Code of Ethics and Conduct

Message from the Chief Executive Officer

The Code of Ethics and Conduct (the Code) serves as Care Plus Bergen, Inc.’s, foundation for expectations and behavior-related to workplace conduct and professionalism. For the Code to be effective, all Bergen New Bridge Medical Center employees, physicians, contractors, and vendors must participate. We must each take the responsibility to raise concerns or questions regarding potential violations of the Code and we must do so without any fear of retaliation from anyone at Bergen New Bridge Medical Center.

The Code is intended to be comprehensive and easily understood but it is not meant to answer every question that might come up during your work here at Bergen New Bridge. The Code is meant as a guideline to knowing and upholding your legal and ethical responsibilities. Policies, procedures, and training will add more detail and information to the expectations of the Bergen New Bridge workforce.

Work is more engaging and meaningful in an ethical and respectable culture. We are all part of our organization’s culture and part of improving and encouraging these types of behaviors. A culture guided by these positive behaviors help not only our workplace but patient and resident care and safety.

The Care Plus Bergen Principles of Behavior are:

  • Be courteous and show dignity to everyone you encounter.
  • Hold ourselves and each other accountable.
  • Make every interaction respectful and meaningful.
  • Care with commitment, integrity and compassion.

We are privileged to be part of a team with a mission to provide high quality, compassionate, cost-effective healthcare services to our community, including the underserved, and to be the leader of healthcare in Bergen County. With this privilege comes a shared commitment and responsibility to each other, our patients, our residents, and the communities we serve. Remember the core values that we strive to embody are Integrity, Quality, Dedication, Diversity, Family, Innovation, Teamwork, Education, Efficiency, and Inclusion.

 

Deborah D. Visconi
President and Chief Executive Officer

Our Commitment to Compliance

The Code of Ethics and Conduct

The Code provides guidance for how we can carry out the mission and vision of Care Plus Bergen, Inc., the manager and operator of Bergen New Bridge Medical Center. The Code reflects Care Plus Bergen, Inc.’s, core mission and vision, which are to:

  • Provide high quality, compassionate, cost effective healthcare services to our community, including the underserved;
  • To be Northern New Jersey’s leading healthcare center providing a unique and integrated approach to both acute and LTC medical, substance abuse, and behavioral disorders for patients and residents of all ages.

Our Code provides guidance for you to respond properly when compliance/privacy-related issues arise. It is designed to assist you in the performance of your job within appropriate moral, ethical, and legal standards. The Code is not intended to cover every situation. Rather, it can help you make the right decisions or ask the right questions.

The Code and the associated Care Plus Bergen, Inc. policies and procedures apply to everyone who has a relationship with our organization, including but not limited to Board of Trustee members, officers, employed and non-employed staff, vendors, consultants, and contractors. We also expect all individuals and organizations working on behalf of Care Plus Bergen, Inc., to adhere to the ethical standards set out in the Code.

We expect and require everyone affiliated with Care Plus Bergen, Inc., to perform their job duties and responsibilities in a law-abiding, honest, and trustworthy manner. 

We are committed to having an ethical environment at Care Plus Bergen, Inc.,  founded on these principles:

  • Treat all patients, visitors, and workforce members with respect, dignity, integrity and compassion;
  • Know, understand, and adhere to laws, regulations and Care Plus Bergen, Inc. policies relevant to job duties;
  • Treat all patients based on clinical needs;
  • Screen and stabilize all patients who seek emergency medical treatment regardless of ability to pay;
  • Report any potential conflicts of interest, including taking anything of value for referrals; and
  • Report any compliance or HIPAA concerns through appropriate channels.

Everyone at Care Plus Bergen, Inc., is responsible for maintaining an ethical environment. Your actions in the workplace must demonstrate your commitment to honesty, respect, dignity, integrity, and compassion. You will be held accountable every day. Your job performance will be evaluated, in part, based on your compliance with the Code, Care Plus Bergen, Inc.’s Human Resource Standards, and with Care Plus Bergen, Inc.’s compliance/HIPAA related policies and procedures.

Certain Care Plus Bergen, Inc. compliance policies are referenced in this Code. Other compliance policies can be reviewed on the Public Folders or from a supervisor in printed form. 

You have a duty to know, understand, and comply with the requirements of all Care Plus Bergen, Inc.  policies, regardless of whether they are referenced in this Code.   

