Message from the Leadership
Dear Team Member:
Every day, our employees continue to live our core values of CLASS (Caring, Learning,
Accountable, Sharing, and Socially Responsible). This strong work ethic is exemplified
through our daily commitment to providing exceptional service to our Clients with CLASS.
The success of our business is dependent on the trust and confidence we earn from our
employees, Clients, and vendors. We gain credibility by adhering to our commitments,
displaying honesty and integrity, and reaching company goals solely through honorable
conduct.
As we conduct our business, it is wise for us to ask:
- Will this build trust and credibility for SYNERGEN?
- Will it help create a working environment in which SYNERGEN can succeed over the long
term?
- Will this benefit our Clients by building their confidence that we will always do the
right thing?
- Would I feel comfortable describing my decision at a Team meeting?
The only way we will maximize trust and credibility is by answering “yes” to those questions
and by working every day to build our trust and credibility.
Everyone, regardless of position, is expected to perform duties honestly, ethically and with
integrity. We are committed to doing the right thing. To ensure we are adhering to all laws
and required standards, everyone has the duty to report any potential or suspected violation
of this Code of Conduct, laws & standards, and SYNERGEN Health policies and procedures. We
promote an Open-Door policy and are committed to ensuring that those who report issues in
good faith will not face retaliation or retribution. Reports may be made anonymously or
confidentially and several options for reporting misconduct are detailed.
Thank you for living up to the trust given to us by those we serve.
Mel Gunawardena
Managing Partner
Duminda Gunawardena
Managing Partner
Surinda Gunawardena
Managing Director
Introduction
SYNERGEN Health is committed to conducting business in a legal and responsible manner,
consistent with our organization’s mission, vision, and values. We strive to provide our
services in compliance with all applicable laws, regulations, standards, guidelines, and
SYNERGEN Health’s policies and procedures. SYNERGEN Health will comply with requirements related
to Client’s participation in Medicare, Medicaid, and other healthcare programs. This Code of
Conduct is intended to ensure that we meet our compliance goals and provide high-quality
services to our Clients and business associates. It provides general guidance and is
supplemented by SYNERGEN Health’s other policies and procedures. This Code is organized into the
following sections:
- Compliance Program
- Commitment to Patient
- Management Compliance Responsibilities
- Record Keeping, Coding, and Billing Integrity
- Conflicts of Interest
- Workplace Commitment
- Use of Information, Property, and Equipment
- Certification and Acknowledgment
I. Compliance Program
The SYNERGEN Health Compliance Program has been established to ensure business operations are
conducted in accordance with professional standards, laws, and regulations. All those engaged in
the SYNERGEN Health workplace must comply with this Code of Conduct, policies and procedures,
laws, regulations, and professional standards including but not limited to:
-
SYNERGEN Health promotes an Open-Door policy, and all supervisors and members of management
must encourage employees, Clients as well as contractors, and other parties affiliated with
SYNERGEN Health, to feel comfortable reporting concerns and asking questions.
-
All those engaged by SYNERGEN Health have a duty to report any concerns or suspected
violations of the Code of Conduct, specifically regarding billing policies, laws, and
regulations (See Duty to Report Policy). The following process should be followed:
-
Talk to your supervisor, who is most familiar with the billing laws, regulations,
and policies that relate to your work.
-
If you are not comfortable contacting your supervisor or if you do not receive an
adequate response, talk to Internal Compliance Team or another member of the
management team including SYNERGEN’s Leadership.
-
If you still have questions after following the steps above, contact the SYNERGEN
Health External Compliance Officer using Microsoft TEAMS or directly call on
Compliance Reporting Hotline 214-979-6444.
-
You may also use the Internal Non-Conformance Management System on SharePoint to
report concerns and complaints.
Guide for reporting types of issues
# |
Type of Issues |
First Report to: |
Second Report to: (If issue not resolved after First Report) |
Third Report to: (If issue not resolved after Second Report) |
Fourth Report to: (If issue not resolved after Third Report) |
1 |
Information Security, Data Security, Physical Security related |
Team Manager |
Internal Compliance Team |
External Compliance Advisor |
Senior Leadership Team |
2 |
Billing Compliance, Contractual Compliance, Violations or Concerns related any
regulatory compliance including anti-kickback, Stark, False Claims Act, etc.
|
Team Manager |
Internal Compliance Team |
External Compliance Advisor |
Senior Leadership Team |
3 |
Human Resource Related issues -Grievances, disputes, etc. |
Team Manager |
Team HR Manager |
HR Manager |
Senior Leadership Team |
-
No retaliation for reporting suspected violations or wrongdoing will be permitted
(Non-Retaliation Policy). Any attempts to retaliate or take other negative action against an
individual who in good faith reports concerns or suspected violations will not be tolerated.
Any reports of retaliation will be investigated. If allegations of retaliation or
retribution are confirmed following an investigation, appropriate disciplinary action will
be taken. Reporting “in good faith” means that you have reason to believe a violation of the
Code of Conduct occurred or may have occurred and that you are sincere in your attempt to
provide honest and accurate information.
