POLICY
Corporate Compliance
Purpose:
Providence Care, Inc. Corporate Compliance Program is intended to provide reasonable assurance that Providence Care, Inc. conducts business activity in full compliance with all the federal, state, and local laws and regulations.
Policy:
It is the policy of Providence Care, Inc. that our Corporate Compliance Program has been established to ensure that each employee has a clear understanding of his or her responsibility and acts accordingly.
Corporate Compliance
It is the policy of Providence Care, Inc. to provide services that fully comply with all federal, state, and local regulations and applicable laws, and to adhere to explicit ethical standards throughout all facets of the organization’s operations. Providence Care, Inc. will ensure these conditions of operation are met through an organized and ongoing comprehensive corporate Compliance program. PROVIDENCE CARE Corporate Compliance Program seeks to meet the following overall goals:
- Maintain and enhance the quality of services.
- Demonstrate a sincere effort to comply with all applicable laws.
- Revise and develop new policies and procedures to enhance compliance.
- Enhance communications with governmental entities to ensure compliance.
- Empower all involved parties to prevent, detect, respond to, report, and resolve conduct that does not conform to applicable laws and regulations, and the organization’s ethical standards/code of conduct.
- Establish mechanisms for staff members to ensure that questions and concerns about compliance issues are appropriately addressed.
- Employees and contractors perform their designated functions in a manner that reflects the highest standards of ethical behavior.
Providence Care, Inc. Corporate Compliance Officer is Mrs. Stella Okpala. She can be reached anytime at 404-931-7854. All staff shall be trained in corporate compliance annually.
POLICY
Code of Ethics
Purpose:
The Code of Ethics shapes the culture and norms of Providence Care, Inc. administrative operations and program practices.
Policy:
It is the policy of Providence Care, Inc. that all full and part-time employees and contractors are expected to perform their designated functions in a manner that reflects the highest standards of ethical behavior.
Code of Ethics
Conduct and Language
The conduct and language of staff members must meet acceptable social standards and contribute to a positive environment. Staff must treat each other in accordance with the values of Providence Care, Inc. in the exercise of their duties. Staff members must not engage in any form of discrimination or harassment on the basis of culture, age, gender, race, religion, sexual orientation, developmental disability, language, and socioeconomic status.
Confidentiality
Staff members must not disclose any confidential information acquired through their duties to anyone other than persons who are authorized to receive such information. This prohibition applies to disclosures made within and outside Providence Care, Inc. and continues to apply after the work relationship ends.
Allegation
Any staff member who witnesses an incident of abuse of an individual, of sexual activity involving an individual while under the care of Providence Care, Inc. staff members shall report the incident to their supervisor immediately. When the agency becomes aware of the possible abuse of an individual or has reasonable suspicion of abuse or neglect, the agency is required by law to notify the Director, Georgia Department of Behavioral Health & Developmental Disabilities, Department of Community Health, local law enforcement authorities, and Support Coordinator within 24 hours.
Stewardship
Staff members have a fiduciary responsibility to ensure the sound and prudent use of public resources and to safeguard the public interest in the performance of their governance duties. They avoid waste, fraud and any abuse of power.
Education and Communication
Staff members are committed to the education of staff and individuals about the Code of Ethical Conduct, to encouraging the reporting of any allegations of violations, to addressing any such allegations in a timely and fair manner, and to ensuring there are no reprisals for such reporting.
Investigations and Reporting
Providence Care, Inc. will ensure the proper conduct of investigations and reporting into critical incidents and deaths. An ‘incident’ which should be reported is any situation, action, or lack of action, which caused or could cause physical or emotional injury to a consumer, employee, or visitor, and/or damage to Providence Care, Inc. property. Any situation that violates our Corporate Compliance and Code of Ethics Policy should also be reported. Providence Care, Inc. will report all reportable incidents to DBHDD within 24 hours and all deaths within 2 hours. The Director will conduct an investigation of all the incidents that are reportable and requires an investigation within 30 days and submit a final report to the Investigations Sections.
Conflict of Interest
Staff members who are direct relatives of each other, or who are direct relatives of individuals receiving service at Providence Care, Inc. may not engage in work activities where the relationship creates an opportunity for involvement that would have a detrimental effect on individuals or Providence Care, Inc. This restriction may be waived provided that sufficient safeguards are in place to ensure the interests of individuals and/or Providence Care, Inc. are not compromised. A staff member must disclose any financial or personal interest, direct or indirect, which he/she may have that may conflict with Providence Care, Inc. or a subsidiary of it, or which may otherwise have bearing upon any transaction or business in which Providence Care, Inc. or a subsidiary of it may have or contemplate having an involvement. Staff may not exchange gifts, or accept money or gratuities from any individual or individual’s family member or legal guardian. This applies whether such interest arises by reason of the personal affairs, employment, office or other association of the staff member. In such circumstance, the staff member will refrain from participation in such transaction or business. Staff members are prohibited from initiation or participation in intimate or sexual relationships of any nature, whether “consensual” or otherwise, with individuals while affiliated with Providence Care, Inc. Please note staff members may not work directly with an individual if they are related according to DBHDD Provider Standards.
