Training Module — New Hire 09: Code of Conduct & Compliance

Policy Reference: NC-03 — Compliance & Code of Conduct

Learning Objectives

By the end of this module, you will be able to:

1. Describe Noble Care's core conduct standards and why they exist.
2. Explain the conflicts of interest policy and give an example.
3. State the gift policy limits and correct response to offers.
4. Identify three examples of healthcare fraud and what to do if you witness it.
5. Describe the anonymous reporting process and non-retaliation protections.

Key Points

The Compliance Program Exists to Protect Everyone
Healthcare fraud costs the U.S. over $100 billion annually. It drives up costs, harms patients, and destroys agencies. Noble Care's compliance program is built on the OIG's 7-element framework and applies to every employee from the first day of hire.

Core Conduct Standards

1. Integrity — Be honest in everything: documentation, billing, communications.
2. Professional Conduct — Treat patients, families, colleagues, and supervisors with respect at all times.
3. Accurate Records — Document only what actually happened. Falsifying records is fraud.
4. Regulatory Compliance — Follow all applicable laws, regulations, and agency policies.
5. Proactive Reporting — If you see something wrong, say something. Silence is complicity.

Conflicts of Interest
A conflict of interest occurs when your personal interests interfere — or could appear to interfere — with Noble Care's interests or a patient's welfare. Examples:

• Working privately for a Noble Care patient off the books (outside of Noble Care) while still employed here
• Accepting business referrals from patients or their families
• Having a financial relationship with a vendor or supplier Noble Care uses

If you have a potential conflict, you must disclose it to the Administrator in writing. The agency will assess it and determine the appropriate response.

The Gift Policy

• No gifts exceeding $25 in value from patients or families.
• No cash gifts of any amount.
• No gifts that could influence how you provide care.
• When a patient insists: "That's very kind of you, but agency policy doesn't allow me to accept gifts. The best thing you can do for me is let me know if there's anything I can do better for you."

Healthcare Fraud — What It Looks Like

False Claims Act: Submitting false claims to Medicare or Medicaid is a federal crime. Penalties include up to $27,894 per false claim, plus triple damages. Employees who report fraud may be protected and entitled to a share of recovered funds (whistleblower provision).

OIG/SAM Exclusion Screening
Noble Care is required to verify that no employee is excluded from participation in federal healthcare programs. The agency performs exclusion screening as follows:

• At hire: Every employee is screened against the OIG List of Excluded Individuals/Entities (LEIE) and the System for Award Management (SAM.gov) before starting work.
• Monthly: All employees are re-screened monthly. This is not optional — it is a federal compliance requirement.
• If you are found on the exclusion list: You will be immediately suspended from all patient care duties pending investigation. Exclusion from federal healthcare programs — for any reason including Medicare/Medicaid fraud, patient abuse, or felony healthcare convictions — requires termination.
• Your obligation: If you become aware of any arrest, conviction, or legal proceeding that may affect your eligibility to participate in federal healthcare programs, you must disclose it to the Administrator immediately. Failure to disclose is itself grounds for termination.

How to Report a Concern

• Talk to your supervisor.
• Talk directly to the Administrator.
• Submit a written concern anonymously to the Administrator's mailbox.
• All reports are confidential. Retaliation is prohibited.

Real-World Scenario

David has been caring for a patient, Mr. K, for eight months. Mr. K's family approaches David and offers to pay him directly to provide extra care on weekends — "just between us, no need to involve the agency." They offer David $25/hour cash.

Why David must decline:

1. Working "off the books" for a Noble Care patient is a direct conflict of interest and a policy violation.
2. It removes David from Noble Care's insurance coverage — if anything goes wrong, David has no protection.
3. It bypasses the agency's safety systems: no supervision, no documentation, no care plan.
4. If discovered, it is grounds for immediate termination.

What David should say:
"I really appreciate your trust in me. If you need additional care hours, I'd love to keep supporting your dad, but it needs to go through the agency. They can schedule additional visits and make sure everything is properly covered. Let me give you the office number."