Ethics Policy

It is the responsibility of every Alacare Home Health & Hospice employee, independent contractors, vendor and others who render services for and/or on behalf of Alacare to act in a manner that is consistent with Alacare’s Mission Statement and its supporting polices.

 

Our mission is to consistently exceed our customers’ expectations by maintaining an ethical, positive, efficient and financially sound workplace environment that allows our organization’s caring, multi-skilled and empowered employees to provide high quality home based services through a system of clinically superior programs.

 

1. Alacare requires all employees’ compliance with all laws and regulations to which it is subject.  When the application of a law or regulation is uncertain, the guidance of the company’s Compliance Officer and/or General Counsel shall be sought. Alacare requires independent contractors, vendor and others who render services for and/or on behalf of Alacare to affirm that their services will be provided in accordance with all laws and regulations.

 

2. Alacare’s policy is to maintain contacts with governmental officials and other government personnel, whether directly or indirectly, as proper business relationships.  Such contacts must never suggest undue influence or cast doubt on Alacare’s integrity. Furthermore, Alacare is committed to ensuring the accuracy of all filings with the government.

 

3. Alacare maintains accurate and reliable corporate records which disclose all disbursements and other transactions to which Alacare is a party.

 

4. Alacare requires the undivided loyalty of its employees in the exercise of their responsibilities.  Except as may be otherwise approved by the Board of Directors or an appropriate committee thereof, personal investments or other activities which may create a conflict of interest are prohibited, and circumstances which may give the appearance of a conflict of interest are to be avoided.

 

5. Alacare requires all employees, independent contractors, vendors and others who render services for and/or on behalf of Alacare to report wrongdoing or suspected wrongdoing. Reports of wrongdoing may be orally to one’s supervisor, through the Compliance Helpline (1-800-306-9165) or in writing. Reports of wrongdoing or suspected wrongdoing may be made anonymously, however, such reports allow for limited feedback and follow up. All reports must be directed or forwarded to the Compliance Officer for appropriate follow up and investigation.

 

6. It is a violation of this Code for personnel not to report a violation of this Code or to fail to report any wrongdoing or suspected wrongdoing.

 

7. It is our policy to promptly and thoroughly investigate reports of wrongdoing or suspected wrongdoing or violations of this Code.  Personnel must cooperate with these investigations.  No reprisals or disciplinary action will be taken or permitted against personnel for good faith reporting of and/or cooperating in the investigation of illegal or suspected illegal acts or violations of this Code.

 

8. Personnel who violate the Code or commit illegal acts are subject to discipline up to and including dismissal.

 

9. Alacare conducts Ethics Committee Meetings to facilitate discussion of ethical questions; to furnish ethics educational resources; to educate staff, physicians, patients and caregivers about ethics; to provide advise, training and consultation to the staff on actual and potential questions of ethics; and to analyze specific ethical questions and assist in the resolutions.

 

The company’s Board of Directors has adopted the foregoing Code of Ethics to apply to Alacare.

 

Susan B. Brouillette

Secretary of the Board

Alacare Home Health Services, Inc.

 

 

Privacy Notice

This notice describes how medical informtion about you may be used and disclosed and how you can get access to this information. Please review it carefully.

 

We are required under the federal health care privacy rules (the “Privacy Rules”), to protect the privacy of your health information, which includes information about your health history, symptoms, test results, diagnoses, treatment, and claims and payment history (collectively, “Health Information”).  We are also required to provide you with this Privacy Notice regarding our legal duties, policies and procedures to protect and maintain the privacy of your Health Information and to notify affected individuals following a breach of unsecured protected health information. We are required to follow the terms of this Privacy Notice unless (and until) it is revised.  We reserve the right to change the terms of this Privacy Notice and to make the new notice provisions effective for the Health Information that we maintain and use, as well as for any Health Information that we may receive in the future.  Should the terms of this Privacy Notice change (while you are receiving service), we will make a revised copy of the notice available to you.  Privacy Notices will also be posted and available electronically on our web site.

 

 

Permitted Uses and Disclosures of Your Health Information

1. General Uses and DIsclosures. Under the Privacy rules, we are permitted to use and disclose your health infromation for the following purposes, without obtaining your permission or authorization.

 

„Treatment. We are permitted to use and disclose your Health Information in the provision and coordination of your health care. For example, we may disclose your Health Information to your primary health care provider, consulting providers, and to other health care personnel who have a need for such information for your care and treatment.

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Payment. We are permitted to use and disclose your Health Information for the purposes of determining coverage, billing, and reimbursement. This information may be released to an insurance company, third party payor, or other authorized entity or person involved in the payment of your medical bills and may include copies or portions of your medical record, which are necessary for payment of your bill. For example, a bill sent to your insurance company may include information that identifies you, your diagnosis, and the procedures and supplies used in your treatment.

