14.1
TO THE VALUED MEMBERS OF OUR PIONEER TEAM
Dating back to our inception in 1976, Pioneer has remained focused on providing
the highest quality of behavioral health care services. We continually
demonstrate the compassion, honesty, and judgment that is expected and required
of a leading health care provider.
To further our reputation as an industry leader, we must continue to hold
ourselves to the highest professional standards, as we respond to the needs of
our patients and their families, our Pioneer colleagues, contractors,
third-party payors, and shareholders.
In order to show our commitment to ongoing quality care, we have updated our
Corporate Compliance Plan. As it is impossible to address every circumstance
that may arise, the Corporate Compliance Plan gives us a general legal and
ethical framework under which to operate on a daily basis. The Corporate
Compliance Plan covers a range of topics, including quality of patient care,
billing and coding integrity, protection of property, and health and safety. We
have attached a copy for your reference, and ask that you sign the
acknowledgment form, stating that you have read and understand the Corporate
Compliance Plan.
If you have any questions about the Corporate Compliance Plan, or if you have
questions regarding any compliance matters, please use the reporting mechanisms
that are available to you. We all must feel comfortable seeking guidance from,
and reporting issues to, our supervisors, managers, the Facility Compliance
Liaisons, and the Compliance Officer. We also have our toll-free Corporate
Compliance Hotline (800-543-2447 ext. 1250), which is available 24 hours per
day, 365 days per year. You may call the hotline anonymously and without fear of
retaliation, to report potential violations of patient rights, professional
standards of conduct, billing fraud and abuse, HIPAA and patient
confidentiality, conflicts of interest, and other compliance concerns. You
should provide as many specific details as possible, so that the Compliance
Officer will have enough information to conduct appropriate follow-up
activities.
We thank you for your continued commitment to quality care, and wish you both
professional and personal success as a member of the Pioneer team.
Bruce A. Shear Andy DeMayo, Esq.
Chairman and Chief Executive Officer Director of Corporate Services /
Compliance Officer
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MISSION AND VALUES
The Mission of Pioneer is to make a positive difference in the lives of our
patients and their families by providing the highest quality health care
services. To accomplish our Mission, we focus on the five Values, which
emphasize our ongoing commitment to quality care, professional ethics, and
industry leadership.
Quality of Patient Care - With a knowledgeable and trained professional staff,
we provide the highest quality of care to our patients. We respond to our
patients' clinical needs and are understanding of their individual personal
concerns.
Corporate Responsibility - We conduct all aspects of our business by adhering to
personal and professional ethics, with our cornerstones being honesty,
integrity, and trust.
Pioneer Team Members - We recruit, train, and develop talented, motivated, and
goal-oriented individuals. We communicate with one another in an open, honest,
and respectful manner, welcoming the individuality of our peers and embracing
our common goals.
Industry Leadership - We strive to become a leader in the behavioral health care
industry through strategic expansion, superior clinical care, and recognition in
the communities we serve.
Results-Oriented - We demonstrate to our shareholders and clients that we are
committed to positive outcomes, by striving to excel in our financial and
operational performance.
All members of the Pioneer team are committed to observing and performing the
Mission and Values.
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THE CORPORATE COMPLIANCE PLAN
CORPORATE COMPLIANCE PROGRAM
The Corporate Compliance Program has been developed to demonstrate our ongoing
commitment to the highest standards of professional and business ethics, as well
as compliance with all laws, rules, and regulations governing the health care
industry. This commitment permeates all levels of our organization. The
Corporate Compliance Program was established by the Compliance Oversight
Committee and implemented by the Compliance Officer. Each of Pioneer's
facilities has Facility Compliance Liaisons to provide the support necessary to
meet our compliance goals.
The Corporate Compliance Program is continually monitored by the Compliance
Officer to ensure that we remain in compliance with changing and newly enacted
laws and regulations.
For employees who may be covered by a collective bargaining agreement, in the
event there is any conflict between that agreement and this Corporate Compliance
Plan, the agreement will govern.
THE COMPLIANCE OVERSIGHT COMMITTEE
The Compliance Oversight Committee consists of the members of Pioneer's
Executive Committee and the Compliance Officer. The Compliance Officer receives
reports on the operational functions and compliance issues impacting our
facilities via the Facility Compliance Liaisons and other facility staff
members. The Compliance Officer reports the information on a regular basis to
the Compliance Oversight Committee. The Compliance Oversight Committee then
works to design new policies and procedures or initiate activities to remedy any
reported compliance deficiencies.
