Corporate Compliance Code of Conduct

The Code of Conduct (Code) is designed to assist you in making the right decision when you encounter situations involving legal or ethical issues in your daily activities. Obviously the Code cannot cover every aspect of your job.  When you are confronted with an unusual situation or you have any doubts about the right course to follow, always use your practical judgment. Other resources are available to answer your questions and concerns, such as your supervisor or your supervisor’s manager, Human Resources, the Compliance Officer and the Employee Hotline.  Our managers maintain an open door policy.    

Over the years, Virtua has established numerous policies and procedures to promote compliance with sound legal and ethical principles, which are not described in the Code.  Nothing contained in this booklet is intended to lessen the importance of adhering to these established policies and procedures.

The Code of Conduct is for all entities under the parent company, Virtua Health, Inc. and controlled entities, known as collectively as “Virtua.” The Virtua Code of Conduct pertains to the Virtua Health, Inc. and the controlled entities as follows:

  • Virtua - Memorial Hospital Burlington County, Inc
  • Virtua - West Jersey Health System, Inc. 
  • Virtua Memorial Burlington - Psych
  • Virtua Health and Rehabilitation at Mt. Holly
  • Virtua Health and Rehabilitation Center at Berlin
  • Virtua Home Care – Community Nursing Services
  • Virtua Home Care at West Jersey 
  • Virtua Health Foundation, Inc. 
  • Virtua Medical Group
  • Virtua Retail

Message from Virtua President and CEO

Dear Employee:


Virtua’s mission is to help people BE WELL, GET WELL and STAY WELL. Part of our commitment to the communities we serve is to provide services of the highest quality, to conduct our business according to the highest ethical standards, and to comply with all regulations.     

Virtua’s Code of Conduct outlines the expectations for meeting our rigorous standards. We must conduct our business activities in full compliance with all federal, state and local laws and regulations. The Code and Corporate Compliance Program are intended to guide and direct all employees, officers, board members and others who work at or are associated with our organization. Compliance is everyone’s responsibility.  

The Code helps us make the right choices when confronted with difficult decisions. Each of us has an obligation to know and to abide by the laws, rules, regulations, policies and practices that have specific application to our job. Our commitment to compliance remains the same, regardless of position within Virtua.  

Please read the Code carefully and completely, and promptly approach your manager with any questions.

If you have questions or concerns about a particular situation you are facing, there are a number of ways to seek assistance.  First, we hope you will feel comfortable discussing your question or concern with your supervisor.  If for any reason you do not wish to do so, or if your supervisor is not able to address your questions or concerns, you may contact your Human Resources Representative, the Compliance Officer, or call the confidential Employee Hotline at 
1-800-268-0502.

On behalf of the entire management team, I pledge my commitment that no retaliatory action will be taken against you for reporting a problem or concern in good faith to the Employee Hotline or through any other appropriate channel. We all have a personal obligation to identify issues and uphold the standards described in the Code.  

Managers have a special responsibility as part of the Corporate Compliance Program.  Our management team maintains an open door policy and is ready and willing to listen to any and all concerns, questions, suggestions that you many have regarding this Code, the Corporate Compliance Program or any other issue.

Thank you for your continued hard work and dedication.  

Sincerely,
 
Richard P. Miller
President & Chief Executive Officer

Employee Responsibility

You are expected to become familiar with and adhere to Virtua’s Code, and all relevant laws and regulations and Virtua’s policies and procedures that affect the performance of your job.  Compliance is everyone’s responsibility.  Your knowledge, or reasonable suspicion, of a violation of the Code, law or regulation, or any other Virtua policy and practice should be reported immediately.  Failure to report your knowledge of a violation may subject you to legal liability.  

You should never hesitate to ask a question or raise a legitimate concern.  Correspondingly, you should also be open and responsive to questions, complaints and concerns expressed by patients and the people you supervise or with whom you work.    

