Each member of the PHCS Board and each of the PHCS personnel understands that:

1. It is my responsibility to be trustworthy, honest and reliable in everything I do while representing PHCS.

2. I must follow all appliance federal, state, and local laws and regulations.

3. I need to know the laws, rules and regulations that apply to my job and will seek additional education, advice and guidance if I have any questions about such laws, rules and regulations.

4. I will keep patient, client, participant, employee, vendor and other business information confidential in accordance with applicable legal and ethical standards.

5. I will not use my position to profit personally or to assist others in profiting in any way at PHCS’s expense.

6. I will not accept or request money or valuable gifts in exchange for the receipt or

7. promise of services or goods.

8. I will use resources efficiently and protect them against loss, theft or misuse.

9. I am committed to ensure that our patients, clients and participants have appropriate access to PHCS.

10. I am committed to treating my coworkers, our patients, clients, participants, vendors and visitors with respect, dignity and courtesy.

11. I will seek the advice of the Compliance Officer, or my supervisor, if I am unsure of the legality of any action.

12. I must report situations that appear to violate these to the Compliance Officer or to the Chair of the Board’s Compliance & Planning Committee, as more fully discussed in this plan or via the Compliance & Privacy Hotline.

Mandatory Reporting

In addition to any required certifications to the OMIG regarding the implementation of an effective compliance plan,PHCS will comply with all other legally prescribed reporting procedures including, but not limited to, the submission of timely and accurate federal and state statistical and cost reports, incident reports, and reports of instances of suspected child abuse.

Using Good Judgment/Seeking Guidance

While the Code of Conduct covers general principles and activities related to an individual’s employment at PHCS, it does not address all conduct-related matters some of which may be covered in the PHCS Employment Handbook and/or other health center policy manuals. Additionally, the code cannot cover all situations which may occur in the course of business. PHCS relies on the good judgment and values of its personnel to guide them in making decisions. When faced with a difficult situation, all personnel should seek help from their supervisor, the Compliance Officer or a member of the management team, as needed.