Partnerships
Staff members take a leadership role in developing and sustaining partnerships with potential employers and community organizations. In all relationships with business and community partners, they act honestly and fairly and avoid conflict of interest. Marketing activities and materials are presented truthfully, presenting individuals and families positively, and not taking advantage of sympathy.
Service Provision
Staff members provide efficient and effective services to members and individuals of Providence Care, Inc. This service must be carried out in a respectful, responsive and ethical manner. Staff members must be sensitive to the changing needs, expectations and rights of a diverse membership and individual base while respecting the legislative, funding, policy and service frameworks within which Providence Care, Inc. operates.
Conduct Business in Accordance with High Ethical Standards
The company aspires to conduct its business in accordance with uncompromising ethical standards. Adherence to such standards should never be traded in favor of financial or other business objectives. High ethical standards are necessary to maintain competitive advantage, the pride and confidence of our employees, and the ability to provide quality services to our individuals. If an employee is involved in proposals, bid preparation or contract negotiations, he or she must be certain that all statements, communications, certification and representations to prospective individuals are accurate and truthful. Employees must never make a false statement or submit a false claim. The company expects every employee to adhere to high ethical standards and to promote ethical behavior. Employees should avoid seeking loopholes, taking shortcuts or relying on “technicalities” to avoid responsible conduct, and they should reject the notion that unethical behavior is acceptable because “everyone is doing it.” Every action should be judged by considering whether it is legal, fair to all concerned, in the best interests of our employees and individuals, and able to withstand the scrutiny of outsiders. Employees whose behavior are found to violate ethical standards will be subject to disciplinary action, up to and including termination.
Conduct Marketing, Fundraising, and Advertising Activities Fairly, Honestly and
Accurately
The agency may use marketing and advertising activities to educate investors and the public, provide information to proposed individuals, increase awareness of our services and business offerings, and recruit new employees. The company is committed to representing its services and offerings fairly, honestly and accurately. Advertising, marketing, fundraising, and promotional materials cannot contain unfair, inaccurate or deceptive statements or grossly exaggerated or unwarranted representations. Employees must not use any advertising, marketing, fundraising or promotional materials that unfairly describe the services of a competitor or make disparaging comments or innuendo.
Public Comments
Staff members must exercise caution and discretion in making public comments or entering into a public debate regarding any aspect of Providence Care, Inc. or its individuals. The public comments of staff members must accurately reflect the official position of the organization and must not bring Providence Care, Inc. into disrepute.
Legal Proceeding
Staff members are obliged to cooperate with legal counsel action for Providence Care, Inc. interests during any legal proceeding. All verbal and written communication between legal counsel and staff member is subject to solicitor/individual privilege and is, therefore, confidential. The content or results of such communication shall not be released to persons outside Providence Care, Inc. without the prior consent of the Director.
Setting Boundaries
It is important that all staff have professional boundaries and realize that their ability to perceive that something they might do, or are already doing could directly or indirectly affect the welfare of the individuals at Providence Care, Inc. Staff must always be aware of the policies, procedures, and ethics of the agency and realize that ethical awareness and boundary setting are continuously active processes that involve constant questioning and professional responsibility.
Witnessing Documents
Staff are members are not authorized to certify, witness or notarize any document for the individual, individual representative or family member. Staff may sign individual acknowledgments and staff forms as in the case of doing normal business.
Professional Responsibility
All staff should reflect positively on Providence Care, Inc., the profession, and the industry. All staff of Providence Care, Inc. have the responsibility of following rules of conduct, policies and procedures, avoiding conflicts and putting the interest and care of the individual ahead of their own interest. The principle of taking personal and professional responsibility requires not only that staff avoid doing harm to others but that they exhibit courteous behavior upholding the standards expected of all staff at Providence Care, Inc. In so doing they are expected to protect the rights of others and respect the diversity of cultures and people with developmental disabilities. All staff at Providence Care, Inc. are well-positioned to assert their rights to have a reciprocal duty to exercise care towards those who depend on them for their well-being. When a conflict arises between a staff and an individual, the issue should be disclosed to the Director. If a problem arises with the Director, the staff member can request a meeting with the Advisory Board President.
Human Resources
All staff at Providence Care, Inc. have the responsibility of adhering to the Human Resource Policies & Procedures of the agency. All staff must maintain and develop knowledge and understanding of their area of expertise or professional field. They should actively and continuously seek to improve work performance with emphasis on quality skills. Additionally, staff should actively seek out ways to bring about improvement on their workplaces and endeavor to take full advantage of all training requirements and staff development activities.
All staff shall be trained in the Code of Ethics Policy annually.