If you have any questions about the Code, a law or regulation, or any other Virtua policy or practice, you are encouraged to:

  • Talk to your supervisor.
  • Talk to another member of management.
  • Talk to your Human Resources representative.  
Most situations can be resolved at this level. If, however, your question or concern cannot be resolved at this level, you should report the matter to the Corporate Compliance Officer, or call the confidential Employee Hotline at (1-800-268-0502).

Non-Retaliation Policy

Virtua will not take any disciplinary action or treat an employee negatively for reporting in “good faith,” a concern, issue, problem, violation of law/regulation of the Code of Conduct to Management, Human Resources, the Compliance Officer or the Employee Hotline. “Good faith” means that you are telling the truth as you know it.  

Any employee who believes that he or she has been retaliated against for making a report should contact the Compliance Officer or call the Employee Hotline. Any manager or employee who retaliates will be subject to disciplinary action up to termination.

Virtua will also protect employees from the intentional misuse of the Employee Hotline. Deliberately making a false accusation is a serious violation of Virtua’s policy and may lead to disciplinary action, up to and including, termination of employment.

Virtua complies with the Deficit Reduction Act of 2005 – Section 6032, which details certain federal and state anti-fraud statutes and qui tam or whistleblower provisions. The policy is located on the VINE, under “Compliance Corner” and the Employee Handbook and on www.virtua.org.   

Patient Care

We are dedicated to providing high quality healthcare services that meet the needs and respect the rights of those we serve.  Any actual or perceived quality of care or patient rights issues should be reported to through the Management chain of command, Human Resources, the Compliance Officer or the Employee Hotline.  

  • We treat all patients with dignity and respect their right to privacy (refer to page 8 – Health Insurance Portability and Accountability Act).  We provide each patient with care that is both appropriate and necessary for the patient’s medical condition.

  • We render services to patients without regard to their sex, age, disability, race, color, creed, religion, national origin, veteran status, sexual orientation or ability to pay. We provide patients seeking emergency medical treatment a medical screening, and manage such patients in accordance with Emergency Treatment and Active Labor Act (EMTALA) regulations.   

  • We utilize personnel with proper credentials and experience in meeting the needs of our patients.  Upon request, we inform patients or their authorized representative of the identity  of all personnel who participate in their care.  

  • We maintain complete, accurate and legible accounts of all care and treatment provided to patients.   

  • We maintain strict confidentiality regarding individually identifiable health information and prevent the unauthorized release of such information.  Unless otherwise permitted by law, information contained in a medical record will not be released to anyone outside the organization without the individual’s consent or authorization. 

  • We respect every competent patient’s right to make his or her own healthcare decisions, including the refusal of medication or treatment after the possible consequences have been clearly explained. 

  • We support informed consent and communicate the benefits, risks and alternatives of diagnostic and therapeutic procedures, and the use of advance directives. 

  • We treat patients in the least restrictive environment appropriate to their individual needs.

Health Insurance Portability and Accountability Act (HIPAA)

We are dedicated to protecting the privacy of our patients by preserving the confidentiality and security of individually identifiable health information, whether or not such information is maintained electronically, in writing, is spoken or in any other medium.  Any actual or perceived violation of patient privacy, patient confidentiality or security should be reported to the Management chain of command, Human Resources, the Compliance and/or Privacy Officer or the Employee Hotline.


  • We will use and disclose individually identifiable health information for purposes of treatment, payment, or healthcare operations in accordance with Federal and State law.