Care Plus Bergen, Inc.’s Compliance Program

Care Plus Bergen, Inc.’s compliance program demonstrates the organization’s firm commitment to the highest standards of ethics and compliance.

 

The Chief Compliance Officer leads the program and reports to the Board of Trustees. Operationally, the Chief Compliance Officer reports to the President and CEO of Care Plus Bergen, Inc.

 

The Compliance Department carries out the day-to-day implementation of the compliance program.

Special Responsibilities of Supervisors, Managers, Directors, and Leadership
  • Set an example by acting as a role model for the Code, Care Plus Bergen, Inc.  Principals of Behavior, and organizational expectations;
  • Make sure work areas reflect Care Plus Bergen, Inc.’s commitment to compliance and quality healthcare;
  • Emphasize, educate, and support the importance of the Code to the workforce;
  • Management must maintain an open environment that encourages workforce members to raise concerns;
  • Management must impose consistent and appropriate discipline as needed and foster a culture of no retaliation for reporting concerns; and
  • Promote honesty and integrity and act as a model for others.
Discipline

Anyone employed by Care Plus Bergen, Inc., who violates the Code or related policies and procedures will be subject to progressive disciplinary action. The discipline imposed will be determined on a case-by-case basis and will depend upon the nature, severity, and frequency of the violation.

 

Possible disciplinary actions include:

  • Verbal warning
  • Written warning
  • Suspension; and
  • Termination of employment.

Please contact the Office of Corporate Compliance whenever you have questions about any compliance-related issue. Care Plus Bergen, Inc.’s Human Resources staff also can provide guidance on workplace issues arising from the Code of Ethical Conduct and/or Care Plus Bergen, Inc.’s policies and procedures. 

Duty to Comply and Report

Reporting Obligations

It is the duty of every Trustee and workforce member of New Bridge Health Systems to comply fully with all governing laws, regulations, Care Plus Bergen, Inc. policies and procedures, and this Code. Everyone must offer their complete cooperation with any investigation by Care Plus Bergen, Inc., and/or governing authorities.

 

You are required to report to the Compliance Officer or the Compliance Helpline any actual or suspected violations of the Code, Care Plus Bergen, Inc. policies and procedures, and/or federal or state law. You must also report any other compliance/HIPAA-related issues, including but not limited to conflicts of interest, patient privacy and security, fraud, or other misconduct of any type relating to Care Plus Bergen, Inc.’s operations. 

Consequences for Not Reporting Potential Compliance Issues

The failure to comply with the laws and/or to report suspected violations of state or federal law can have serious consequences for Care Plus Bergen, Inc., and for any affiliated individual who fails to comply or report. The individual may be terminated from employment (or from his/her contractual arrangement with Care Plus Bergen, Inc.) or be subject to other disciplinary measures, depending on the nature of the violation.   

 

Concerns should be reported using any of the following ways:

  • Contacting supervisor or department leadership;
  • Contact the Compliance Helpline at 888.203.9067 to make an anonymous report, or via email CorporateCompliance@newbridgehealth.org.           
  • Contact the IT Helpline at 201.967.2222 or by email to helpdesk@newbridgehealth.org about any lost or stolen electronic device, or
  • Contact the Human Resources Dept. at 201.967.4151 about issues related to payroll, discipline, or harassment.
Non-Retaliation and Non-Intimidation

Care Plus Bergen, Inc., will enforce the whistleblower protections under the law.  Care Plus Bergen, Inc., will prohibit anyone from retaliating against or intimidating an employee who discloses a compliance/HIPAA concern. Care Plus Bergen, Inc., will immediately investigate and take appropriate action with respect to all suspected acts of retaliation or intimidation. Any individual who is found to have retaliated or intimidated a workforce member in any way will be subject to immediate progressive discipline based on the nature of the offense.

Responding to Potential Compliance Issues

Care Plus Bergen, Inc., is committed to investigating all reported concerns promptly, thoroughly and confidentially, to the extent possible and appropriate. The Chief Compliance Officer will direct the investigation of any compliance concerns or reports. When an internal investigation substantiates a reported violation, we will initiate corrective actions or other changes needed to remedy the problem.

 

These actions can include making prompt repayment of any government funds to which we are not entitled, notifying the appropriate government agency, instituting disciplinary action, and implementing systemic changes to prevent a re-occurrence of the problem.

We do not permit anyone to retaliate in any manner against an individual who reports any potential compliance problem or violation of law in good faith.  

