc. or with any entity, business or individual with which MDT Home Health Care Agency, Inc. has a transaction or arrangement; or c. A potential ownership or investment interest in, or compensation arrangement with, any entity, business or individual in which MDT Home Health Care Agency, Inc. is negotiating a transaction or arrangement. 7. “Inurement” refers to an improper economic advantage that can accrue to an officer, director, or other insider (i.e., a person who is in a position to exercise substantial influence over the Agency’s affairs) of a charitable organization. Charitable organizations are prohibited from providing private inurement and can lose tax-exempt status if they do so. 8. “Vendor” refers to any existing or potential manufacturer, distributor, supplier or service organization, and their salespersons, representatives, or other employees. Policy: Affected and interested persons are required to maintain appropriate relationships with third parties, including patients and their families, health care practitioners, donors, suppliers, subcontractors and competitors so no third-party has an opportunity or appears to have an opportunity to inappropriately influence MDT Home Health Care Agency, Inc. decisions or activities. A COI occurs when an individual’s personal interests diverge from his or her professional obligations to MDT Home Health Care Agency, Inc.. When this occurs, an independent observer may reasonably question whether an individual’s professional actions or decisions are determined or affected by considerations of personal gain or benefit, whether financial or otherwise. Affected and interested persons shall report to the Agency a potential Confidentiality and Conflict of Interest Disclosure within application process or committee membership approval. Failure to disclose an interest in accordance with this policy may result in removal from a Committee or corrective actions for MDT Home Health Care Agency, Inc. employees, consultants or others as appropriate. Requirements 1. Required Disclosures: Affected and interested persons are required to disclose potential conflict of interest situations at application, initial service, or as Board Member on their annual disclosure form and on a situational basis for any situation occurring during the year. The following items are a non-exclusive list of items that must be reported: Ownership Relationships with Competitors: A direct or indirect (e.g., through a family member) financial interest in any business or health care enterprise that produces services or products which compete with those of MDT Home Health Care Agency, Inc.. Work Relationships with Competitors: A direct or indirect (e.g. through a family member) financial interest where salary or other remuneration is received as an employee, consultant, officer or board member) in any business or health care enterprise that produces services or products which compete with those of MDT Home Health Care Agency, Inc.. Relationships with Organizations Doing Business with MDT Home Health Care Agency, Inc.: A situation in which they directly or indirectly (e.g., through a family member) have any financial interest in any business or health care enterprise that does business with MDT Home Health Care Agency, Inc.. Home Health Agency Policies A-182