  • We will provide written notices of our privacy practices, including descriptions of individual rights with respect to protected health information (such as the right to inspect, copy, amend, or correct their health records) and the anticipated uses and disclosures of this information that may be made without the patient’s written authorization. 
  • We will only view a patient’s personal health information on a need to know basis.  Whenever using, disclosing, or requesting protected health information, we will use reasonable efforts to limit the amount of individually identifiable information we use, disclose, or request to the minimum necessary to accomplish the purpose for which the use, disclosure or request is made.  
  • Before sharing any individually identifiable health information with a non-Virtua entity or individual, we will first verify that such entity or individual is a properly authorized business associate of Virtua or the disclosure is otherwise permitted by law.  
  • To the extent possible, we will ensure that our business associates provide us with satisfactory assurance that they will safeguard and keep confidential, our patient’s individually identifiable health information in accordance with HIPAA. 
  • When providing information to a directory (such as a patient directory maintained in a hospital) or to the next of kin or other person involved in the care of the patient, reasonable efforts will be made for the patient to be given notice and the opportunity to decline prior to the information being disclosed. 
  • By law, we treat designated patient information, such as mental health notes, substance abuse and HIV/AIDS, with the strictest of confidence and will not release or disclose such information without the patient’s prior written consent or by valid court order or as otherwise permitted by law.
  • We will take reasonable efforts to protect patient information when transmitting electronically.

Laws and Regulations

We conduct our business activities and patient care operations in full compliance with all applicable federal, state, and local laws and regulations.  Any actual or perceived violation of a law, regulation or our professional standards should be reported to the Management chain of command, Human Resources, the Compliance Officer or the Employee Hotline.  

  • We provide services that are appropriate and safe, and conduct our business affairs in compliance with all applicable laws, regulations and professional standards. 

  • We will not solicit, accept, give or offer anything of value to physicians or other healthcare providers for the referral of patients or services which may be paid by a federally funded healthcare program.  Kickbacks, bribes, rebates or any kind of benefits intended to induce referrals or in return for referrals are strictly prohibited. 

  • We compensate healthcare professionals and other providers at fair market value and only for documented services provided.  

  • We never pursue a business opportunity that is illegal.  Vendors are verified for participation in the Medicare program.    

  • We do not share or discuss proprietary information such as pricing, market information or contractual arrangements with someone from a non-affiliated healthcare organization or divide, or attempt to divide, territories or customer lists with competitors.  

  • We conduct our marketing efforts with truth, accuracy, fairness and responsibility to patients, the communities we serve, and the public at large.  Marketing materials reflect only those services available, the level of licensure and accreditation, and comply with applicable laws and regulations dealing with truth in advertising, non-discrimination and confidentiality. 

  • We record all financial information in accordance with generally accepted accounting principles and established financial procedures and internal controls.  

  • We do not tolerate the making of false or misleading statements to any government agency, healthcare program or payer source.  

  • We cooperate with all appropriate requests for information from government auditors, investigators or other officials.  Examples include: Department of Health and Human Services, Office of Inspector General, Centers for Medicare and Medicaid (CMS), and Department of Labor.  If an employee is contacted by an organization, the employee should contact their manager immediately.  If the manager is unavailable, employee should contact General Counsel, Privacy Officer or Compliance Officer.

  • All contracts, business arrangements and affiliations entered into will be in compliance with all applicable laws, regulations and professional standards.  

  • When performing work under a federal or state government contract or subcontract, we will comply with all applicable laws, regulations and operational policies and procedures.  Any question or concern about the appropriate course of action in a government contracting scenario should be referred to Management, Human Resources or the Compliance Officer.

Billing and Coding

We are committed to properly coding and billing for the services we render in accordance with all applicable regulations. Any actual or perceived billing or coding irregularity should be reported to the Management chain of command, Human Resources, the Compliance Officer or the Employee Hotline.  
 
  • We bill only for those services and care which are actually provided, medically necessary, appropriately authorized, and properly documented.   

  • We use billing codes that most accurately describe the services and care provided.  Upcoding or improperly bundling charges to increase reimbursement is strictly prohibited. 

  • We prepare and maintain all billing records accurately, reliably, honestly, and in accordance with established accounting and billing policies and practices.

  • We will not tolerate the submission of any claim for payment or reimbursement that is false, fraudulent, fictitious, or is grossly misleading or inaccurate.

  • We regularly check for credit balances and promptly refund any overpayments.

  • We make reasonable attempts to collect all deductibles and co-payments. 

  • We strictly prohibit the premature destruction or the alteration of any document in response to, or in anticipation of a request for those documents by any government agency or court.