Under the Deficit Reduction Act of 2005, any employer who receives more than $5 million per year in Medicaid payments is required to provide information to its employees about the Federal and NJ State False Claims Acts, the rights of employees to be protected as whistleblowers, and the employer’s policies and procedures for detecting and preventing fraud, waste, and abuse. 

 

The Act also imposes liability on individuals who knowingly submit a false record in order to obtain payment from the government or who obtain money from the federal government to which he/she is not entitled and then uses false statements or records in order to retain the money.

 

The Act permits private parties to bring actions to recover money on behalf of the United States and to share in a percentage of the proceeds obtained by the government.  Persons who bring these actions are protected against retaliation.

Deficit Reduction Act of 2005 – False Claims Acts

Examples of false claims include:
  • Billing for a higher level of services than were actually performed;
  • Billing for services that were not medically necessary;
  • Billing multiple codes instead of one for a drug panel test to increase reimbursement;
  • Submitting a claim under one patient’s name when services were provided to another person;
  • Signing off on a record using someone else’s name;
  • Altering claim forms or medical records;
  • Billing for services provided by an unlicensed provider;
  • Failing to repay overpayments within 60 days of identification;
  • Submitting false or inaccurate pricing or rebate information on pharmaceuticals to a Federal healthcare program;
  • Enrolling a beneficiary in a Medicare Advantage program without the beneficiary’s consent;
  • Billing for resident services without required supervision and documentation.

Our Commitment to Our Patients

High Quality Patient Care

Care Plus Bergen, Inc.’s number one priority is the delivery of the highest quality of care possible. Our main concern is for the well-being, comfort, and dignity of our patients and residents. We do not make any distinction in the availability of services or the care we provide based on age, gender, disability, race, color, religion, national origin, actual or perceived sexual orientation, marital status, veteran status, any other class protected by law or based on the source of payment for the patient or the patient’s ability to pay.

  • We treat all of our patients and residents equally with compassion, integrity, respect, and dignity;
  • We provide only medically necessary and appropriate care,
  • We make clinical decisions based upon identified healthcare needs regardless of how Care Plus Bergen, Inc., is reimbursed or compensated; and
  • We will provide and help patients understand the financial assistance available to them.
Patient Choice

All patient care at Care Plus Bergen, Inc., is administered in accordance with the “Patient’s Bill of Rights in the State of New Jersey”. Every patient is provided with a statement of these rights and with a Notice of Privacy Practices. These patient rights include:

  • The right to make decisions regarding medical care;
  • The right to refuse or accept treatment;
  • The right to informed decision-making;
  • Rights related to how the patient’s health information is used and maintained by Care Plus Bergen, Inc.
Emergency Treatment

We follow the Emergency Medical Treatment and Active Labor Act (EMTALA) in providing an emergency medical screening examination and necessary stabilization to all persons who present themselves for emergency care, regardless of ability to pay or any other discriminatory factor. Patients with emergency medical conditions are transferred to another facility at the patient’s request or if the patient’s medical needs cannot be met by Care Plus Bergen, Inc., because we do not have the capacity or capability to do so. Patients must consent to any transfer and all transfers are accomplished in strict compliance with state and federal EMTALA regulatory and statutory requirements.  

Protecting Patient Information

We demonstrate our respect for our patients by protecting the confidentiality of all personal information they share with us for the purpose of receiving quality medical care. This information, known as “Protected Health Information” or PHI, can include patients’ names, addresses, phone numbers, social security numbers, medical diagnoses, family illnesses, financial information, and other personal information. Federal and state laws, including the Health Insurance Portability Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health (HiTECH), as well as quality of care standards, require us to keep this information confidential. Care Plus Bergen, Inc. workforce members who are patients in our facilities also must be accorded the highest level of confidentiality with respect to their medical records and the Protected Health Information contained in them.

 

We must never use, disclose, or discuss patient specific information except as necessary for patient care or as required by law for treatment, payment for services, or legitimate business operations. Subject to emergency exceptions, patient and member privacy will be protected and patient specific information will be released only to persons authorized by law or by the patient’s written authorization.

 

Some examples of inappropriate use or disclosure are:

  • Discussing patients’ cases in a public area where conversation may be overheard by others;
  • Permitting access to a patients’ record by individuals who are not involved in legitimate activities relating to the patient;

or

  • Accessing employees’ medical records when they are receiving medical care at our facilities unless it is for treatment, payment or healthcare operations.

