Help at Home Has a Strong Record of Compliance
Our ethics and compliance program includes auditing and monitoring, enhanced lines of communication between the Chief Ethics & Compliance Officer and employees, consistency in the standards we set for ethics and compliance and increased awareness of these standards through a robust training and education program.
Below you will find more information about our program and company-wide resources:
Our ethics and compliance program was developed to help ensure that we conduct our business in compliance with all applicable federal and state laws and rules and regulations, and to reduce the risk of misconduct. According to the Office of Inspector General (OIG), a well-built compliance program should have a strong foundation that includes the following seven elements:
- Written policies, procedures, and standards of conduct
- Designated compliance officer and compliance committee
- Effective training and education
- Reporting and investigating: effective lines of communication
- Enforcement and discipline: well-publicized disciplinary guidelines
- Strong internal monitoring and auditing program
- Response and prevention: prompt response to detected offenses
To follow the OIG guidelines, we have developed an ethics and compliance program that consists of the following elements:
- Development, distribution, and routine review and update of the Code of Conduct & Ethics (“Code”), as well as policies and procedures that promote Help at Home’s commitment to ethics and compliance and address specific areas of risk to the organization
- Designation of a Chief Ethics & Compliance Officer, who is responsible for overseeing and monitoring the ethics and compliance program, and a compliance committee that advises the Chief Ethics & Compliance officer and assists in the execution of the ethics and compliance program
- Regular and effective training and education, which addresses the various components of the ethics and compliance program and effectively communicates Help at Home’s standards and procedures
- Well-publicized use of an anonymous third-party compliance hotline, the Ethics Hotline, and website for employees to communicate with the Chief Ethics & Compliance Officer to report potential violations or ask questions
- A system to respond to allegations of improper activities and to enforce consistently appropriate disciplinary action for non-compliance
- Performance of regular compliance audits and evaluation techniques, internally and externally, to monitor compliance with relevant health care standards and regulations
- Immediate response to, and the investigation of, possible violations of the Code, compliance policies and procedures and applicable laws, rules, or regulations, as well as appropriate corrective action initiatives and consistent discipline for any violations that have occurred
In addition, Help at Home also has established extensive policies and guidelines anchored around privacy and security and the Health Insurance Portability and Accountability Clinical Act of 1996 (HIPAA), the Health Information Technology for Economic and Clinical Health Act (the HITECH Act), and HIPAA regulations for our patients, employees, and business associates.
Our Code provides guidance to all Help at Home employees, contractors, and board members about carrying out daily activities within appropriate ethical and legal standards.
The Code was developed to help ensure we meet our ethical standards and comply with applicable laws, rules, and regulations. The Code is a critical component of our overall ethics and compliance program and an important resource — especially in situations in which questions may arise about determining the right thing to do.
The Code includes the potential consequences to both Help at Home and our employees for failure to comply with all statutes, regulations, and guidelines applicable to federal and state health care programs. The standards set forth in the Code are mandatory and should be applied both in letter and in spirit. The business practices that are addressed in the Code include, but are not limited to:
- Awareness of fraud, waste and abuse
- Legal and regulatory compliance
- Quality of care
- Coding and billing
- Conflicts of interest
- Patient information and privacy
- Confidential information
- Surveys and external audits
- Workplace conduct and employment practices
All employees and representatives of Help at Home are required to conduct themselves in a way that supports the highest standards of ethics and integrity and to follow the standards set forth in our Code and our policies and procedures without exception.
All new employees must receive Compliance training. We also require distribution of the Code to all employees annually.
Additional specialized state-specific training is offered in areas such as eligibility for home health and hospice, HIPAA, medication administration, clinical and quality, coding, billing and reimbursement, and sales and marketing. Training is delivered through webcasts, state Learning Management Systems, online courses, and instructor-led sessions. All training is documented and tracked by a supervisor or member of management.
Our Code establishes rules and procedures governing our employees’ interactions with current and potential referral sources, as well as those with the ability to influence or recommend a referral to one of our providers, helping ensure current regulations and laws are followed.
Help at Home has developed auditing and monitoring programs to assess internal controls and processes for compliance with applicable laws, rules, and regulations. The Office of Inspector General (OIG) has published areas of concern for home health agencies, hospice, and other services. Our compliance department has developed work plans and audit tools for each area of concern to assist in evaluating our company’s risk for each of these areas. Compliance professionals work in conjunction with other departments and external consultants to ensure necessary goals and objectives for each compliance work plan.