  • We require that our employees are made aware of the laws and regulations pertaining to billing and coding.  In this respect, we take responsibility for the training and education of our employees so that they may properly perform their duties.

  • We conduct internal and external audits to ensure compliance with coding and billing regulations.   

  • We will submit annually a Medicare and Medicaid cost report to governmental intermediaries in order to review and settle payment differences. 

Conflicts of Interest

We take all reasonable precautions to avoid conflicts, or the appearance of conflicts, between our private interests and the performance of our official duties and responsibilities. Any actual or perceived conflict of interest should be reported to the Management chain of command, Human Resources, the Compliance Officer or the Employee Hotline.  

  • We do not tolerate any business or financial opportunity, which might conflict, or appear to conflict, with the interests of Virtua or those we serve.  A conflict exists whenever a trustee, officer, physician or employee (or a related party such as a business or family member) may receive a financial benefit from any decision or action that he/she takes. 

  • We will report to the above mentioned, any conflicts of interests concerning ourselves, family members or business interests when known.  Family members include spouse, parents, grand-parents, siblings, children, grandchildren, aunts, uncles, niece, nephew and first cousin, in-law, whether by birth, marriage or residence and other persons living in the same household.

  • We do not permit family members to be in a direct reporting relationship to each other. We review other employment situations involving family members, and reserve the right to transfer employees if a conflict exists.   

  • We do not solicit or accept gifts, payments, fees, services, valued privileges or other favors where these would, or might appear to, improperly influence the performance of our official duties.  Questions regarding the acceptance of an unsolicited gift, entertainment or other favor of nominal value (greater than $50) should be discussed with your manager, Human Resources, the Compliance Officer or the Employee Hotline.  

  • We do not use our position to secure a special discount or other favorable treatment (e.g., not available to all employees) from a person or outside organization which does or is seeking to do business with Virtua.

  • We do not use our position to influence personal decisions of our staff.   

  • Virtua Board Members, senior management and other individuals with purchasing authority and/or influence over vendor or product selection disclose annually any direct or indirect business relationship or investment in Virtua.  Disclosure also includes compensation, remuneration, and gifts, gratuities or favors that are of a material or substantial nature received by Virtua.    

Property, Equipment and Other Assets

We protect all assets that are entrusted in our care. Any actual or perceived loss, theft or misuse of Virtua’s property or the assets of others should be reported to the Management chain of command, Human Resources, the Compliance Officer or the Employee Hotline.  
 
  • We personally are responsible and accountable to ensure, including the access and security of our systems and our facilities, the proper business use of all Virtua funds, property and equipment in general and, in particular, that is entrusted to our care.  All users of the computer system acknowledge the proper use each time the computer is accessed. 

  • We follow established internal control procedures when handling and recording Virtua’s funds, property and equipment. The responsibility for physical security of laptops and portable computing devices and information contained within resides with the individual to whom the device is allocated.   Prior to leaving the employment of Virtua, individuals must return all Virtua owned property.

  • We do not copy or disclose any Virtua information or publications which are not intended for public distribution (i.e., policies & procedures, facility listings, organizational charts, employee, patient and provider information, etc.) to unauthorized persons either within or outside of Virtua.

  • We strictly prohibit making unauthorized copies of any computer software licensed to Virtua, including downloads or executables from the Internet.  Executable software must be validated, approved and installed by Information Services. Unmanaged installations can compromise the operating environment and also constitute a security risk, including the intentional or unintentional spreading of software viruses and other malicious software.

  • We will report any Virtua lost or stolen equipment or any personally owned devices that maintain Virtua data to the IT Help Desk at the time of the loss.

  • We respect and protect the intellectual property rights of individuals and companies with which we do business. We do not make copies or use this property without advance written permission. 

  • We understand that any research or product developed on Virtua’s time or equipment, whether intellectual or physical, is the property of Virtua. 