If you are unsure of the rules governing the release of patient related data, ask and be sure you understand them before you release any information.

Anyone affiliated with Care Plus Bergen, Inc., who engages in the unauthorized use or disclosures of patient information will be subject to progressive disciplinary action up to and including termination of employment and may also be subject to civil and criminal penalties.

Technology Security

In addition to the privacy of protected health information, all workforce members must take extra precautions when using the technology at Care Plus Bergen, Inc. All systems, computers, mobile devices, medical equipment and other forms of technology are to be used in accordance with all organizational policies and procedures and rules and regulations. All computers, mobile devices, and other forms of technology provided to you by the organization, are the property of Care Plus Bergen, Inc., and used for job-related tasks and not for personal use.

 

Passwords are never to be shared and access is based on a job-related need-to-know basis. Every precaution must be taken when using technology, but if anyone is concerned the system has been misused, breached, or other concerns, should report the information immediately to the IT Helpdesk at 201.967.2222 or by email to helpdesk@newbridgehealth.org. The newbridgehealth.org email is to be used for work purposes. No personal (i.e., gmail, AOL, etc.) should be used. Confidential information sent outside newbridgehealth.org must be encrypted. On the subject line the word ‘Encrypt’ should be inserted. Cell phones are not to be used for pictures and videos within the facility and no texting of confidential information is permitted. All workforce members will be given specific instructions around the technology they will be using and they must adhere to all restrictions and procedures.

Patient Records

Care Plus Bergen, Inc., makes every effort to ensure entries made into patient’s records are clear and complete and record exactly the service provided to the patient.  Care Plus Bergen, Inc., strives to ensure patient records do not contain guesswork, exaggeration, or miscoding. 

Credentialing

One important aspect of our commitment to high quality care is the proper credentialing of all healthcare providers associated with Care Plus Bergen, Inc.   

 

We conduct credentialing reviews for:

  • Hospital employees whose work requires a license; and
  • Temporary and non-employed staff, such as voluntary physicians, visiting physicians, and agency-employed nurses.

Credentialing reviews occur before the relationship between Care Plus Bergen, Inc., and the individual commences. We recheck those credentials at regular intervals in accordance with regulatory requirements.  We also conduct background checks on individuals who work in our facilities, regardless of whether their position requires a license, to ensure they do not have criminal backgrounds.

 

All employees, physicians, and vendors are checked against all relevant excluded provider lists each month in accordance with the generally accepted principles of NJ Medicaid Fraud List, NJ Consolidated Debarment Report, GSA Excluded Parties List, and other lists, as appropriate. Any individual found to be on any of the excluded lists will be separated from the facility.

If you become aware of an unauthorized disclosure of patient or member information,  you must report it immediately to your supervisor or to the Office of Corporate Compliance. 

 

Care Plus Bergen, Inc., prohibits retaliation  against any person who makes a good faith report of a privacy violation.

Adverse Event Reporting

New Jersey State law requires us to report to the Department of Health certain adverse patient events within 24 hours after their occurrence.  Our healthcare providers are required to report such incidents to designated Care Plus Bergen, Inc. administrators immediately upon learning of them. Failure to do so constitutes an unacceptable practice and is grounds for discipline. 

Marketing and Advertising

We market Care Plus Bergen, Inc.’s services in a fair, truthful, and ethical manner and adhere to the applicable federal and state regulatory standards. Our marketing materials are designed to reflect only the services available and the level of the providers’ licensure and accreditation. Care Plus Bergen, Inc., uses marketing and advertising to educate the public, report to our community, and increase awareness of our services and to recruit staff members. Any use of the Care Plus Bergen, Inc.’s logo, name, or trademarks in any public marketing material or social media must have prior consent. 

Our Commitment to Government Regulators

Coding and Billing

One of the important aspects of the Care Plus Bergen, Inc.’s commitment to compliance is the dedication to the preparation and submission of accurate claims for payment to federal and state health care programs.

 

All claims for payment for any service provided by Care Plus Bergen, Inc., must be supported by complete documentation in the medical record, proper coding based on that record, and bills that accurately reflect the coding. We can bill only for those goods and services actually provided and medically necessary. Accurate and timely documentation also depends on the diligence and attention of clinical providers who treat patients in our facilities. We expect those providers to provide us with complete and accurate information in a timely manner.