THE COMPLIANCE OFFICER
The Compliance Officer is a member of the Compliance Oversight Committee, and
serves in an advisory role to the Executive Committee. The Compliance Officer
also acts as an intermediary between the Compliance Oversight Committee and the
Facility Compliance Liaisons. If the Compliance Oversight Committee recommends
the implementation of a new policy or procedure, the Compliance Officer ensures
its implementation by working closely with the Facility Compliance Liaisons. The
Facility Compliance Liaisons immediately communicate to the Compliance Officer
any issues related to the Corporate Compliance Program, including general
compliance questions and potential or actual violations of laws or policies. The
Compliance Officer then determines how the issues may be resolved. When
necessary, the Compliance Officer works with the Compliance Oversight Committee
or outside legal counsel to determine the most appropriate course of action. The
result may require an amendment to a current policy, creation of a new policy,
employee discipline, enhanced training at a facility, or other remediation.
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FACILITY COMPLIANCE LIAISONS
One Facility Compliance Liaison is appointed by the Compliance Officer at each
facility in order to identify and respond to any issues related to the Corporate
Compliance Program. The Facility Compliance Liaisons focus on the day-to-day
operations of the facility, and ensure that the staff members maintain
compliance with the Corporate Compliance Program. The Facility Compliance
Liaisons are easily accessible to all individuals who have comments,
suggestions, or wish to report a potential or actual violation of laws or
company policies. The Facility Compliance Liaisons speak regularly with the
Compliance Officer, making recommendations for new and existing policies, and
reporting potential or actual violations of laws or company policies.
FACILITY HIPAA LIAISONS
One Facility HIPAA Privacy Liaison and one HIPAA Security Liaison are appointed
by the Compliance Officer at each facility in order to oversee compliance with
the privacy and security regulations of the Health Insurance Portability and
Accountability Act of 1996 ("HIPAA"). The Facility HIPAA Liaisons are
responsible for overseeing and managing each facility's development,
maintenance, and compliance with all policies and procedures related to the
privacy, confidentiality, and security of patients' protected health
information. The HIPAA Privacy Liaisons monitor compliance with areas, including
patients' access to medical records, disclosures of protected health
information, restrictions on the uses of protected health information,
amendments to medical records, contractual relationships with business
associates, and HIPAA training sessions. The HIPAA Security Liaisons monitor
compliance with areas, including the physical security of protected health
information, the usage of protected health information by external parties,
investigation of security breaches, and reduction of the harm caused by
disrupted access to protected health information. The Facility HIPAA Liaisons
are easily accessible to all individuals who have comments, suggestions, or wish
to report a potential or actual violation of confidentiality or security laws or
company policies.
QUALITY OF PATIENT CARE
We are committed to providing high-quality patient care, by exhibiting
compassion, integrity, and innovation. We will treat all of our patients and
their families with the highest level of consideration and respect, while
continually respecting their dignity and right to privacy.
o We will provide all of our patients with high-quality behavioral health
care services.
o We will not discriminate based on race, color, religion, sex, age, marital
status, national origin, veterans status, or disability.
o Our patients and their families have the right to request and receive
information regarding the identity and professional qualifications of all
personnel involved in the patients' care.
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o We will honor the patients' right to participate in all decisions regarding
their health care, including the refusal of treatment to the extent
permitted by law, and we will keep the patients informed of the
consequences of any action taken. We will provide patients with adequate
and accurate information concerning clinical decisions and treatments, so
they will be fully informed.
o Patients have the right to voice their opinions about the care and services
we provide.
o We will promptly and courteously answer all questions from patients and
their families, or, when necessary, refer the question to another source
better suited to respond.
o We will develop and maintain complete, accurate, and legible patient
medical records, which shall be stored in a confidential setting.
o We will only employ those personnel with proper credentials, experience,
and expertise to meet the needs of our patients.
o Only individuals with valid licenses or credentials shall perform direct
clinical care.
o We will participate in continuing education programs to ensure our
understanding of evolving industry standards, as well as compliance with
newly enacted laws, rules, and regulations.
o We will routinely assess and evaluate our clinical protocols to ensure
compliance with current standards of practice and relevant laws and
regulations.
o We will provide only those health care services that are medically
necessary, appropriate, safe, and in compliance with all standards of
practice and relevant laws, rules, and regulations.
COMPLIANCE WITH LAWS, RULES, AND REGULATIONS
We will act in accordance with all applicable laws, rules, and regulations in
order to provide the highest quality of care and maintain the integrity of our
organization.
o We will not pursue any business opportunity that would require us to engage
in illegal or unethical behavior.
o We understand that if we violate the law or the company's policies and
procedures, or knowingly fail to report such a violation, we will be
subject to disciplinary action. Depending on the specific violation,
Pioneer may take disciplinary action up to and including termination, as
well as referral to law enforcement, government agencies, or professional
licensing boards, as applicable.
