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Health Network Laboratories believes that conscientious dedication to the highest ethical standards is essential to fulfilling its mission. Integrity governs our actions and relationships with our employees, clients, providers, suppliers and others.
Our Corporate Compliance Plan formalizes our policies and procedures into a comprehensive program which defines the responsibilities of HNL. Our compliance efforts are designed to establish a culture that:
• Facilitates discovery and education
• Promotes prevention, detection and resolution of instances of conduct that do not conform to our ethical and business policies and
• Supports those structures and plans that exist to improve performance and provide for a safe environment.
The HNL Compliance Program applies to all claims and payments for private and governmental patient services and third party payers. Due to the breadth of requirements, complexity, cost of non-compliance and high-volume, added emphasis and priority will be brought to Medicare and Medical Assistance under this plan.
The objectives of the HNL Compliance Plan are to prevent, detect and correct inappropriate claims for patient services and thereby prevent related false claims and potential charges for civil and criminal wrongdoing. The Program demonstrates and reinforces the positive standard of conduct expected of HNL, its employees and agents, and specifies duties and responsibilities throughout HNL regarding claims and payments for services.
HNL will comply with proscribed governmental claim and payment regulations and requirements to the best of its ability and expects its employees and agents actions to uphold this standard.
HNL will formally train its employees and agents in Medicare and Medical Assistance billing requirements on a regular, effective basis including current and changing requirements and regulations.
HNL will create an expectation that its’ employees and agents at any level will communicate with their supervisors regarding questions about appropriate claims and payment practices. Employees are expected to follow existing policies regarding compliance matters just as with other job responsibilities. Employees and agents who believe that acts of non-compliance exist after following existing policies are expected to contact the Compliance Officer. The Compliance Officer will in turn work with the reporting employee and all appropriate parties until resolution is achieved.
Corrective action, if required, will occur and will be based on the circumstances and facts of each case. Employee and agent retraining or discipline in accord with existing and customary polices, if needed will be part of the corrective action.
DUTY TO REPORT
HNL is committed to ethical and legal conduct that is complaint with all relevant laws and regulations. Each member of the organization is responsible for reporting any suspected criminal activity or illegal or unethical conduct by any colleague, physician, contractor or vendor that appears to be a violation of applicable law, regulation or policy.
HOTLINE/Alternative Avenues of Communication
To obtain guidance on a compliance issue or report a suspected violation, individuals may choose from several options. As with other operational matters, it is expected that if comfortable and appropriate, individuals will first discuss concerns with the immediate supervisor, or department head. If this is uncomfortable or inappropriate, another option would be to discuss concerns with another member of the management group including Human Resources, or the Compliance Officer. Individuals can always contact the anonymous Employee Hotline at 1-877-895-2905. HNL will make every effort to maintain, within the limits of the law, the confidentiality of the identity of any individual who reports a suspected violation or misconduct.
Non-Retribution Policy
HNL will not impose disciplinary action or other types of retaliation against any employee who, in good faith, reports a concern to management, the Compliance Officer or the employee hotline. “Good Faith” means that an individual doesn’t have to be right, but it means that an individual must be telling the truth as they believe it to be. Reporting a false accusation is a serious violation of policy and may lead to disciplinary action up to and including termination from employment.
Internal Investigations
All reported concerns will be addressed promptly and confidentially to the extent possible. The Compliance Officer will coordinate the investigation and recommend corrective action or changes that are required. Full cooperation with investigation efforts if expected of all employees and interested partied.
~ Federal Anti-Kickback Statute
The U.S. Department of Health and Human Services Office of Inspector General (OIG) has stated that giving free goods that have an independent value to a physician may violate the Federal anti-kickback statute if the requisite intent to induce referrals is present. The term “independent value” means that the physician may use the supply for purposes unrelated to collecting and processing a specimen for testing by the laboratory who furnishes the supply. As an example, the OIG specifically views as suspect the provisional free gloves and regular personal computers and fax machines because these items have an independent value to a physician because he/she may use them for purposes unrelated to laboratory testing. Based on the OIG’s guidance, any arrangement whereby HNL furnishes free supplies in excess of a physician’s need to collect and process specimens for testing by HNL may be deemed as a violation of the anti-kickback statute.
The Centers for Medicare and Medicaid Services (CMS) has declared that laboratories may only give their customers supplies that may be used solely for the collection, processing, storage, or transport of specimens sent to the laboratory that provided such supplies. If a customer is able to use a supply for other purposes, the laboratory may not provide the supply.
In addition, laboratories may only give customers quantities of permitted supplies that are reasonably related to the number of specimens the client sends to the laboratory for testing. For example, laboratories cannot provide customers with gloves.
HNL does and will continue to utilize reasonable controls to help ensure that we provide only the appropriate quantities of these permitted supplies. We have a commitment to comply with all laws and regulations that affect our business. Our policies and practices are developed to safeguard both HNL and you, as a valued customer, from potential violations of these laws and regulations. Should you have any additional questions, please contact our Compliance Office at 610-402-8150.