Examples of certain audits that are conducted on- and off-site include:
- Clinical and billing compliance audits of medical records performed by clinicians and certified home health coders
- Self-auditing and validation at the branch level
Audit frequencies vary depending on potential risk and vulnerability factors. Findings and recommendations are documented and monitored. Each review provides valuable guidance to assist in strengthening controls and improving overall performance throughout our agencies and branches. The analysis of this information assists in identifying both trends and opportunities for improvement within our company.
Our compliance department also conducts an annual risk assessment. This annual risk assessment process includes:
- Pulse Surveys and/or interviews with personnel, external consultants, agency/facility leadership, home office staff, and senior management
- Analysis of qualitative and quantitative information to determine appropriate risk areas and future audit activity for the approaching year’s audit work plan
Help at Home is committed to maintaining the confidentiality, privacy, and security of the protected health information (PHI) of those we serve. Consistent with HIPAA, we do not use, disclose, or discuss patient-specific information, including patient financial information, with others unless it is necessary to serve the patient or permitted by law. A copy of our Notice of Privacy Practices is provided to each patient at the time of admission. The notice describes how PHI may be used and disclosed and how to access PHI.
We are committed to being conscientious and accountable when handling confidential company information. In addition, because of its confidential nature, business, health, and financial information must be protected by an effective internal control environment, including policies and procedures to secure the company’s assets, and made available outside the company only with appropriate authorization and after consideration of the interests of Help at Home as a whole.
Protecting Help at Home’s information assets is everyone’s responsibility. Examples of confidential information include:
- Health information of those we serve
- Company financial information, including financial statements, payroll records, accounts payable summaries, vendor listings, and price/cost information
- Written and verbal agreements between Help at Home and employees, agents, strategic partners, vendors, and/or other third parties
- Trade secrets
- Due diligence information about potential acquisitions
- Customer lists and agreements, market share data, and strategic plans
- Policies, procedures, and processes
Help at Home’s Ethics Hotline provides a confidential and anonymous line of communication for employees, contractors, and third parties to communicate with the Help at Home compliance department. Individuals may contact the Ethics Hotline 24 hours a day, seven days a week, at 1-844-769-0288 or at https://helpathomemobile.ethicspoint.com. The toll-free telephone number and website are hosted by an independent third party vendor.
Help at Home makes every effort to maintain, within the limits of the law and within the bounds of an appropriate investigation, the confidentiality of the identity of any individual who uses the Ethics Hotline or dedicated website. There will be no retribution or discipline for anyone who reports a possible violation in good faith.
The success of our corporate ethics and compliance program relies on high-level oversight from our board of directors and senior management, as well as buy-in, support, and accountability from employees.
The quality and compliance committee of our board of directors provides regular guidance regarding the direction of the company’s ethics and compliance program. In addition, the committee receives regular reports on the status of the ethics and compliance program. Our Chief Ethics & Compliance Officer has a direct reporting line to the quality and compliance committee.
Our Chief Ethics & Compliance Officer oversees the ethics and compliance program and evaluates compliance issues/concerns within the organization. The Chief Ethics & Compliance Officer helps ensure that the board of directors, management, and employees are in compliance with the rules and regulations of regulatory agencies, that company policies and procedures are being followed, and that behavior in the organization meets the company’s Code of Conduct & Ethics.
Each employee has a shared responsibility and commitment to our mission of health care service to our clients. Ethics and compliance are the responsibility of every Help at Home employee, and every employee is required to always do the right thing, without exception, and to make all clinical decisions based solely on the needs of the patient.
At Help at Home, we take our commitment to our policies seriously. Our Code of Conduct & Ethics has been developed to prevent and address specific issues, been vetted with key stakeholders, outlines the Purpose, Policy, and Procedures for each, and is audited for compliance.
As a national leader in in-home care, Help at Home is pleased to share compliance resources with others in the health care industry. The following information may be helpful to in-home organizations focused on compliance issues.
Help at Home Policies:
- Help at Home Code of Conduct & Ethics: Available in English, Spanish, Chinese – Mandarin, and Russian
- State Employee Handbooks: Available at local Branch offices
- Corporate Administrative Employee Handbook: Available at local Branch offices or Corporate Support Center
- Office of Inspector General, US Department of Health and Human Services
- United States Sentencing Guidelines – Chapter Eight
- Health Care Compliance Association
- National Association for Home Care & Hospice
- American Association for Homecare
- Beacon Health
- National Hospice and Palliative Care Organization