References for more information
Mission and Values
Health Plus is a not-for-profit health care plan committed to quality health care and dedicated to the health and well-being of our culturally diverse communities through partnerships with members, providers, and community-based organizations.
We strive for excellence through our commitment to:
- Our communities
- Quality
- Advocacy
- Cultural sensitivity & linguistic competence
- Respect and compassion
- Teamwork
- Members', providers', employees', and partners' satisfaction
- Accessibility and responsiveness
- Fiscal responsibility
- Health outcomes
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I. MESSAGE FROM THE HEALTH PLUS EXECUTIVE DIRECTOR AND THE CHAIRMAN OF THE BOARD
Health Plus is committed to providing quality services, fully complying with the law, and meeting the highest ethical practices for business conduct. This commitment to our employees, members, and other business partners is consistent with the values and standards of our parent organization, Lutheran Medical Center. The ethics and compliance program adopted by the Board of Directors supports and demonstrates Health Plus’s mission and sets the norm for how we do business. Our Code of Ethics and Business Conduct is the cornerstone of our ethics and compliance program. All Health Plus employees, officers, members of the Board of Directors, volunteers, and other individuals working at or on behalf of Health Plus are responsible for following the standards of behavior outlined in the Code. No list of standards or rules can cover every possible circumstance. If you run into a situation that is not specifically addressed in this document, you should apply the overall philosophy and concepts of the Code. If you ever have a question or a concern about anything in the Code, or its applicability to a specific circumstance, please discuss it with your supervisor or the Ethics and Compliance staff, or call the Ethics and Compliance Hotline. We expect our staff to be aware of and comply with our business ethics policies. If you suspect a violation of our policies, report it to your supervisor or to the Ethics and Compliance staff. You do not have to fear retaliation or negative actions if your report was made in good faith. Whether you are a new employee or have been with Health Plus for many years, we urge you to review the Code. Our ethics and compliance program depends upon everyone’s participation and support for its continued success. .
Do the right thing!
Sincerely,
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II. ABOUT THE CODE OF ETHICS AND BUSINESS CONDUCT
Health Plus is committed to providing access to quality health care in the communities we serve. To succeed in our mission, we must maintain our members’ trust as well as the trust and respect of our employees and our business partners. This trust rests on our commitment to the highest ethical standards in every aspect of our business. To preserve this trust, we must devote ourselves to maintaining high ethical standards in our relationships with our members, providers, vendors, consultants, business partners, and one another. We must live the values of integrity, honesty, fairness, and responsibility in all of our daily work activities, and, ultimately, in our provision of high quality health care services. Health Plus relies upon the integrity of its employees to comply not only with the letter of the Code of Ethics and Business Conduct (Code) but also with its spirit — and to ask questions if they are uncertain about any aspect of the Code. All Health Plus employees, officers, members of the Board of Directors, and other individuals working at or on behalf of Health Plus must comply with the Code and all federal, state, and local laws, rules, and regulations that relate to our business activities. We depend upon each employee at all times to rely upon his or her good judgment to do the right thing! The Code informs employees and those who do business with us of the conduct expected of them. Further, it enables us to identify, address, resolve, and prevent potential problems. .
A. COMPLIANCE WITH LAWS AND REGULATIONS
Health Plus’s business is based on agreements with New York State and New York City. When we accept government contracts, we must operate and deliver products and services in a manner that complies with those contracts, as well as with our own standards of integrity.
Health Plus employees must know and follow the laws, regulations, and Health Plus policies that apply to their job responsibilities. Health Plus provides training to its employees on these policies, rules and regulations on regular basis. Employees are required to participate in such training and are evaluated based on that training.
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B. Failure to Follow the Code
Health Plus takes the Code seriously. An employee’s failure to follow the Code, Health Plus policies and procedures, or applicable laws and regulations may result in serious consequences, up to and including termination, and/or criminal charges, reimbursement for losses or damages, and, where appropriate, reporting to a governmental authority. The following are some examples of actions that could result in disciplinary action:
- Violating or directing another employee to violate the Code
- Deliberately withholding relevant information or knowingly providing false information concerning a violation of the Code
- Retaliating, directly or indirectly, against another employee for reporting a suspected violation of the Code
- A manager’s ignoring actions by a member of his or her staff that may violate the Code
This Code will be enforced at all levels, fairly and without prejudice.