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o We will abide by all of the legal and ethical guidelines pertaining to the
confidentiality of patient medical records and other protected health
information. Absent either a valid authorization signed by the patient or a
court order signed by a judge or magistrate, all information about a
patient's condition, care, treatment, personal affairs, or medical records
will only be discussed with the patient, the patient's legal representative
(when appropriate custodial paperwork is received), the clinical staff
involved in the patient's direct care, or whose job responsibilities
specifically require knowledge of such confidential information.
o We will not offer, pay, solicit, or receive any remuneration to or from an
individual or entity, whether that remuneration is in cash or in kind, in
order to induce patient referrals or arrange for the provision of other
healthcare items and services. Such prohibited remuneration includes
kickbacks, bribes, rebates, or other compensation, which are paid in order
to obtain or provide patient referrals.
o All contractual arrangements with non-full-time clinical staff and referral
sources must be reviewed and approved by the Compliance Officer, and
executed by a member of the Executive Committee. Such agreements must
provide fair market value rates for actual services rendered. Every payment
made pursuant to the agreements must be supported by proper documentation,
indicating that the contracted services were performed in an acceptable,
legal manner.
o For those facilities that obtain payment from government payors, including
Medicare and Medicaid, we will not knowingly employ or contract with any
individual or entity who is listed by any state or federal agency as being
sanctioned, disbarred, or otherwise ineligible to participate in state or
federally funded health care programs. All employees and contractors will
be informed that sanction checks will be performed at the time of
engagement and, when warranted, any time thereafter. All employees and
contractors also shall be informed that their employment or engagement may
be suspended or terminated, pending the results of the sanction checks.
o All employees and contractors will be required to report to the Facility
Compliance Liaison or Compliance Officer any felony or misdemeanor arrests
and convictions during the term of their employment or contract. All
employees and contractors will be informed that criminal background checks
will be performed at the time of engagement and, when warranted, any time
thereafter. All employees and contractors also shall be informed that their
employment or engagement may be suspended or terminated, pending the
results of the criminal background checks.
o As employees of an organization whose securities are traded publicly, we
will not release insider, non-public information that could affect an
investor's decision to buy or sell our stock. We will neither trade our
stock, nor provide tips to others to trade our stock, based on non-public
information we acquired during our employment. We also will not divulge any
non-public information pertaining to our vendors, contractors, or other
organizations with whom we deal during the course of business. All
employees and contractors shall consult Pioneer's policies and procedures
or contact the Executive Committee if they have questions about these
restrictions, or to report a potential or actual violation.
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o We will preserve Pioneer's intellectual property rights, including
copyrights, trademarks, and service marks. We also will honor the
intellectual property rights of others by obtaining authorization from the
copyright holder prior to copying any newsletters, magazines, journals,
articles, computer software, or other copyrighted materials.
o We will not make false, misleading, or inaccurate statements to government
agencies or payors, nor shall we bribe or offer inducements to any
governmental or political official or representative of a payor.
o We will ensure that all data, reports, and records, including financial
records, accounting entries, materials submitted to payors and other
documentation pertaining to our business, are complete, accurate, and
truthful. If we discover an error or omission, we immediately will notify
our supervisor, the Facility Compliance Liaison, or the Compliance Officer.
o We will retain all business-related records in accordance with applicable
laws, rules, regulations, and policies.
BILLING AND CODING INTEGRITY
We will maintain honesty, accuracy, and integrity in all activities involving
billing, coding, and support documentation.
o We will only submit for payment or reimbursement claims for services
actually rendered and evidenced by an accurate and legible note in a
patient's medical record. Under no circumstances will we submit a claim for
payment or reimbursement that is false, fraudulent, incomplete, or
otherwise inaccurate.
o We will only submit claims for services based on documentation that
complies with the applicable community standards of practice, such as
medical necessity.
o We will train and monitor all applicable staff in the proper usage of codes
and appropriate rates.
o We will enter and issue claims in a timely manner, including bills issued
to patients for co-payments and deductibles. In addition, we will ensure
that claims are filed in accordance with all applicable laws, rules,
regulations and company policies.
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o We will timely review all Explanation of Benefits forms, and verify that
all payments received relate to services actually rendered. All rejected
invoices will be promptly investigated and reissued only after the
necessary corrections are made.
o We will take immediate steps to alert the appropriate entity or individual
if we discover inaccuracies in claims that have been submitted for
reimbursement. If we receive any money that was not due to us, we will
promptly issue a refund.
