I. PURPOSE

This policy sets forth standards by which employees and contracted professionals of the Western Arkansas Counseling & Guidance Center and its affiliates will conduct themselves in order to protect and promote organization wide integrity and to enhance the ability of WAC&GC and its affiliates to achieve its business and strategic objectives in a manner consistent with the Mission and values of the Center.

II. SCOPE

Western Arkansas Counseling & Guidance Center and its affiliates.



III. POLICY

This policy articulates for employees and affiliated professionals of the Center the ethical framework within which the Center operates and places employees on notice that they will be held accountable for abiding by the articulated standards set forth in this Code of Conduct concerning applicable laws and ethical standards of business behavior for Center and its affiliates.

IV. PROCEDURES

This policy specifically relates to the Corporate Compliance Code of Conduct and is maintained in addition to other standard codes of ethics or professional codes already in effect. In keeping with the Mission of the Center, Board members, administrators, managers, supervisors, employees, medical staff, contractors, volunteers, students and others are expected to comply with the Code of Conduct. Instances of non-compliance shall be promptly reported, and appropriate corrective actions shall be immediately taken.

V. CODE OF CONDUCT

Employees and affiliated professionals of the Western Arkansas Counseling & Guidance Center shall:

Deal openly and honestly with fellow employees, customers, persons served, external healthcare providers, contractors, auditors, government entities, third party payors and others. Maintain high standards of business and ethical conduct in accordance with applicable federal, state, and local laws and regulations including fraud, waste and abuse. Adhere to both the spirit and letter of applicable federal, state and local laws and regulations. Practice good faith in transactions occurring during the course of business, clinical treatment and care services. Preserve patient confidentiality unless there is written permission to divulge protected health information or as excepted by law. Refuse any illegal offers, solicitations, payments, or other remuneration to induce referrals of the people we serve for an item of service reimbursable by a third party. Disclose financial interests/affiliations with outside entities to the Board of Directors as required by the Center's Conflict of Interest Policy. Hold vendors to this Code of Conduct as part of their dealings with the Center. Notify the Compliance Officer of instances of suspected non-compliance. Where necessary, ensure compliance requirements regarding coding and billing are monitored and enforced. Use Center supplies and services in a manner that avoids waste and abuse. Protect and retain records and documents as required by professional standards, governmental regulations and Center policies. Exercise discretion in the coding and billing of services, regardless of payor source. Nothing in this Code of Conduct replaces sound ethical and professional judgment nor supplants the Center's Code of Ethics.

VI. EMPLOYEE AFFIRMATION

Employee Affirmation of Compliance with the Center Code of Conduct

I affirm that I have read and understand the Corporate Compliance Code of Conduct of the Western Arkansas Counseling & Guidance Center.

I certify my intention to act in complete compliance with the Center's Corporate Compliance Code of Conduct.

I understand that when necessary, I may seek advice from the appropriate supervisor, the Corporate Compliance Officer, and/or the Corporate Compliance Committee concerning appropriate actions that I may need to take in order to comply with the Center's Code of Conduct.

Date: ___________ Signature: __________________________ Name (Printed): _____________________________ Job Title or Capacity: _________________________