  • We do not permit the use of Virtua funds, equipment and facilities to support a political party, candidate or holder of any government position.  We limit our efforts to influence legislation to those activities, which are, in the opinion of our General Counsel, appropriate and in the best interests of Virtua and those we serve. 

  • We have established appropriate Email, Internet and Password Control policies and procedures outlining proper use.

  • We will maintain records in accordance with regulatory and accrediting agency record retention requirements regarding the appropriate time periods for maintenance and location of records. We will not prematurely destroy records.     

  • We require employees to accurately record their time as the basis of payment for hours worked. Time is recorded either on an electronic, telephonic or written basis, depending upon the location or needs of the department or entity.   We will reimburse employees for business expenses incurred as provided for in Virtua’s Employee Business Expense Policy.  We will pursue recovery for any overpaid and/or misappropriated funds.

Health and Safety

We are committed to maintaining a safe and healthy working environment which complies with all relevant laws and regulations. Any actual or perceived health or safety issue should be reported to the Safety Officer, the Management chain of command, Human Resources, the Compliance Officer or the Employee Hotline.  
 
  • We will comply with state and federal laws as it pertains to maintaining a safe working and service environment.  We immediately report any unsafe acts or circumstances which may create an unsafe condition.    

  • We handle and dispose of hazardous materials and waste, and regulated medical waste in accordance with all applicable laws and regulations.

  • We take all reasonable precautions to ensure our safety as well as the safety of patients, visitors and co-workers.  This includes employing “standard precautions” at all times.

  • We strictly prohibit unauthorized weapons of any kind on Virtua premises.

  • We do not tolerate the unlawful manufacture, distribution, dispensation, possession or use of a controlled substance on any Virtua premises.  We, moreover, will not tolerate the use of alcohol in the workplace, on Virtua time, and/or on Virtua  property, except at Virtua  sponsored events.  Suspected violators will be immediately relieved of their current duties and may be requested to undergo drug and alcohol testing.  

  • We immediately report to a manager all accidents involving injury to a patient, employee or visitor.  After the appropriate person(s) is notified, incident reports are completed promptly.

  • We are responsible for being knowledgeable about and strictly following emergency, safety and security plans and procedures.  Emergency preparedness and safety training is provided to all employees on a regular basis.  

  • We provide education on equipment and supplies. We proactively upgrade equipment and supplies to maintain state-of-the-art patient care.      

  • We have established procedures to eliminate access to Virtua facilities and other proprietary information when employment at Virtua is ended. 

Human Resources

  • We seek to treat all applicants and employees fairly and equitably, and in accordance with all relevant governmental rules and regulations. Any actual or perceived mistreatment, discrimination, hostile activity, or legal violation which occurs in the workplace should be reported through the Management chain of command, Human Resources, the Compliance Officer or the Employee Hotline.  
  • We comply with all employment rules and regulations set forth by federal, state and local governments.
  • We maintain a work environment that respects the rights, dignity and diversity of our employees. Harassment or any other form of physical, verbal or mental abuse will not be tolerated.  
  • We adhere to the Code of our professions and exercise reasonable judgment and care in the performance of our duties.
  • We treat employees in accordance with Virtua policies and/or collective bargaining agreements or employment agreements, if applicable.  A Dispute Resolution/Grievance Process is available to all regular staff employees to deal with unresolved, employment-related concerns or issues. 
  • We provide everyone with equal employment and advancement opportunities regardless of race, color, creed, religion, sex, age, marital status, national origin, ancestry, veteran status, sexual orientation or disability.  
  • We never discuss information contained in another employee’s personnel file unless we are authorized or legally required to do so.
  • We strive to understand and address issues which may cause employees to leave the organization.  We may conduct exit interviews upon or after an employee’s termination of service.
  • We maintain staff competencies by means of credential checks, education and training, and adherence to accreditation and licensing procedures. 
  • We have a No Solicitation and Distribution policy to protect the rights of every employee and to assure no interference with patient care.
  •  We conduct criminal background investigations, reference checks and verify applicants’ highest level of education as well as participation in the Medicare and Medicaid programs on external applicants for employment.