AVOIDING CONFLICTS OF INTEREST
We will take all steps to avoid conflicts and the appearance of conflicts that
may arise between our personal interests and our duties and responsibilities as
members of the Pioneer team.
o We will seek advanced written approval from Pioneer's management before
engaging in any situation that may create an actual conflict of loyalty or
interest, or the appearance of such a conflict. For those situations in
which we are unsure if a conflict exists, we first will seek the guidance
of our supervisor, the Facility Compliance Liaison, or the Compliance
Officer.
o Pioneer allows employees to hold jobs outside of the organization, as long
as those employees can effectively continue meeting Pioneer's performance
standards. We may not hold other jobs if such activity is expressly
prohibited by contract, or if an actual or potential conflict of interest
is created by such other employment. It is our responsibility to take the
necessary steps to confirm the propriety of our actions in advance.
o We will not establish an association or other connection with any
individual or organization, whose operation conflicts with Pioneer's stated
Mission and Values, and policies and procedures.
o We will not solicit or accept gifts, favors, or hospitality of considerable
value from patients, visitors, vendors, referral sources, or other
organizations with which we conduct business. "Considerable value" refers
to a gift, favor, or hospitality, including entertainment, meals, and
tickets, with a high fair market value. We will track and monitor the gifts
we receive, to ensure that they are provided in the normal course of
Pioneer's legitimate business activities.
o We will not solicit or accept money or cash equivalents, including gift
certificates, in any amount from any source. Any employee who receives such
a monetary gift immediately should contact their supervisor, the Facility
Compliance Liaison, or the Compliance Officer.
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o We will not solicit or accept gifts, favors, or hospitality of any value,
whether or not of considerable value, if it appears or might appear that
the donor is seeking to influence our decisions.
o We will not offer or provide gifts, favors, or hospitality to organizations
with which we conduct business, except for infrequent, modest business
courtesies. Such business courtesies shall be tracked and monitored to
ensure that they are infrequent, of nominal value, and provided in the
normal course of Pioneer's legitimate business activities.
o We will not offer or provide gifts, favors, or hospitality to any
individual or entity, regardless of the frequency or value, if it appears
or might appear that we are seeking to influence the recipient's decisions.
o We will not solicit, accept, offer, or provide gifts, favors, or
hospitality from or to a government agency, government official, law
enforcement officer, or member of a judiciary, regardless of the amount,
frequency, and type of such gift.
o While we are allowed and encouraged to take part in the political process,
we will not contribute money or resources to candidates, elected
representatives, political parties, or political organizations on behalf of
the company, nor will we use company funds to support a particular
candidate or issue.
o We will work productively to promote Pioneer's business while on the
company's time.
o We will transact business in furtherance of Pioneer's best interests, by
working with those individuals and companies that operate with the
integrity and ethical standards shared by Pioneer.
o We immediately will report any potential conflicts of interest concerning
ourselves, our family members, and our colleagues to our supervisor, the
Facility Compliance Liaison, or the Compliance Officer.
PROTECTION OF PROPERTY
We are committed to protecting our organization's and patients' assets and
property from theft, loss, waste, or misuse.
o We will be held responsible and accountable for the proper expenditure of
Pioneer's funds and the appropriate use of Pioneer's property. We will
recognize and abide by our duty to protect and preserve Pioneer's assets,
property, and facilities.
o We will obtain prior approval from the appropriate level of Pioneer's
management prior to the commitment or expenditure of any Pioneer funds.
o We will follow all policies and procedures related to the handling and
recording of funds and property that are received in the course of
conducting our business.
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o We accept our duty to safeguard the property of our patients and visitors.
o We will dispose of surplus, obsolete, or unusable property only in
accordance with Pioneer's policies and procedures. Pioneer strictly
prohibits any unauthorized removal or disposal of property.
o As all of Pioneer's internal information and publications, including
policies and procedures, facility listings, organizational charts, patient
and provider information, and customer lists are the property of Pioneer,
we will not copy or communicate this information to any unauthorized
person, whether within or outside the organization.
o We will use Pioneer's computer networks, e-mail systems, and software only
for authorized purposes, which are directly related to our job functions.
We understand that the company may monitor our e-mail and any information
stored or retrieved on our work computers at any time.
