Chief Compliance and Ethics Officer Health Care

one page code of conduct

  • 1.  one page code of conduct

    Posted 05-15-2019 12:28 PM
    I was on the CI post-conference webinar about revitalizing the code of conduct (I forgot the actual title), but the speaker presented the idea and his thoughts on a one-page code of conduct.  What are thoughts on a one-page code of conduct - do you think it can work, would it be effective, would it meet the OIG's scrutiny?  Does anyone have a one page code of conduct?

    David Garrison
    Compliance/Privacy Officer
    2020 HCCA Compliance Institute

  • 2.  RE: one page code of conduct

    Posted 05-15-2019 02:38 PM


    Our Code of Conduct aids employees on how to behave legally and ethically.  It is 5 pages long and covers so many subjects, e.g., fraud and abuse, antitrust, lobbying, confidentiality, conflict of interest, accepting gifts/tips, stewardship of assets, travel- just to name a few! One page would be nice, but I don't think there would be room to give employees the kind of direction some of them need.  I guess you could add policies/procedures to cover a lot of the topics though!  Good topic David!  Interested to see what others think!



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  • 3.  RE: one page code of conduct

    Posted 05-15-2019 02:59 PM
    We have a one page code of conduct and I think it works well. We put this in the front of our compliance program manual then the rest of the manual is made up of   many other policies and laws and regulations and how we accomplish the seven elements of a compliance program. I don't necessarily think it has to be multiple pages to be effective.

    Savannah Knuettel
    Compliance Officer
    Galen Medical Group

    The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.

    2020 HCCA Compliance Institute

  • 4.  RE: one page code of conduct

    Posted 05-15-2019 07:49 PM
    I was on the same webinar.  I think it is an intriguing idea, but the key was being sure to have all the policies and procedures in place otherwise to refer to/link to.  Will be giving this more thought, for sure.

    One thing I did get out of the webinar was the idea of having 12 standards, and designing some communications around "standard of the month" - as luck would have it, our CoC has 12 standards, and we will be rolling this out next year using our email blast system to highlight one per month.

    Marie Wagner
    Operations Manager, Corporate Compliance
    The Queen's Health Systems

    2020 HCCA Compliance Institute

  • 5.  RE: one page code of conduct

    Posted 05-16-2019 07:22 AM
    I was also on the webinar and thought the one page was more like a table of contents. It had 12 standards that were also printed on ID badges. The presenter mentioned that links/references to policies & procedures were provided so more detail is available.

    For example, if Standard 3 is "Gifts of nominal value may be accepted," it points you to the policy on gifts that will define nominal value, gifts among employees at holidays, no alcohol gifts, etc. This prevents repetition among documents too.

    Interesting presentation & I am interested in others responses.

    Cindy Hart LPN, CPA, CPC, CHC
    Horsham, PA & Port Charlotte, FL

    2020 HCCA Compliance Institute

  • 6.  RE: one page code of conduct

    Posted 05-16-2019 07:36 AM

    I was not on that webinar but would like to add the following to the discussion.

    I think much of whether this is a viable option or not is going to depend on what or how organizations view as one of the prime objectives of the content of its Code of Conduct.  To help explain my opinion, I will use New Employee Orientation or NEO.

    Look at the NEO program that your organization uses.  Does it give new folks basic, useful information to help them move from Day 1 onward as they begin their journey into your organization or is it an attempt to give people so much information that by the second presenter...and 100 slides later...people are just hanging on and hoping the lunch break arrives sooner rather than later?

    I've seen some NEO programs go into depth in various areas that I think would make even folks who are responsible for such areas as Joint Commission compliance or folks who are tasked with Medicare compliance oversight glaze over in their seats.  Imagine how folks whose jobs are not even remotely related to some of this content must feel.  They probably can't get out of the exit fast enough when NEO is over.

    In comparison, is the Code of Conduct an immersion into the organization which is also some type of primer on all or most of the target areas or objectives that the organization is looking to achieve?

    When one remembers what the OIG refers to as standards of conduct, it makes sense that a standards of conduct or code of conduct can be very basic but very important.  A clear statement endorsed by leadership and the Board on the organization's commitment to follow all rules and regulations and to provide a workplace where people are supported in bringing issues forward...I think are at the core of such a code.

    One Code of Conduct I saw recently had page after page of about 4 or 5 key laws that an organization is keyed on complying with which included a detailed explanation of the law, how it is enforced, the penalties for violations,etc, etc, etc.  C'mon man!

    So my takeaway, do I believe the idea of a code of conduct of one page (or maybe 2 or 3) is a good idea?  Definitely!

    ► Next Study Group Ready to Start on 6/6 ◄
    --------Frank Ruelas---------

    2020 HCCA Compliance Institute

  • 7.  RE: one page code of conduct

    Posted 05-16-2019 11:17 AM

    Sometimes the less said , the more is said.  One page could be used depending on how the organization presents  other education.  A number of years ago I re-did our very boring single spaced code of conduct that I inherited into a frequently asked questions.  It has been well received by staff.  I also was at a seminar years ago where a presenter said that he felt "do the right thing" was enough of a code of conduct.  Whatever you do I believe it must work for your organization and be read and internalized by your employees.


    Thank you,

    Sharon Taylor, RN, MS, CIC, CPHRM, CHC, CHPC        

    Director Risk Management/ Accreditation Services

    Burgess Health Center

    1600 Diamond Street

    Onawa, IA 51040

    Tel: 712-423-9248

    Fax: 712-423-3500







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