~ Notice of Privacy Practices
Effective Date: 04/14/2003
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Uses and Disclosures of Health Information
At Health Network Laboratories (HNL), we may use and disclose health information about you for treatment purposes, to obtain payment for services and for operational purposes. Treatment means the provision, coordination, or management of health care and related services, including consultations and referrals among health care providers. HNL may provide laboratory testing-related information to your physician(s). Payment generally means obtaining reimbursement for the provision of health care services. Payment also includes, but is not limited to: determinations of eligibility with your insurer or insurance coverage; risk adjustment; billing; claims management; collection activities; and utilization review activities. HNL may provide health information to your insurance company in order to receive reimbursement for services. Operational purposes means activities that are necessary for HNL’s operations. These activities include, but are not limited to: quality assessment; credentialing; underwriting; legal services; and business planning and development, as well as general administrative activities. HNL may use patient demographic information to understand our covered service area.
HNL may use or disclose identifiable information about you without your authorization or permission for several other reasons. These reasons include:
- To a family member, other relative, or a close personal friend or for disaster relief. HNL may disclose to a family member, other relative, or a close personal friend, or any other person you identify, such health information directly relevant to the person’s involvement with your care or payment of care. HNL will attempt to obtain your agreement to such use or disclosure, if possible. If agreement is not possible due to incapacity or an emergency circumstance, HNL will exercise its professional judgment in disclosing health information that is directly relevant to the person’s involvement with your health care.
- As required by law. A federal, state or local law may require HNL to use or disclose your health information.
- For public health activities. HNL may disclose your health information to a public health authority or for public health activities, such as notifying a person about exposure to a communicable disease, or participating in a public health investigation.
- For health oversight activities. HNL may disclose your health information to a government agency that oversees the health care system.
- For judicial and administrative proceedings. HNL may disclose your health information pursuant to a court order, subpoena, discovery request or other legal process.
- To law enforcement. HNL may disclose your health information to law enforcement under limited circumstances, such as to comply with a court order, search warrant, or administrative request.
- To coroners and medical examiners. HNL may disclose your health information to a coroner or medical examiner for the purposes of identification, determining a cause of death, or other duties as authorized by law.
- For organ, eye or tissue donation. HNL may disclose your health information to an organ procurement organization or other entities engaged in procurement in order to facilitate procurement.
- For research purposes. HNL may disclose your health information to a researcher provided the researcher has met certain conditions.
- To avert a serious threat to health or safety. HNL may use or disclose your health information if it, in good faith, believes that such information is necessary to avert a serious and imminent threat to the health or safety of a person or the public or to identify or apprehend a suspect.
- For specialized government functions. Your health information may be disclosed for military, national security, intelligence, or correctional or custodial activities.
- For workers’ compensation. HNL may disclose health information regarding work-related injuries in compliance with workers’ compensation laws.
In other situations, we will ask for your written authorization before using or disclosing any identifiable health information about you. If you chose to sign an authorization to disclose information, you can later revoke that authorization to stop any future uses and disclosures.
HNL may change our policies at any time and make the new policies effective for all information we maintain. Before we make any significant change in our policies, we will change our notice and post the new notice in the waiting area of all our Patient Service Centers. You can request a copy of our notice at any time. For more information about our privacy practices, contact the HNL representative listed below.
Individual Rights
You have the right to request that HNL restrict the manner in which we communicate health information to you. Your request must be in writing, and HNL will accommodate any reasonable request to provide health information by alternative means or at alternative locations. Please forward your written request to the HNL representative listed below.
With few limitations, you have the right to look at and/or get a copy of your health information that HNL has on file. This request must be in writing. If you request copies, we may charge you a per page fee to cover costs. If we deny you access to requested information, you may appeal the denial in certain circumstances. If you believe that information in your record is incorrect or incomplete, you have the right to request that we correct, or add to, the existing information. This request must be made in writing and be supported by a reason. We have the right to deny the request. Please forward your written request to access or amend information to the HNL representative listed below.
You have the right to receive a list of instances where we have disclosed health information about you for reasons other than treatment, payment or related administrative purposes during the previous six (6) years. This request must also be made in writing. HNL is not required to account for disclosures made before HIPAA’s effective date. We reserve the right to charge for multiple requests for disclosure to cover cost incurred.
You have the right to request in writing that we not use or disclose your information for treatment, payment or operational purposes, or to family, friends and individuals involved in your care. We will consider your request but are not legally required to accept it.
You have the right to obtain a paper copy of this notice, if you received it electronically. Please submit your request in writing to the HNL representative list below.
Complaints
If you are concerned that we have violated your privacy rights, or you disagree with a decision we made about access to your records, you may contact the HNL representative listed below. You may also send a written complaint to the U.S. Department of Health and Human Services. The HNL representative listed below can provide you with the appropriate address upon request. You will not be penalized for filing a complaint.
Our Legal Duty
HNL is required by law to protect the privacy of your information, provide this notice about our information practices, and follow the information practices of this notice.
This document is also available in a printable PDF format.
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If you have any questions or complaints, please contact:
Beth A. Rokus, Compliance Officer
Jane Erdman, Privacy Officer
Health Network Laboratories
2024 Lehigh St, Allentown, PA 18103
Phone: (610) 402-8150
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