Principle Health Systems (PHS) is committed to conducting business in accordance with the highest standards of integrity, legal compliance and ethical conduct. Conducting business ethically is critical to serving our customers, stakeholders, and communities where we live and serve.

The Officers of Principle Health Systems have adopted this Code of Business Conduct and Ethics policy. This policy is intended to focus on conflicts of interest, compliance and other ethical issues, provide mechanisms to report violations of compliance, conflicts or unethical conduct, while fostering a culture of transparency, accountability and integrity. The principles set forth in this document describe how we conduct business. Although no policy can anticipate or address every situation that may arise regarding compliance, proper and ethical business conduct, each member of the Principle Health Systems team is expected to comply with the letter and spirit of this policy.

Accordingly, this policy will serve as a source of guiding principles. All Principle Health Systems employees are encouraged to read this policy in conjunction with our policies and procedures.

Code of Conflict– Principle Health Systems has developed a Code of Conduct designed to deter wrongdoing and promote transparency and ethical conduct. The Code of Conduct details the fundamental principles, values, and framework for compliance within the company, provides guidance on acceptable behavior for all employees, clearly stating they must comply with all applicable governmental laws, rules, and regulations, and report suspect violations of the law or company policy to the Compliance Officer.

Code of Business Conduct and Corporate Standards- The Code of Business Conduct and Corporate Standards provides the framework for ethical practices and is required to be followed by all Principle Health Systems employees. Principle Health Systems employees shall be personally responsible and accountable for his or her adherence to the provisions of this policy in all material respects.

Compliance with Applicable Governmental Laws, Rules and Regulations- Principle Health Systems promotes full compliance with all applicable laws and regulations including, but not limited to, Federal Anti-Kickback Statute, Texas Illegal Remuneration Statute, Stark Law, Physician Payments Sunshine Act, and Health Insurance Portability and Accountability Act. In furtherance of this commitment, all Principle Health Systems Officers/Directors are expected to comply, and should encourage and promote compliance by all employees of the company, its subsidiaries and affiliated entities, with governmental laws, rules and regulations applicable to PHS’s business and operations.

Compliance Program– Principle Health Systems has implemented an effective Compliance Program that includes the following elements:

  1. Designation of a PHS Compliance Officer and, if applicable, a Compliance Committee.
  2. Development of written Compliance Policies and Procedures and the PHS Code of Conduct, which contains written standards of conduct.
  3. Form open lines of communication, including a toll-free hotline and internet-based reporting that permit anonymous reporting without fear of retaliation.
  4. Development of appropriate annual training and education.
  5. Development of internal monitoring and auditing activities.
  6. Enforcement of disciplinary standards.
  7. Response to detected deficiencies plan.

The Compliance Program defines the roles and responsibilities, assigns oversight for compliance, and conducts assessments of the program’s effectiveness.

The PHS Compliance Program is part of the operations of all PHS facilities and corporate functions. It exists to review and evaluate compliance issues and concerns within the organization relating to federal and state healthcare programs, and is designed to assure compliance with all laws, rules and regulations relating to PHS’s business operations.

Overall responsibility for operation and oversight of the Compliance Program belongs to Managing Partners; however, the day-to-day responsibility for operation and oversight rests with the Compliance Officer, who has direct access to the Managing Partners to make regular reports on the status of the PHS Compliance Program. The Compliance Officer is supported in these duties by the PHS Compliance Committee, if applicable.

Reporting Violations- Principle Health encourages compliance with all applicable laws and regulations, including those designed to prevent and deter fraud, waste, and abuse at all levels of the organization. We desire a climate that discourages inappropriate conduct and facilitates open communication of any compliance concerns and/or questions. PHS personnel are encouraged to contact the Compliance Officer if they, in good faith, suspect or know of any wrongdoing in: the documenting, coding, or billing for services, equipment, or supplies; the organization’s financial practices; a violation of any law or regulation; or a violation of any PHS policy.

Consequences for Non-Adherence to Code Provisions- Principle Health Systems takes non-adherence to the provisions of the Code of Business Conduct and Ethics very seriously. Failure to comply with these requirements may subject an individual to disciplinary action, including termination.

To discuss or report Compliance related issues, please contact our Corporate Compliance Officer directly via email at phsalertline@principlehs.com 

 

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