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Health Care Operations.  We are permitted to use and disclose your Health Information during our health care operations, including, but not limited to: quality assurance, auditing, licensing or credentialing activities, and for educational purposes.  For example, we can use your Health Information to internally assess our quality of care provided to patients.

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Uses and Disclosures Required by Law.  We may use and disclose your Health Information when required to do so by law, including, but not limited to: reporting abuse, neglect and domestic violence; in response to judicial and administrative proceedings; in responding to a law enforcement request for information; or in order to alert law enforcement to criminal conduct on our premises or of a death that may be the result of criminal conduct.

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Public Health Activities.  We may disclose your Health Information for public health reporting, including, but not limited to: suspected abuse and neglect; reporting communicable diseases and vital statistics; product recalls and adverse events; or notifying person(s) who may have been exposed to a disease or are at risk of contracting or spreading a disease or condition.

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Abuse and Neglect.  We may disclose your Health Information to a local, state, or federal government authority, if we have a reasonable belief of abuse, neglect or domestic violence.

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Regulatory Agencies.  We may disclose your Health Information to a health care oversight agency for activities authorized by law, including, but not limited to, licensure, investigations and inspections.  These activities are necessary for the government and certain private health oversight agencies to monitor the health care system, government programs, and compliance with civil rights.

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Judicial and Administrative Proceedings.  We may disclose your Health Information in judicial and administrative proceedings, as well as in response to an order of a court, administrative tribunal, or in response to a subpoena, summons, warrant, discovery request, or similar legal request.

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Law Enforcement Purposes.  We may disclose your Health Information to law enforcement officials when required to do so by law.

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Coroners, Medical Examiners, Funeral Directors.  We may disclose your Health Information to a coroner or medical examiner.  This may be necessary, for example, to determine a cause of death.  We may also disclose your health information to funeral directors, as necessary, to carry out their duties.

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Organ Procurement Organizations.     Consistent with applicable law, we may disclose health information to organ procurement organizations or other entities engaged in procurement, banking, or transplantation of organs for the purpose of tissue donation and transplant.

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Research.  Under certain circumstances, we may disclose your Health Information to researchers when their clinical research study has been approved and where certain safeguards are in place to ensure the privacy and protection of your Health Information.

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Threats to Health and Safety.  We may use or disclose your Health Information if we believe, in good faith, that the use or disclosure is necessary to prevent or lessen a serious or imminent threat to the health or safety of a person or the public, or is necessary for law enforcement to identify or apprehend an individual.

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Specialized Government Functions.  If you are a member of the U.S. Armed Forces, we may disclose your Health Information as required by military command authorities. We may also disclose your Health Information to authorized federal officials for national security reasons and the Department of State for medical suitability determinations.

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Inmates.  If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release your Health Information to the correctional institution or law enforcement official, where such information is necessary for the institution to provide you with health care; to protect your health or safety, or the health or safety of others; or for the safety and security of the correctional institution.

 

Workers’ Compensation.  We may disclose your Health Information to your employer to the extent necessary to comply with Alabama laws relating to workers’ compensation or other similar programs.

 

„Fundraising.  We may use or disclose your Health Information to make a fundraising communication to you, for the purpose of raising funds for our own benefit.  Included in such fundraising communications will be instructions describing how you may ask not to receive future communications.

 

„Visit Reminders/Treatment Alternatives.  We may use and disclose your Health information to remind you of your upcoming home visit or to provide you with treatment alternatives or other health-related benefits and services that may be of interest to you.

 

„Business Associates.  We may disclose your Health Information to business associates who provide services to us.  Our business associates are required to protect the confidentiality of your Health Information.

 

„Other Uses and Disclosures.  In addition to the reasons outlined above, we may use and disclose your Health Information for other purposes permitted by the Privacy Rules.

 

2. Uses and Disclosures Which Require Patient Opportunity to Verbally Agree ot Object

Under the Privacy Rules, we are permitted to use and disclose your Health Information: (i) for the creation of facility directories (ii) to disaster relief agencies, and (iii) to family members, close personal friends or any other person identified by you, if the information is directly relevant to that person’s involvement in your care or treatment.  Except in emergency situations, you will be notified in advance and have the opportunity to verbally agree or object to this use and disclosure of your Health Information.

