Policy Manual sample

MDT Home Health Care Agency, Inc. BOARD OF DIRECTOR CONFLICT OF INTEREST PURPOSE: To establish a procedure to identify potential conflict of interest for Board of Directors and staff. POLICY: The agency is responsible to the community it serves. If a member of the Board of Directors or an employee could derive profit or gain through association with the agency, the objectivity or legality of that member or employee could be questioned and a charge of self-dealing could be made. PROCEDURE: · All Board members are required to submit a disclosure statement at the beginning of each fiscal year. (See INDIVIDUAL STATEMENT REGARDING CONFLICT OF INTEREST in this Chapter) · A Board member or employee should report immediately to the Board of Directors or President any matter that arises in which the member or employee has a conflict of interest. · In matters involving a conflict of interest, a Board member or employee must disclose any known significant reasons why a transaction might not be in the best interest of the agency. The member may not participate in discussion unless requested by the Board or vote on such transactions. His/her abstention and the reason for it will be recorded in the committee and/or Board minutes. · In addition, the Medicare-certified home health agency must have evidence of annual disclosure, which includes the following information: · Names and addresses 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. · The persons in (A) above who are related as spouse, parent, child or sibling. · The persons in (A) with an ownership or controlling interest in a Medicare or Medicaid facility. · The names and addresses of any officer, director or partner. · Conviction of any criminal offense involving Medicare, Medicaid or Title XX programs on the part of any person or organization in (A) and (C) above or on the part of any agent or managing employee of the agency. · 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. · Any changes within the previous year in Administrator, Director of Operations or Medical Director, if applicable. · The dates of the following: any change in ownership or control during the previous year or any anticipated changes in the coming year; any anticipated bankruptcy filings; and any changes in operations by a management company or leasing in whole or in part by another organization. · Change of address for parent, subunits or branches. Home Health Agency Policies A-40