Policy Manual sample

MDT Home Health Care Agency, Inc. conflict of interest, the Agency Administrator, working in conjunction with the affected person’s department and the appropriate executive will decide whether a conflict of interest exists. B Violations of the Conflict of Interest Policy – Affected Persons 1. If any person has reasonable cause to believe that an affected person failed to disclose an actual, perceived or potential conflict of interest, that person shall inform the Agency Administrator of the basis for such belief. The Administrator will investigate and afford the affected person an opportunity to explain the alleged failure to disclose. 2. If, after hearing the response of the affected person and further investigating as may be warranted, the Administrator determines that the affected person has in fact failed to disclose an actual, perceived or potential conflict of interest, he may request that the appropriate executive take corrective or disciplinary action. a. An affected person will be terminated or suspended as an employee or will have their contractual arrangement terminated or suspended in accordance with contractual terms for intentionally failing or refusing to complete the required conflict of interest disclosure form or for violating MDT Home Health Care Agency, Inc.’s confidentiality or conflict of interest requirements. b. An affected person who receives a gift, favor, or other service or thing of value from any Vendor when in a position to influence the conduct of business of that person with MDT Home Health Care Agency, Inc. will be subject to corrective action by the appropriate executive. c. Other corrective actions may be taken based on the severity of the conflict of interest. 3. The Administrator must document the name of the affected person, the nature of the interest or conflict, the process taken to determine whether a conflict was present, the final decision as to whether a conflict of interest in fact existed, and any corrective or disciplinary action that was taken. C Duty to Disclose — Interested Persons In connection with any actual or possible conflicts of interest, an interested person must disclose the existence of his or her financial interest and must be given the opportunity to disclose all material facts before admitted to the Agency (clients, patients, family members), to the chairs/directors and members of committees with board delegated powers considering the proposed transaction or arrangement. The Administrator is responsible for ensuring compliance with this requirement for all committee boards. 1. Disclosures Required upon admission or appointment: All interested persons are required to report Conflict of Interest Disclosure at time of Admission or when/before was appointed as any committee member. 2. Situational Disclosures: An interested person with any actual, perceived or potential conflict of interest must disclose such interest verbally to the staff assigned (patients, clients, family), and directors and members of the appropriate Committee that is considering a decision, transaction or arrangement that may be in conflict. An interested person who receives a gift, favor, or other service or thing of value from any Agency’s employee, contractor or administrator at admission/referral process, or as committee member when in a position to influence the conduct of business of that person with MDT Home Health Care Agency, Inc. will be subject to corrective action by the appropriate executive, that may include report to authorities is bride is identified, or in case of committee members separation of this duties. Home Health Agency Policies A-184