 

3. Uses and Disclosures which Require Written Authorization

As required by the Privacy Rules, all other uses and disclosures of your Health Information (not described above) will be made only with your written Authorization.  For example, in order to disclose your Health Information for certain marketing purposes, we must obtain your Authorization. Further, we may not receive compensation or reimbursement in exchange for the release of your Health Information unless we obtain a valid Authorization or the release of Health Information is otherwise allowed by applicable law. Under the Privacy Rules, you may revoke your Authorization at any time. The revocation of your Authorization will be effective immediately, except to the extent that: we have relied upon it previously for the use and disclosure of your Health Information; if the Authorization was obtained as a condition of obtaining insurance coverage where other law provides the insurer with the right to contest a claim under the policy or the policy itself; or where your Health Information was obtained as part of a research study and is necessary to maintain the integrity of the study.

 

 

Patient Rights

You have the following rights concerning your health information:

 

Right to Inspect and Copy Your Health Information.  Upon written request, you have the right to inspect and copy your own Health Information contained in a designated record set, maintained by or for us.  A “designated record set” contains medical and billing records and any other records that we use for making decisions about you.  However, we are not required to provide you access to all the Health Information that we maintain.  For example, this right of access does not extend to psychotherapy notes, or information compiled in reasonable anticipation of, or for use in, a civil, criminal or administrative proceeding. Where permitted by the Privacy Rules, you may request that certain denials to inspect and copy your Health Information be reviewed.  If you request a copy or summary of explanation of your Health Information, we may charge you a reasonable fee for copying costs, including the cost of supplies and labor, postage, and any other associated costs in preparing the summary or explanation.

 

Right to Request Restrictions on the Use and Disclosure of Your Health Information.  You have the right to request restrictions on the use and disclosure of your Health Information for treatment, payment and health care operations, as well as disclosures to persons involved in your care or payment for your care, such as family members or close friends.  We will consider, but do not have to agree to, such requests.  However, we must agree to the restriction on a disclosure of health information where the disclosure is to a health plan for purposes of carrying out health care operations and the health information pertains solely to a health care item or service for which the individual or person other than the health plan on behalf of the individual has paid the organization in full.      

 

Right to Request an Amendment of Your Health Information.  You have the right to request an amendment of your Health Information.  We may deny your request if we determine that you have asked us to amend information that: was not created by us, unless the person or entity that created the information is no longer available; is not Health Information maintained by or for us; is Health Information that you are not permitted to inspect or copy; or we determine that the information is accurate and complete.  If we disagree with your requested amendment, we will provide you with a written explanation of the reasons for the denial, an opportunity to submit a statement of disagreement, and a description of how you may file a complaint.

 

Right to an Accounting of Disclosures of Your Health Information.  You have the right to receive an accounting of disclosures of your Health Information made by us within six (6) years prior to the date of your request.  The accounting will not include:  disclosures related to treatment, payment or health care operations; disclosures to you; disclosures based on your Authorization; disclosures that are part of a Limited Data Set; incidental disclosures; disclosures to persons involved in your care or payment for your care; disclosures to correctional institutions or law enforcement officials; or disclosures that occurred prior to April 14, 2003.  If you request an accounting of disclosure more than once in a 12-month period, we may charge you the reasonable cost-based expenses incurred to comply with your additional request.

 

Right to Alternative Communications.  You have the right to receive confidential communications of your Health Information by a different means or at a different location than currently provided.  We will arrange for you to receive protected health information by reasonable means or at alternative locations.  Your request must be in writing.  We do not require an explanation for the request as a condition of providing communications on a confidential basis and will attempt to honor requests for confidential communications.

 

Right to Receive a Paper Copy of this Privacy Notice.  You have the right to receive a paper copy of this Privacy Notice upon request, even if you have agreed to receive this Privacy Notice electronically.

 

If you want to exercise any of these rights, please contact our Privacy Officer.  All requests must be submitted to us in writing on a designated form (which we will provide to you), and returned to the attention of our Privacy Officer at the address below.

 

If you believe that your privacy rights have been violated or that we have violated our own privacy practices, you may file a complaint with us. You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services at Region IV, Office for Civil Rights, U.S. Department of Health and Human Services, Atlanta Federal Center, Suite 3B70, 61 Forsyth Street, SW., Atlanta, GA 30303-8909.  Complaints filed directly with the Secretary must be made in writing, name us, describe the acts or omissions in violation of the Privacy Rules or our privacy practices, and must be filed within 180 days of the time you knew or should have known of the violation. Complaints submitted directly to us must be in writing and to the attention of our Privacy Officer. There will be no retaliation for filing a complaint.

 

2400 John Hawkins Parkway

Birmingham, AL 35244

Attention: Privacy Officer

205-981-8000

Fax: 205-981-8573

 

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The Effective Date of this Privacy Notice is September 23, 2013.