 

Care Plus Bergen, Inc., should always bill accurately for services rendered in accordance with the law and with its agreements with third-party payers. When we receive a question from a patient or a third-party payer about an invoice or charge, we will promptly address the question or refer the matter to the person who is authorized to address it.

 

Under federal law, all identified overpayments must be refunded to the government payer within 60 days of identification. Failure to do so can result in fines and other penalties.

Cost Reports

Care Plus Bergen, Inc., receives reimbursement under federal and state healthcare programs. These programs require us to submit complete and accurate cost reports. These laws, regulations, and guidelines define what costs are allowable and outline the appropriate methodologies to claim reimbursement for the cost of services provided to program beneficiaries. 

Anti-Kickback/Bribes

Care Plus Bergen, Inc., strictly prohibits its employees and other service providers from offering, paying, asking for, or accepting money or other benefits in exchange for patient or member referrals, purchases, leases, or orders. 

Not-For-Profit Tax-Exempt Status

Care Plus Bergen, Inc., is a tax-exempt entity because of its charitable mission. We provide community benefits that include healthcare services, medical training, education, research, and community outreach activities. 

Antitrust

Care Plus Bergen, Inc., engages in activities subject to state and federal antitrust laws. Generally, these laws prohibit competitors from entering into agreements to fix prices or to reduce price competition. We should not provide information about Care Plus Bergen, Inc.’s business to a competitor. In addition, we are to refrain from engaging in unfair practices that might restrict competition.

Records Retention

Accurate and complete records are crucial for the continuity of patient care, appropriate and proper billing, and for compliance with regulatory, tax, and financial reporting requirements. Everyone who enters information into a medical record, business record, regulatory or financial report has a responsibility to do so in a truthful manner. These records must be retained by Care Plus Bergen, Inc., as required by federal and state laws. 

Response to Government Inquiries

Care Plus Bergen, Inc., cooperates fully with government inquiries and investigations. We do not prevent persons affiliated with Care Plus Bergen, Inc., from speaking with government officials. However, you should contact the Chief Compliance Officer (201.967.3807) or General Counsel (201.967.4313) before doing so. When we receive a request for documents or a subpoena, we refer it to the Legal Department, which will coordinate our response and ensure it is appropriate and complete. We never destroy, alter, or change Care Plus Bergen, Inc. records requested by or related to a government investigation.

Accreditation and Surveys

In preparation for, during, or after surveys, Care Plus Bergen, Inc. workforce members deal with all accrediting bodies in a direct, open, and honest manner. No action should ever be taken in a relationship with an accrediting body that would mislead the accrediting organization or its survey teams, either directly or indirectly.

 

Our business partners, suppliers, contractors, physicians, and others with whom we do business are vital to our success. We always treat them with respect, professionalism, and fairness.

 

We examine the background of our business partners before allying with them to ensure they demonstrate high standards of ethical business conduct.

Our Commitment to Our Business Partners

Supplier, Vendor, Subcontractor, Attorney, and Consultant Relationships

Care Plus Bergen, Inc., selects our suppliers, vendors, subcontractors, attorneys, and consultants based on the quality, price, delivery, and supply of their goods and services. We obtain these services only when there is a legitimate need for them. 

Referral of Patients.

We do not pay or offer to pay anyone – colleagues, physicians, or any other person or entity – for the referral of patients or members.

 

Similarly, we do not accept payments for referrals we make. When Care Plus Bergen, Inc., discharges patients and refers them to other providers, we ensure the referrals are based on the patient’s documented need for the referred services, the ability of the referred provider to meet the need, and patient choice. Our patient’s freedom to choose a service provider must be honored at all times. Financial relationships with providers with whom Care Plus Bergen, Inc., has a referral relationship are reviewed to ensure compliance with the relevant laws.

Gifts and Interactions with Industry

Care Plus Bergen, Inc., does not solicit, accept, make, or offer to make any payment nor does Care Plus Bergen, Inc., accept or provide anything of value to another person or company with the understanding or intention such payment is to be used for an unlawful or improper purpose. This includes payment for referrals. 

 

Any gifts or gratuities from any vendor must adhere to the Care Plus Bergen, Inc. policy on gifts and gratuities. Specific approval and criteria must be met and documented. 

Our Commitment to Our Colleagues

Conflicts of Interest

We have a duty to avoid conflicts of interest and a duty of loyalty to Care Plus Bergen, Inc. Our business conduct must always put Care Plus Bergen, Inc.’s interests ahead of our personal interest. All workforce members must adhere to and comply with the Care Plus Bergen, Inc. Conflicts of Interest policy. 

