Vendor Code of Conduct
HealthSpan strives to comply with all applicable laws, regulations and HealthSpan policies, and to demonstrate high ethical standards in our business practices. Our Vendors1 play an integral role in helping to reach these goals. We have created the Vendor Code of Conduct to communicate the minimum standards by which all Vendors are expected to conduct themselves when providing goods and services to HealthSpan. Please share this Vendor Code of Conduct with your employees.
Gifts and Business Courtesies – HealthSpan discourages you from providing gifts, meals, entertainment, or other business courtesies to physicians, employees, or contractors working in HealthSpan facilities (“HealthSpan”). The following items are never acceptable:
- Gifts or entertainment that exceed $25.00 in value
- Gifts, meals or entertainment that are given on a regular basis
- Cash or cash-equivalents, such as checks, gift certificates/cards, stocks, or coupons
- Gifts from government representatives
- Gifts or entertainment that violate the law or HealthSpan policy
- Gifts or entertainment that reasonably could be perceived as a bribe, payoff, deal, or any other attempt to gain
- Gifts or entertainment given to HealthSpan employees involved in purchasing and contracting decisions
Conflicts of Interest – Conflicts of interest between a Vendor and HealthSpan, or the appearance thereof, should be avoided. We recognize that there are circumstances in which members of the same family or household work for HealthSpan and a Vendor. When an actual, potential, or perceived conflict of interest occurs, the conflict must be disclosed, in writing, by the Vendor to the Compliance Officer at HealthSpan. HealthSpan employees are not permitted to work for a Vendor if HealthSpan is the client.
Compliance with Laws – Vendors are expected to conduct their business activities in compliance with applicable laws and regulations, including laws that are applicable to individuals and entities receiving federal funds. Vendors are also expected to take appropriate action against their employees who have been found to have violated the law or their own internal policies.
Privacy and Security – Federal and state laws require HealthSpan and our Vendors to maintain the privacy and security of HealthSpan member and patient information (PHI). Vendors are responsible for assuring that all Vendor employees who provide services to HealthSpan know about the requirements of both the Health Insurance Portability and Accountability Act (HIPAA) Privacy and Security Rules and, where applicable, those state laws and HealthSpan policies that provide more stringent protection of PHI. If your business relationship with HealthSpan contemplates access to or the disclosure of PHI, you may be required to sign a business associate agreement with us.
Ineligible Vendors – HealthSpan will not do business with any Vendor if it or any of its officers, directors or employees is, or becomes, excluded by, debarred from, or ineligible to participate in any federal health care program, or is convicted of a criminal offense in relation to the provision of health care. HealthSpan expects each Vendor to assume full responsibility for taking all necessary steps to assure that its employees involved in providing goods and services to HealthSpan, directly or indirectly, have not been or are not currently excluded from participation in any federal program.
Fraud, Waste and Abuse (FWA) –HealthSpan will investigate allegations of Vendor FWA, and, where appropriate, will take corrective action, including but not limited to civil or criminal action. The Federal False Claims Act and similar state laws make it a crime to present a false claim to the government for payment. These laws also protect “whistleblowers” — people who report noncompliance or fraud, or who assist in investigations, from retaliation. HealthSpan policy prohibits retaliation of any kind against individuals exercising their rights under the Federal False Claims Act or similar state laws.
HealthSpan Principles of Responsibility and Compliance Hotline – The HealthSpan Principles of Responsibility (POR) is the code of conduct for HealthSpan in their daily work and is available to Vendors upon request. Vendors are expected to report any suspected wrongdoing. The HealthSpan Compliance Hotline is a convenient and anonymous way for Vendors to report suspected wrongdoing including FWA, safety concerns and compliance violations, without fear of retaliation. It is available 24 hours a day, 365 days a year. Our toll free Compliance Hotline number is 855-329-1882. Appropriate action is taken against those found to have violated applicable law or HealthSpan policy.
Environmental Purchasing Policy – In support of our mission to improve the health of our members, patients, and the communities we serve, HealthSpan is committed to purchasing products and services whose environmental impacts are healthier for the environment and human health. HealthSpan expects Vendors to develop price competitive, environmentally sound, and safe products and services that help us achieve our purchasing objectives.
Supplier Diversity Program –Where applicable, HealthSpan expects its Vendors to have a commitment to finding subcontracting opportunities with diverse businesses.
Visitation Policy – When visiting HealthSpan facilities, Vendors must comply with the applicable HealthSpan supplier visitation policy, which is available at facilities upon request. Vendor representatives are required to schedule appointments and must register prior to visiting any HealthSpan medical facility.
Representatives will be required to state the area to be visited, and visits must be restricted to those location(s) only. Visitor badges provided by the facility must be worn at all times.
Publicity – Vendors are not permitted to distribute advertising, press releases, or any other general public announcement regarding its products or services in HealthSpan facilities unless you have obtained prior written authorization from an authorized HealthSpan management employee.
Vendor Compliance Training – HealthSpan requires certain Vendors, including Vendor personnel providing services in HealthSpan facilities, to complete compliance training as required by their contract, or applicable law, or regulation. The Vendor must document that its employees and agents complete compliance training. Please refer to your HealthSpan contract manager for guidance regarding these requirements.
Business Record Retention – HealthSpan requires Vendors to retain and make available records related to business with HealthSpan in accordance with applicable law, regulation, and contract requirements.
Resources – For more information on HealthSpan’s policies, contact your contract manager or visit HealthSpan’s Vendor compliance Web site at: www.HealthSpan.org.
As used in this Vendor Code of Conduct
1 “Vendor(s)” include any contractors, manufacturers, suppliers, distributors, wholesalers, service companies, and other businesses that contract with, or seek to contract with HealthSpan to provide products and/or services to HealthSpan and/or HealthSpan members or patients. Vendor(s) does not include contractors, e.g., physicians and hospitals, who provide direct medical services.