Privacy Policy & HIPAA Policy

AIMA personnel shall adhere to high standards of ethical conduct and will comply with and assist AIMA in complying with all applicable laws and regulations and third-party payor program requirements.

PROCEDURE:

AIMA personnel shall comply with the following policies and standards:

1. Ethical and professional standards: AIMA personnel shall comply with and perform their services consistent with high ethical and professional standards. They shall treat co-workers and others in a professional manner with honesty, fairness, dignity, and respect.
2. AIMA policies and procedures: AIMA personnel shall comply with all applicable AIMA policies and procedures, including but not limited to those policies and procedures relevant to the Compliance Program.
3. Laws, regulations, and program requirements:  AIMA personnel shall comply with all applicable federal and state laws, regulations, and third-party payor program requirements.
4. Non-discrimination: AIMA personnel shall not discriminate against other AIMA personnel, patients, or others based on race, color, sex, religion, age, national origin, ancestry, disability, or sexual orientation.
5. Offering or receiving items of value to induce referrals: Federal and state laws prohibit paying, offering, or receiving anything of value to induce referrals for healthcare business unless certain conditions are met. AIMA personnel shall not offer, solicit, pay, or accept anything of value in exchange for healthcare referrals without first obtaining approval from the Compliance Officer. This applies to offering or receiving any money, gifts, free or discounted items or services, professional courtesies, or other arrangements with the intent to induce referrals. This applies to any such transactions involving potential referral sources, including transactions with other health care providers, vendors, or patients. Violations may subject the entity and its personnel to criminal and administrative penalties.
6. Financial relationships with physicians and other referral sources:  Federal and state laws affect contracts, agreements, and other financial relationships with physicians, practitioners, vendors, and other referral sources.
   1. AIMA personnel shall not enter any contract or other financial arrangement with or give or receive anything of value to or from, an outside physician, a physician’s family member, or other referral source without the prior approval of the Compliance Officer.
   2. AIMA personnel must comply with the terms of any approved contract or other financial arrangement with outside physicians, their family members, or referral sources. Failure to perform or improper modifications of such contracts or arrangements may violate applicable laws.
7. Improper inducements to Medicare or Medicaid beneficiaries: Inducements to Medicare, Medicaid, or other government beneficiaries may violate applicable law. AIMA personnel shall not waive or discount government beneficiary co-pays unless such discount complies with AIMA’s charity care policy. AIMA personnel shall not offer any other discount, gift, free items or service, or other inducements to government beneficiaries without first obtaining approval from the Compliance Officer.
8. Professional courtesies: AIMA personnel shall not offer or receive any free or discounted items or services to or from other health care providers, their family members, or their office staff unless such offer is consistent with AIMA’s Professional Courtesy Policy, or the offer has been approved by the Compliance Officer.
9. Improper billing activities: AIMA personnel shall not engage in false, fraudulent, improper, or questionable billings. Such improper activities include, but are not limited to:
   1. Billing for items or services that were not actually rendered.
   2. Billing for or rendering items or services that were not medically necessary.
   3. Submitting a claim for physician services when the services were rendered by a non-physician, or where a physician failed to provide the level of supervision required by applicable laws or regulations.
   4. Submitting a claim for payment without adequate documentation to support the claim.
   5. Signing a form for a physician without the physician’s authorization.
   6. Improperly altering medical records.
   7. Using a billing code that provides a higher payment rate than the correct billing code (i.e., “upcoding”).
   8. Submitting bills in fragmented fashion to maximize reimbursement even though third-party payors require the procedures to be billed together (i.e., “unbundling”).
   9. Submitting more than one claim for the same service (i.e., “duplicate billing”).
   10. If AIMA personnel have a question about the proper standard or procedure for documenting or submitting a claim, they should contact the Compliance Officer.
10. Unfair competition and deceptive trades: Federal and state antitrust laws prevent certain anti-competitive conduct, including collusive agreements among competitors to set prices; divide patient care or services; boycott other entities; etc. AIMA personnel should not engage in collusive discussions with competitors over such things as prices, employee wages, services to be rendered or eliminated, or division of patients or patient services without the Compliance Officer’s prior approval. Similarly, AIMA personnel should not discuss exclusive arrangements with third-party payors, vendors, and providers without first discussing the matter with the Compliance Officer. Finally, AIMA personnel should not engage in any deceptive acts relating to AIMA.
11. Privacy and confidentiality: AIMA personnel shall maintain the confidentiality of patients’ protected health information as required by AIMA’s privacy policies and applicable law, including but not limited to the Health Insurance Portability and Accountability Act (“HIPAA”) and its accompanying regulations, 45 C.F.R. part 164. AIMA personnel should not access patient information unless they have a need to access the information because of their job duties. To the extent feasible and allowed by law, AIMA personnel shall maintain the confidentiality of communications and records containing confidential information concerning co-workers; communications and records relating to AIMA’s confidential financial or business operations, trade secrets, credentialing, or peer review actions; documents prepared in anticipation of litigation; and communications with legal counsel for AIMA. This section shall not be construed to prohibit activity protected by the National Labor Relations Act.
12. Entities that contract with AIMA: AIMA personnel shall ensure that clients and other entities which contract with AIMA comply with the Compliance Program and cooperate with AIMA’s compliance efforts. If a contract or arrangement with an outside entity implicates any of the compliance concerns discussed above, AIMA personnel should refer the contract or matter to the Compliance Officer for review.  Nothing in this policy or Compliance Program shall be construed as an undertaking by AIMA to inspect, assume liability for or guarantee the performance of work or activities by independent client entities.
13. Questions concerning the Compliance Program: AIMA personnel shall seek clarification from or approval by the Compliance Officer before engaging in actions or transactions if there is any question concerning whether the action or transaction complies with applicable laws, regulations, program requirements, or AIMA policies.
14. Report suspected violations: AIMA may have an obligation to promptly repay money it improperly receives from third party payors within 60 days. It is essential that AIMA personnel:
    1. Comply with applicable laws, regulations, and policies; and
    2. Immediately report suspected violations or compliance concerns to their supervisor, department leader, or the Compliance Officer as set forth in the COMPLIANCE PROGRAM: Communication About Compliance Issues Policy.
15. Non-retaliation. AIMA personnel shall not retaliate against any person for reporting a suspected violation of any law, regulation, program requirement or AIMA policy relevant to the Compliance Program.

All AIMA personnel shall be required to review these Standards of Conduct and sign below confirming that they have reviewed the Standards as set forth above.