C. GUIDELINES FOR ETHICAL DECISION MAKING
Health care is governed by complex, demanding, and changing laws, rules, and regulations. Sometimes the application of these rules and regulations can create uncertainty and questions. The Code of Ethics and Business Conduct helps us to resolve any concerns or questions about business ethics, integrity, and Health Plus’s expectations.
If you are not sure about an action or decision, ask yourself:
- Is it consistent with this Code, Health Plus’s policies, and values?
- Is it fair, honest, and appropriate?
- Would I be embarrassed if my supervisor, coworkers, friends, or family learn of my actions?
If you are not sure whether an activity is wrong, speak to your immediate supervisor, or another member of management. You may also call the Ethics and Compliance Hotline or Department.
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D. REPORTING A POTENTIAL VIOLATION
If you are not sure about a situation, or if you believe your own conduct or that of another employee may have violated Health Plus’s Code or any law or regulation, you must report the suspected violation. Your identity will be kept confidential, subject to legal limitations.
Discuss the issue with your immediate supervisor who knows you and the issues in your workplace. Your supervisor is in a good position to understand your concerns. Give your supervisor an opportunity to resolve the issue.
If you still have concerns after talking with your supervisor or if you are not comfortable discussing the matter with your supervisor, you may discuss it with the next management level.
If you still have concerns, or if you are not comfortable discussing the matter with a member of the management team, contact the Ethics and Compliance Hotline or Department.
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E. ETHICS AND COMPLIANCE HOTLINE
The Ethics and Compliance Hotline is available any time, 24 hours per day, 365 days per year. The toll-free number is:
1-800-826-6762
Calls to the hotline may be made anonymously and without fear of retaliation. The calls are not traced and the information is treated in a confidential manner, subject to the limits imposed by law. If you call, please provide as much information as you can.
The hotline is intended to supplement – not replace – our management team or other corporate resources. It is best used when you believe that you have exhausted the normal channels of reporting problems. No employee is ever discouraged from reporting an issue through the Ethics and Compliance Hotline.
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F. NON-RELATION POLOCY
Health Plus has a non-retaliation policy to protect individuals who report ethical or legal issues in good faith. “In good faith” means an employee actually believes or perceives the information reported is true. Any person who, in good faith, raises concerns or allegations of possible violations of the Code, policies, procedures, laws, or regulations will not be discharged, demoted, suspended, threatened, harassed or in any other manner discriminated against in the terms and conditions of their employment. We want you to raise issues and concerns, and you may do so without any fear of retaliation or punishment.
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G. AT-WILL EMPLOYMENT
The Code does not create a contract of employment either expressly or implied. Nothing contained in the Code is intended to alter a person’s status of “employment-at-will” or other status with Health Plus.
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lll. OBLIGATIONS TO OUR MEMBERS
Our members are the reason we are in business. Health Plus is committed to providing access to quality, cost-effective health care services that respond to individual, family, and community needs. All contracted providers and vendors that provide services for Health Plus must conduct business consistent with the Code.
- We will serve our members in a professional manner with integrity, honesty, courtesy, and respect.
- We will communicate openly, honestly and professionally with our members.
- We recognize our members’ right to receive appropriate quantity and quality health care services without discrimination based on race, creed, gender, national origin, sexual orientation, age, physical or mental handicap or disability, type of illness or condition, need for health services, or source or amount of payment.
- We will allow only qualified, properly licensed individuals, practicing within the scope of their licenses, to provide health care services to our members.
- We will base utilization review decisions upon objective criteria and apply those criteria fairly and consistently. Clinical determinations to authorize or deny coverage will be made only by licensed, certified, or registered health care professionals and in accordance with all legal requirements.