  • We do not use our positions or confidential information obtained in the course of our work for personal gain.
  • We make sure any outside jobs or positions do not conflict with our work at Care Plus Bergen, Inc.
  • We disclose to our managers and the Compliance Officer any potential conflicts of interest.

It is a violation of Care Plus Bergen, Inc.  policy to accept cash gifts of any amount provided in connection with our employment or job duties.

Examples of potential conflicts of interest include:

  • Acting as a director, partner, consultant, or employee of a firm that provides services, supplies, or equipment to Care Plus Bergen, Inc., or a competitor of Care Plus Bergen, Inc.
  • Having a material financial interest (or a family member having a financial interest) in a firm that is either a competitor of, or vendor or potential vendor to Care Plus Bergen, Inc.
  • Purchasing or leasing real estate that may increase in value based on knowledge that Care Plus Bergen, Inc., may have an interest in the property.
  • Hiring subordinates or Care Plus Bergen, Inc.  vendors to perform personal work for yourself or family without appropriate administrative approval.
  • Having your research funded by a company or evaluating a product owned, manufactured, or distributed by a company in which you (or a family member) have a financial interest.

Confidentiality of Business Data

In addition to patient information, other information created by Care Plus Bergen, Inc., in the conduct of business, such as staff data, financial data, development plans, proprietary research data, making strategies, or information about pending or contemplated business deals, is confidential information that belongs to Care Plus Bergen, Inc. All data relating to employees, including data generated when employees are patients at Care Plus Bergen, Inc., is strictly confidential. 

We are obligated to avoid conduct that could create a conflict of interest.

When you receive confidential information in the course of performing your job duties, you must not use it for your own or your family’s benefit and you may never disclose it to others for their personal use.

Information received by Care Plus Bergen, Inc., under an obligation to maintain its confidentiality, is also confidential information which, if you receive such information, is to be utilized only for the purpose for which it was provided and may not be disclosed in violation of the obligation to maintain its confidentiality.

Substance Abuse and Impairment in the Workplace

Care Plus Bergen, Inc., works diligently to maintain an alcohol-free and drug-free environment. If we suspect you are under the influence of drugs or alcohol, you will be required to submit to appropriate drug or alcohol testing. If you are found to be performing any activity for Care Plus Bergen, Inc., while impaired by or under the influence of alcohol or illegal drugs you will be subject to disciplinary action up to and including termination of employment, as appropriate. 

Controlled Substances

Pharmaceutical drugs may be handled only by properly authorized individuals who do so as a part of their job duties and responsibilities.  You may not under any circumstances divert pharmaceuticals for personal use or sale. You are expected to protect the integrity of Care Plus Bergen, Inc., by safeguarding the drugs entrusted to you. 

Non-Discrimination and Equal Employment Opportunity

Care Plus Bergen, Inc., promotes diversity in its workforce at all levels of our organization.  We are committed to providing a work environment where everyone is treated with respect, courtesy, and dignity. We are an equal opportunity employer and do not discriminate on the basis of race, color, creed, religion, gender, national origin, actual or perceived sexual orientation, veteran status, age, or disability.

 

We comply with all laws, regulations, and policies relating to equal employment opportunity in hiring, reductions in force, transfers, terminations, evaluations, recruiting, compensation, promotions, and discipline.  We make reasonable accommodations to the known physical and mental limitations of qualified individuals with disabilities.

Harassment

Care Plus Bergen, Inc., strives to provide a workplace free from harassment and disruptive behavior. Degrading jokes, slurs, intimidations, or other harassing conduct are not acceptable at Care Plus Bergen, Inc. 

 

Sexual harassment can be particularly harmful to the work environment and is prohibited.  This prohibition includes unwelcome sexual advances or requests for sexual favors in conjunction with your employment. Verbal and physical harassment or abuse and any other behavior that creates an intimidating, hostile, or offensive work environment have no place at Care Plus Bergen, Inc. If you engage in this conduct, you will be subject to progressive discipline.

 

If you observe or experience any form of harassment or violence, you must report it to you supervisor, the Human Resources Department, any member of management, the Chief Compliance Officer at 201.967.3807, or the compliance helpline at 888.203.9067. In addition, a Work-Related Incident Form should be completed and submitted in accordance with the Care Plus Bergen, Inc. policy.