-
All reports of potential non-compliance with SYNERGEN Health’s Code of Conduct, policies and
procedures, laws, and regulations, including the unauthorized disclosure of personal health
information (PHI) will be investigated in a timely and thorough manner (Incident Management
Policy). If SYNERGEN confirms a report of non-compliance, appropriate disciplinary actions,
including and up to termination, will be administered. (Non-Conformance Management
Procedure)
-
Every SYNERGEN Health employee will receive an initial compliance orientation and periodic
training updates in compliance protocols as they relate to the employee’s individual duties.
Participation in required training is a condition of employment. Failure to participate in
required training may result in disciplinary actions, up to and including, termination of
employment.
-
SYNERGEN Health will promote only honest, straightforward, fully informative, and
non-deceptive marketing. We use marketing to educate the public, increase awareness of our
services and recruit employees. All marketing materials must accurately describe our
services and programs. In order to ensure that no incorrect information is disseminated,
employees must coordinate all marketing materials with and direct all media requests to the
SYNERGEN Health Executive Leadership.
-
Relationships with Vendors and Suppliers
- SYNERGEN Health is committed to employing the highest ethical standards in its
relationships with vendors and suppliers with respect to source selection,
negotiation, determination of contract awards, and administration of purchasing
activities. All vendors and suppliers are to be selected solely based on objective
criteria; personal relationships, friendships, or any other conflict of interest
play no part in the selection process.
- SYNERGEN Health does not knowingly contract or do business with a vendor that has
been excluded from a government-funded healthcare program.
II. Commitment to Patients
Even though SYNERGEN Health is not a direct healthcare provider, we are committed to serving our
Clients’ patients by:
- Providing high-quality billing services consistent with appropriate professional and
regulatory standards.
- Not permitting Employees to accept gifts from anyone being served by SYNERGEN Health to
avoid conflicts of interest.
- Protecting patients’ private and confidential information, in accordance with state and
federal laws, and professional standards.
III. Management Compliance Responsibilities
-
Management has the added responsibility of demonstrating, through their actions, the
importance of this Code of Conduct. In any business, ethical behavior does not simply
happen; it is the product of clear and direct communication of behavioral expectations,
modeled from the top and demonstrated by example.
-
To make our Code of Conduct work, managers must be responsible for promptly addressing
ethical questions or concerns raised by employees and for taking the appropriate steps to
solve such issues. Managers should not consider employees’ ethics concerns as threats or
challenges to their authority, but rather as another encouraged form of business
communication. At SYNERGEN Health, we want the ethics dialogue to become a natural part of
daily work.
-
If an employee has a question or issue to report regarding compliance with a law,
regulation, or policy and procedure, a manager is responsible for:
- Maintaining the person’s confidentiality, to the extent possible;
- Providing responsive and accurate information regarding the person’s report;
- Taking prompt action on credible reports of suspected violations; and
- Informing the person that an issue or concern is being addressed.
-
Managers have an obligation to:
- Know and follow laws, regulations, and policies related to their duties;
- Know and educate their Employees on how to report suspected or actual violations;
- Encourage others to ask questions and to report actual or suspected violations; and
- Know and educate their Employee on SYNERGEN Health’s Non-Retaliation Policy.
IV. Record Keeping, Coding, and Billing Integrity
Individuals responsible for providing SYNERGEN Health Revenue Cycle Services will:
- Maintain all corporate records to be true, accurate, and complete with company data being
promptly and accurately entered in accordance with SYNERGEN Health and other applicable
accounting/business principles.
- Not improperly influence, manipulate, or mislead any authorized auditor, nor interfere with
any authorized auditor engaged to perform an audit of SYNERGEN Health’s books of business,
records, processes, or internal controls.
- Bill patients and third-party payers in accordance with applicable laws, regulations,
policies, and procedures; and not “knowingly” submit or cause to be submitted claims that
are
false or fraudulent. Examples of “knowingly”: Billing for non-FDA approved drugs, and you
knew
that the FDA approval was only in the final stages of approval, but not yet approved would
be
“knowingly”. If you accidentally typed in the wrong CPT code, you are not “knowingly”
submitting
an inaccurate claim.
- Periodically review bills, reimbursement, and medical records to ensure compliance with
applicable billing, coding, and documentation requirements, i.e., double billing,
unbundling,
upcoding, etc. are not appropriate.
- Apply CPT and ICD-10 codes used for claims submission, following officially published
guidelines that are supported by documentation that is provided by the Client.
- Disclose billing errors to third-party payers (and patients) and inform Clients of refund
obligations that are identified in the SYNERGEN Health billing process.
- Not offer, provide, solicit, or accept kickbacks, bribes, rebates, or anything of value tied
to influencing the referral of services covered and payable by a federal or state health
care
program.
V. Conflicts of Interest
SYNERGEN Health employees will avoid any conflicts of interest between their private interests
and those of SYNERGEN Health that may prevent them or appear to prevent them from fulfilling
their job responsibilities ethically and responsibly (Conflicts of Interest Policy).