- We will disclose to our members our financial relationships with other organizations and providers, if requested.
You should report deficiencies, errors, or any incidents of inferior health care services provided to members to your supervisor.
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lV. MARKETING PRACTICES
We are committed to promoting Health Plus and educating consumers ethically. We will provide sufficient information about health insurance options, and help members make informed choices.
We must comply with all laws, government regulations, and contractual requirements on marketing practices and consumer protection. All marketing materials must be approved internally and then by the appropriate state and city agencies prior to use. Health Plus provides trainings to its employees on policies, rules and regulations specific to their job responsibilities on regular basis. Employees are required to participate in such training and are evaluated based on that training.
We must be careful and honest in marketing. We will not engage in any of the following activities:
- deceptive marketing practices
- door-to-door solicitation of potential members
- unsolicited personal contacts with potential members, including cold calls
- direct marketing or distribution of materials in hospital emergency rooms
- distribution to potential members of marketing and sales materials that lack appropriate approval
- misuse of marketing or competitor information
- misleading or discriminatory enrollment practices
- misrepresentations of any kind
- tampering with documents, “coaching” potential members, or allowing potential members to tamper, alter, or “create” documents or otherwise engage in fraudulent activities
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V. PROTECTION OF CONFIDENTIAL AND PROPRIETARY INFORMATION
We will protect the company’s confidential and proprietary information, as well as nonpublic information entrusted to us by employees, members, providers, and other business partners.
We are committed to using and disclosing information only for its intended purposes. Confidential and proprietary information will be accessed, used, or disclosed by employees only as needed to perform specific job responsibilities.
Confidential information includes financial data, strategic plans, policies and procedures, and employee records. If you are not sure whether or not something is confidential, ask! .
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A. MEMBER INFORMATION
Confidential information also includes protected health information, or PHI. This means all individually identifiable health information or demographic information that is maintained or transmitted in any form or medium. PHI is information that:
- is created or received by Health Plus;
- relates to the past, present, or future physical or mental health or condition of a member, the provision of health care to a member, or the past, present, or future payment for the provision of health care to a member; and
- identifies a member, or could reasonably be used to identify a member.
PHI includes information collected for member applications, claims information, medical information, personal information (such as address, telephone number, and birth date), and eligibility information for public programs.
We will access and use only the minimum PHI necessary to process a claim, handle an inquiry, or otherwise perform our jobs.
We will not disclose PHI to persons outside of Health Plus unless allowed under the Health Insurance Portability and Accountability Act (HIPAA) and other applicable federal and state laws, or we have the member’s written authorization to do so. We will follow Health Plus’s policies and procedures for the handling of PHI. These requirements continue to apply even after we leave Health Plus employment.
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B. EMPLOYEE INFORMATION
We will not share other employees’ personal information with other persons or entities, unless required for business operations. This includes an employee’s salary, Social Security Number, age, status, type of leave, or banking information.
Employees who are also our members should be given the same protections as other members.
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C. INTELLECTUAL PROPERTY AND TRADE SECRETS
Intellectual property and trade secrets include all ideas, inventions, discoveries, improvements, and innovations. Health Plus owns all intellectual property that we make, create, develop, write, or conceive, on our own or with another person, while employed by Health Plus or contracted with Health Plus, if it relates or pertains in any way to Health Plus’s business. We will not disclose information about Health Plus’s intellectual property and trade secrets to people outside Health Plus.
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D. HEALTH PLUS BUSINESS AND “INSIDER” INFORMATION
We will not give confidential or non-public Health Plus information to people outside Health Plus, including competitors, suppliers, or outside contractors, without proper authorization. This includes financial information, member lists, computer data and computer programs, and descriptions of Health Plus’s processes, policies, or operations. We will not discuss Health Plus’s potential business relationships, purchases, mergers or acquisitions, or other organizational changes with people outside Health Plus unless authorized.
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E. PASSWORDS
We will protect and maintain the confidentiality and integrity of passwords and other personal security codes used to access our computer systems. We recognize that we are responsible for actions resulting from the use of our passwords.