Leadership and Professionalism

Care Plus Bergen, Inc., is committed to the highest standards of excellence in the practice of medicine and strongly believes collaboration, communication, and cooperation are essential for the provision of safe and competent patient care.

 

Appropriate professional and cooperative behavior means any reasonable conduct intended to advocate for patients, to recommend improvement in patient care, and to participate in the operations, leadership, or activities of the staff, including the Medical staff. Behaviors that undermine a culture of safety include but are not limited to:

  • Use of profanity in the workplace;
  • Refusal to speak or respond to others;
  • Inappropriate physical contact;
  • Sexual, religious, racial, or other unlawful harassment;
  • Throwing objects; or
  • Any destruction of Care Plus Bergen, Inc. property.

Violations of the Code by any workforce member will be addressed in accordance with our policies. Violations by providers credentialed by the medical board, physician trainees, and medical students will be addressed by the procedures provided for in the By-laws, Rules, and Regulations of the Medical Staff and the relevant Care Plus Bergen, Inc. policies. Issues relating to non-credentialed workforce members will be addressed by the policies in the Human Resources policy manual.

 

Anyone who observes or is subjected to inappropriate conduct by any workforce member can notify their supervisor, Human Resources Department, Chief Compliance Officer, the Compliance Helpline at 888.203.9067, or via email at CorporateCompliance@newbridgehealth.org. Employees who make such reports in good faith cannot be retaliated against for making the report.

Health and Safety

Care Plus Bergen, Inc., is committed to providing a workplace that is safe, healthy, smoke-free, and in compliance with all applicable laws and regulations.

 

It is important that you immediately advise  your supervisor of any workplace injury or any circumstance presenting a danger of injury so timely corrective action can be taken to resolve the problem. In addition, a Work-Related Incident Form should be completed in accordance with the Care Plus Bergen, Inc.  policy.

Environmental Protection

We are to dispose of all waste and other materials and store all chemicals and substances in accordance with applicable laws and regulations. It is important to file all necessary environmental reports accurately and promptly and to cooperate fully with all governmental authorities in the event of an environmental incident.

Use of Care Plus Bergen, Inc. Resources

Each of us is responsible for preserving Care Plus Bergen, Inc.’s assets including time, material supplies, equipment, and information.  All communication systems including, but not limited to, telephones, computers, electronic mail, intranet, Internet access, and voice mail are the property of Care Plus Bergen, Inc., and are to be used primarily for business purposes in accordance with Care Plus Bergen, Inc. policies.

Intellectual Property

Care Plus Bergen, Inc., is committed to adhering to all applicable intellectual property laws. We will respect the intellectual property and copyright laws regarding books, trade journals, and other applicable resources. All software used in connection with Care Plus Bergen, Inc. work must be properly licensed and used in accordance with the terms of that license. 

All individuals associated with Care Plus Bergen, Inc., must treat others with respect, courtesy, and dignity and must conduct themselves in an appropriate, professional, and cooperative manner.

Screening of Excluded Individuals and Entities

Care Plus Bergen, Inc., will not knowingly employ, appoint, elect, contract, or bill for any individual or entity that has been listed as debarred, excluded, or is otherwise ineligible for participation in federal or state healthcare program. Monthly, we search the lists of excluded and ineligible persons in NJ Medicaid Fraud List, NJ Consolidated Debarment Report, GSA Excluded Parties List, and other databases as needed and appropriate.

 

You are required to report to Care Plus Bergen, Inc., if you become excluded, debarred, or ineligible to participate in federal or state healthcare programs or have been convicted of a criminal offense related to the provision of healthcare items or services.

Media Relations

All media representative requests for information should be referred to the Public Relations office at 201.225.7141 or publicrelations@newbridgehealth.org.

 

Employees should never release information without the permission of the Public Relations Department.

Responsible Use of Social Media

Protected Health Information, employee health information, and confidential business information (such as Care Plus Bergen, Inc. business plans or contracts) must not be posted on Facebook, Twitter, or any other social media site. Images and video may be posted only when advanced written permission is obtained from the Public Relations Department.

Compliance Resource

Chief Compliance Officer

Barbara Piascik
201.967.3807
Building 8, Floor 1, Room 104
bpiascik@newbridgehealth.org

Compliance Helpline

888.203.9067
CorporateCompliance@newbridgehealth.org

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