- SYNERGEN Health employees and business associates shall refrain from and avoid conflicts or
the appearance of conflicts, between the performance of their duties at SYNERGEN Health and
their private interests.
- No one engaged by SYNERGEN Health may solicit, receive, offer, or provide gifts or favors
(e.g., cash, meals, and entertainment), which may be interpreted as improperly influencing
the
performance of their job responsibilities.
- No one at SYNERGEN Health may either give or accept business courtesies that constitute, or
could reasonably be perceived as constituting, unfair business inducements that would
violate
law, regulation, or policies or would cause embarrassment or reflect negatively on SYNERGEN
Health’s reputation.
- Employees may accept unsolicited gifts of nominal value, other than money, such as flowers,
fruit baskets, calendars, pens, mugs, caps, and t-shirts (or other novelty, advertising, or
promotional items).
- Generally, SYNERGEN Health employees may not accept compensation of any amount from entities
with whom SYNERGEN Health does or may do business. Tangible gifts (including tickets to a
sporting or entertainment event) that have a market value greater than $100 may not be
accepted
unless approved in writing by management.
- Any situations that would create or appear to create a conflict of interest shall be
reported
to the Compliance Officer.
VI. Workplace Commitment
SYNERGEN Health strives to establish and maintain a work environment where employees,
contractors, and volunteers are treated with respect and fairness. SYNERGEN Health will:
- Maintain a work environment free of harassment and intimidation. Verbal, physical, or sexual
harassment will not be tolerated (Sexual Harassment Policy, & Zero Tolerance Policy).
- Make all employment and promotion decisions without regard for an individual’s race, color,
sex, national origin, age, disability, or any other classification or status protected by
local,
state, or federal law.
- Have all employees and others engaged, regardless of status or position, follow the Code of
Conduct, Employee Handbook, and SYNERGEN Health’s policies and procedures.
- Maintain a workplace that protects the health and safety of everyone in the workplace.
- Ensure all those in the workplace show respect and consideration for one another regardless
of
status or position.
- Resolve disagreements and conflicts in the workplace by following proper procedures and in a
fair and respectful manner.
- Not hire or contract with individuals or entities that have been sanctioned or excluded by
any
federal or state health care program.
VII. Use of Information, Property & Equipment
SYNERGEN Health resources, including time, material, equipment, and information, are provided for
company business use only. SYNERGEN Health employees will:
- Protect patient and company information and property from improper use, disclosure, loss,
theft, or destruction according to federal and state regulations. (See HIPAA policies)
- Not use company equipment such as email, computers, copiers, and fax machines in the conduct
of an outside business or in support of any religious, political, or other outside daily
activity, except for company-requested support to nonprofit organizations. Disclose company
information only as required in the performance of their duties or as authorized by SYNERGEN
Health, HIPAA Privacy Regulations, and Health Information Technology for Economic and
Clinical Health Act (HITECH).
- Not solicit contributions nor distribute non-work-related materials during work hours.
- Follow established internal procedures for the handling of SYNERGEN Health’s funds and
property. Properly maintain and use SYNERGEN Health’s supplies.
- Social Media -- social media refers to online communities and personal blogs in which users
post information, personal messages, and other content. When social media is used
inappropriately, it can violate patient privacy leading to significant damage to SYNERGEN
Health and SYNERGEN Health’s Employees through, without limitation:
- Breach of patient privacy causing harm to the patient
- Reputational harm
- Loss of Client/patient trust
- Substantial fines and penalties
Use of any social media must follow the established SYNERGEN Health Social Media policy.
VIII. Certification and Acknowledgement
Acknowledgment Process
SYNERGEN Health’s Code of Conduct is shared with all employees from the inception of employment
and is repeated with annual compliance training, which is incorporated into the employee’s
annual review and must be completed by all employees. Each employee must acknowledge in writing
that he or she received a copy of this Code of Conduct, understands it, and commits to honoring
it. SYNERGEN Health provides a copy of this Code of Conduct to Vendors and Clients to provide
the foundation for conducting business. Like SYNERGEN Health employees, Vendors must acknowledge
in writing that they received a copy of the Code of Conduct, understand it, and commit to
honoring it throughout their relationship with SYNERGEN Health.
Acknowledgment Form
- I acknowledge that I have received a copy of SYNERGEN Health’s Code of Conduct.
- I acknowledge that the Code of Conduct applies to my employment, duties, and services and
that following all laws, regulations, SYNERGEN Health policies, and compliance with the Code
of
Conduct is a condition of my employment or services provided at SYNERGEN Health.
- I acknowledge that I have a duty to report suspected or actual acts of non-compliance with
laws, regulations, standards, SYNERGEN Health’s Code of Conduct, and policies and
procedures.
- I acknowledge that if I violate the Code of Conduct or any of SYNERGEN Health’s policies and
procedures, I may be subject to corrective or disciplinary action, up to and including
termination.
By signing below, I acknowledge and agree to the terms of this certification and affirm my
obligation to comply with this Code of Conduct, SYNERGEN Health’s policies and procedures, and
applicable laws and regulations.
__________________________________________________
Date
___________________________________________________________
Printed Name.