HEALTH AND SAFETY
We are committed to providing a safe environment for our patients, employees,
and visitors.
o We will promote sound environmental and safety practices, which prevent,
detect, and monitor damage to our facilities.
o We will handle hazardous materials and other medical waste in accordance
with all applicable laws, rules, and regulations.
o We will take all necessary precautions to ensure our safety, as well as the
safety of our patients, visitors, peers, and other personnel.
o We will maintain a workplace free from violence. Weapons of any kind are
prohibited on company property, as is all conduct that may be deemed
threatening, violent, intimidating, or harassing.
o To ensure the safety and well being of our patients and colleagues, we are
committed to maintaining an alcohol-free work environment. We will not use,
possess, or be under the influence of alcohol while on company property or
on company time.
o We will not manufacture, distribute, use, possess, or be under the
influence of any controlled substances, including illegal narcotics and
prescription medications for which we do not have a valid prescription. We
understand that this requirement applies both while we are on company
property and company time, as well as during our personal time away from
the work environment, since such behavior may adversely affect our
company's reputation within the communities we serve. We are subject to
drug testing at the time of our employment, and anytime thereafter, in
accordance with Pioneer's policies and procedures.
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o We will immediately report to our supervisor or the Facility Compliance
Liaison all accidents involving a patient, visitor, or employee. We will
complete and submit a detailed incident report, in accordance with
Pioneer's policies and procedures.
o We will be familiar with emergency plans and risk management policies and
procedures. We will have access to information pertaining to fire,
disaster, and other emergency plans.
o We will ensure that all pharmaceutical products are properly stored,
secured, and inventoried. We will promptly report missing pharmaceutical
supplies or substances to our supervisor or the Facility Compliance
Liaison.
EMPLOYEE SERVICES
We are committed to treating all employees in a fair and equitable manner, while
helping them to achieve their full potential.
o We will receive the highest levels of respect and consideration in the
workplace. Pioneer does not accept inequitable or unfair treatment or
harassment of any type. Unfair treatment includes, but is not limited to,
unlawful discriminatory practices or harassment based on sex, age, race,
national origin, religion, disability, or any other characteristic
protected by law. Unlawful harassment includes, but is not limited to,
slurs, epithets, threats, derogatory comments, and unwelcome or offensive
jokes. In addition, unlawful harassment may result from verbal and physical
conduct of a sexual nature by any employee, supervisor, manager, physician,
or other individual. Such unlawful conduct includes sexual advances,
requests for sexual favors, uninvited touching, or sexual comments that
tend to create an intimidating, hostile, or offensive work environment. Any
employee, supervisor, or manager who becomes aware of any unlawful
harassment, whether or not that employee is directly affected, must
immediately act in accordance with Pioneer's harassment policy by advising
a supervisor, the facility's Human Resources Representative, the facility's
Chief Executive Officer, Pioneer's Director of Human Resources, the
Compliance Officer, Pioneer's Executive Committee, or the Corporate
Compliance Hotline.
o We are required to abide by the standards of our profession, and exercise
reasonable judgment and objectivity in the performance of our duties.
o We will ensure that each individual is provided equal employment and
advancement opportunities regardless of sex, age, race, national origin,
religion, and disability. This equal opportunity practice relates to all
personnel matters, including, but not limited to, compensation, benefits,
training, promotions, transfers, layoffs, and recalls from layoffs.
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o We will not sign or witness any legal documents on behalf of Pioneer. If
requested to do so, we will refer the matter to our supervisor, Facility
Compliance Liaison, or the Compliance Officer.
o We will demonstrate respect, consideration, and courteousness when working
with one another, regardless of our position or status within the
organization.
o We understand that our work areas and computer systems are the property of
Pioneer, and may be subject to search upon a reasonable suspicion of
wrongdoing.
o We will properly maintain and remain current on the requirements of our
licenses, certifications, and other credentials. We immediately must report
any limitations or revocations of such credentials to our supervisor,
Facility Compliance Liaison, or Compliance Officer.
OPEN COMMUNICATION
We will foster an environment that encourages open and honest communication.
o We will share ideas, resolve problems or concerns, and treat all opinions
with respect and consideration.
o We will raise legitimate questions or concerns in an appropriate, timely,
and efficient manner, without fear of retaliation.
o We will strive to understand the duties, responsibilities, and challenges
that face our colleagues on a daily basis.
o Supervisors and managers will respond in a timely and appropriate manner to
all questions and concerns brought to their attention.
o We will be truthful and accurate in our advertising and public relations
activities. Prior to distribution, we will share with the Compliance
Officer any advertising or public relations information.
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ACKNOWLEDGMENT
I acknowledge that I have received, read, and understand Pioneer's Mission and
Values and the Corporate Compliance Plan. I further acknowledge that I will, at
all times, act in accordance with these materials, and that I am not presently
aware of any activity, relationship, or conduct that may be considered a
violation of the Mission and Values or the Corporate Compliance Plan.
_______________________________________ ____________________
Signature Date
_______________________________________
Print Name
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