1. Standards of Conduct  Training today will give you talking points  You need to read through the book and get comfortable with the information  This replaces two page Standard  Acknowledgement must be signed and sent to HR when all meetings complete

2. Standards of Conduct  Purpose – All MHCC Board memebers, employees, physicians, volunteers, contractors following the same guidelines  Governing board supports  Leadership must support and lead by example  Standards are the outward/public sign of BRMC compliance to legal and ethical behavior

3. Standards of Conduct  Education the most critical element of the compliance program  Standards do not address all the complexity of the issues, rules and regulations  Outlines what’s expected of all who have dealings with us

4. Standards of Conduct  A Commitment to Providing Patient Care  Document all care and services given  Individual professionalism – being responsible for your actions and taking pride in your work  Effective communication – using plain language, making eye contact, using proper phone etiquette, smiling and greeting patients and family members  Exceeding the expectations of patients, patient family members, and co-workers

5. Standards of Conduct  A Commitment to Our Community  You are identified with BRMC when in public  DO nothing to embarrass yourself or BRMC

6. Standards of Conduct  A Commitment to Environmental Health and Safety  Follow all governing rules and regulations, i.e.OSHA, FDA. CDC, etc.  A Commitment to Environmental Health and Safety  Workforce members will:  Wear appropriately displayed name badges at all times and be familiar with others that work in their areas  Report suspicious persons or situations immediately  Remain calm, listen, and diffuse verbally hostile situations

7. Standards of Conduct  A Commitment to Proper Employment Practices  McLaren Health Care takes reasonable precautions to ensure the work environment is free of discrimination or harassment  To maintain public trust,  Employees may not solicit or accept anything of more than de minimus value, including a loan, reward, material or property, from a patient or a patient’s family, visitor, contractor, supplier or competitor.  Employees may not use their employment, or any information received through MHC, to obtain financial gain (direct or indirect) for themselves, a member of their family or a business with which they or a member of their family, is associated.

8. Standards of Conduct  A Commitment to Ethical Business Conduct  Outside employment or business activities must be limited to off-work time  Report any situation that may be considered a conflict of interest  Staff and physicians may not share pricing information, internal reports, communications, procedure schedules  Honest, accurate, and complete reporting of financial transactions

9. Standards of Conduct  A Commitment to MHC Assets and Financial Transactions  Honest, accurate, and complete reporting of financial transactions  Appropriately representing productivity  Accurately recording travel expenses and mileage  Securing money, equipment, or supplies from theft  Complying with business expense reimbursement policies

10. Standards of Conduct  A Commitment to Accurate Coding and Billing Transactions  Providing and billing only for services that were reasonable and necessary  Billing for services at levels that are supported by medical record documentation  Waiving of co-pays or deductibles only in accordance with policy and procedure  Bundling or unbundling charges appropriately  Attempting to collect outstanding balances from a Medicare or Medicaid patients only when Advance Beneficiary Notices were provided prior to service  Preventing duplicate billing  Ensuring the accuracy of diagnostic and procedure codes

11. Standards of Conduct  A Commitment to Physician Relations  The organization will maintain positive working relationships and respect the legal rights of physicians.  provides a uniformly-applied privileging process  teaching facilities and practices to assist in advancing the field of medicine.

12. Standards of Conduct  A Commitment to Confidentiality and Electronic Security  Right to confidential communication of PHI  Right to receive a notice of uses/disclosures of PHI  Right to access or receive a copy of their medical records  Right to request a restriction to how PHI is used  Right to request changes (amendments) to their records  Right to receive a listing (accounting of disclosures) if requested  the same safeguards used to protect confidential patient information should be used to protect our business and financial information.

13. Standards of Conduct  A Commitment to Laws and Regulations  Anti-Kickback  Stark Laws (Physician Self-Referral Law)  Federal False Claims Act  State False Claims Act  EMTALA (Emergency Medical Treatment and Active Labor Act)

14. Standards of Conduct  A Commitment to Ongoing Monitoring  The MHC and BRMC compliance program  BRMC Hot Line 989-894-3945  BRMC Privacy Line 989-894-3970  BRMC Compliance Officer 989-894- 3849