  • We maintain a drug-free and tobacco free work environment.
  • We provide uninterrupted patient care while recognizing, respecting and resolving any conflicts resulting from an employee’s personal cultural values, ethics or religious beliefs.
         
  • We will not conduct any games of chance without the appropriate licenses.

Communication

We encourage open and candid communication, and we respond to issues and concerns in a timely manner. Any actual or perceived communication problem should be reported through the Management chain of command, Human Resources, the Compliance Officer or the Employee Hotline.  
 
  • We inform employees of their duties and responsibilities, and provide timely feedback about their performance. Written performance reviews are conducted after 90 days of employment and annually.  Feedback concerning performance is provided on an on-going basis.

  • We are committed to transparency, accuracy and honesty in our communications.

  • We share ideas and treat all opinions with respect and consideration.

  • We practice an “open door policy” which encourages employees to raise legitimate questions or concerns to their immediate supervisor or another member of their facility’s management. 

  • We respond to questions and concerns in a timely manner.  If we are unable to address a question or concern in a reasonable time frame, we refer the individual to the proper source for response. 

  • We respect every patient’s right to voice his or her opinion about the care and services he or she receives.

  • We solicit employees’ feedback to implement changes to maintain high employee engagement and customer loyalty.  This includes, among other opportunities, participation in the Employee Engagement Survey, Town Hall Meetings, EAG and LECT committees and shared governance teams as well as campus and departmental staff meetings. 

Corporate Compliance Program

Virtua implemented the Corporate Compliance Program in February 1999.   Virtua has a Corporate Compliance Officer to oversee the day-to-day operations of our Corporate Compliance Program. The Program elements, as recommended by the Office of Inspector General (OIG), are as follows:  

  • We establish and maintain standards of conduct through the Code of Conduct. 

  • We report to the Audit and Compliance Committee of the Virtua Board of Trustees on all compliance related issues.  

  • We develop and conduct training programs to instruct employees in compliance-related decision making. 

  • We oversee the operation of the Employee Hotline as a mechanism to receive concerns. 

  • We review problem areas identified by callers to the Compliance Officer and the Employee Hotline, and consistently enforce standards through appropriate interventions and/or disciplinary mechanisms.

  • We establish auditing and monitoring mechanisms in accordance with the Office of Inspector General’s Workplan to ensure compliance. 

  • We respond to detected violations of standards, laws, and regulations and work to prevent future similar occurrences.

  • We will verify that all employees, medical staff and vendors are permitted to participate in the Medicare/Medicaid programs.  

Employee Hotline

Virtua strongly encourages all employees to discuss their question or concern using the management chain of command, beginning with your supervisor, prior to calling the Employee Hotline.  A toll-free Employee Hotline is available to you when you have a question or concern and do not feel comfortable discussing the matter with your supervisor, manager, Human Resources representative or the Compliance Officer.  Calls to the Employee Hotline are answered by an outside company with trained personnel 24 hours a day, 7 days a week. Calls are not traced or recorded. 

Information from your call will be communicated to the Compliance Officer for review, follow-up and response.  Your request for information or action will be handled promptly and professionally.  All reports of improper conduct will be investigated.  No disciplinary action will be taken solely on the basis of a hotline report (e.g., innocence is presumed).   

All calls are kept confidential to the extent permitted by law.  Although you are encouraged to identify yourself, you may make an anonymous report.  However, if you tell others (i.e., co-workers, friends, etc.) about your call, your anonymity and confidentiality cannot be guaranteed.  

You also may make a follow-up call to learn what action was taken on your report.  If you make an anonymous report, you will be given a “pin” number, which will permit you to make a follow-up call and learn about the action taken. 

To reach the confidential Employee Hotline, call:

1-800-268-0502, 24 hours a day, 7 days a week. 

Or call or email the Compliance Officer:

Susan Hatch
Virtua 
856-355-0722
Shatch@virtua.org
ComplianceOfficer@virtua.org