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F. PHYSICAL SAFEGUARDS
In accordance with HIPAA privacy and security regulations, state law, and our policies and procedures, we will maintain confidential business documents and information under strict control at secure work-site locations, and will store them in locked file cabinets or offices. We will protect confidential materials from disclosure when copying, faxing, mailing, e-mailing, or speaking to others.
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Vl. CONFLICTS OF INTEREST
Whenever an employee’s personal interests, or the interests of immediate family members or close relatives, could conflict or appear to conflict with his or her job or Health Plus’s interests, the employee must report such interests to management. We will avoid any conflicts with the best interests of Health Plus and its members.
When we deal with persons or business entities on behalf of Health Plus, we will act in the best interests of Health Plus. We must award business solely on merit, getting the best value for Health Plus, and, wherever practical, on a competitive basis. .
Here are some examples of potential conflicts of interest that must be disclosed to management:
- Ownership by an employee or by a member of his or her family of an outside enterprise that does business with Health Plus, seeks to do business with Health Plus, or is a competitor of Health Plus.
- Hiring or supervising a family member or other closely related person. (A family member generally includes an employee’s spouse or domestic partner, parents or stepparents, children, siblings, grandparents, grandchildren, in-laws, and corresponding family members of the employee’s spouse or domestic partner).
- Using information that comes to us in the course of employment for personal investment or gain, or providing this type of information to family members or others.
- Being involved, directly or indirectly, in an outside commercial interest that could improperly influence our actions on behalf of Health Plus. This may include being an officer, director, manager, employee, or consultant of a competitor, vendor, or contractor of Health Plus.
- Engaging in any outside activity that could impair our job performance or interfere with our ability to perform our duties adequately.
Employees who date other employees should be sensitive to potential conflicts of interest caused by the dating relationship, particularly if their job responsibilities involve working together or if one member of the relationship works with any information prepared or transmitted by the other. Such potential conflicts should be brought to the attention of the employees’ managers so that the managers may reassign work or modify procedures to avoid any possible conflicts. Also, managerial employees should not date employees who work in their departments. Determining whether a conflict of interest exists is not always easy to do. If you have a question regarding a possible conflict of interest, you should seek advice from your supervisor or from the Ethics and Compliance Department
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VlI. GIFTS, GRATUITIES, AND FAVORS
Employees should avoid any actions that could create a perception that favorable treatment of outside entities was sought, received, or given in exchange for a gift, gratuity, or favor.
For this reason, we should not give or accept gifts, payments, fees, services, discounts, valued privileges, or favors, beyond common business courtesies of nominal value.
Under no circumstances will we accept or give kickbacks when obtaining or awarding contracts, services, referrals, goods, or business. A kickback means a willful offer to receive, request, or pay anything of value, including goods or services, in order to encourage or reward referrals of business. We must never offer to or accept gifts or other items of value from government employees.
Gifts to members, potential members, and applicants must be of nominal value, approved by Health Plus, and consistent with government regulations.
The following guidelines apply to business courtesies from vendors and other business associates:
- We may not accept gifts of cash (including checks, money orders, etc.) of any amount, or gifts valued at over $100. You must report offers of cash, or non-cash gifts in excess of $100, to the Ethics and Compliance Department. If you receive a gift exceeding $100 in value, you must report it to the Ethics and Compliance Department, which will advise you what to do.
- Employees are discouraged from giving gifts to members of Health Plus management at the level of supervisor or above. In no instance should you give a gift worth more than $25 to a member of management, unless approved in advance by a Chief.
- At a vendor’s invitation (not an employee’s request), an employee may accept a meal, refreshment, attendance at a local theater or sporting event, and/or other entertainment in connection with furthering Health Plus’s business interest, provided that the business courtesy:
- is of a reasonable value;
- is offered infrequently;
- is customary and a part of normal business practices;
- imposes no sense of obligation on the giver or recipient
- involves no special treatment, such as free services or special discounts;
- is not a loan or payment; and
- would not be perceived as likely to influence the employee’s business judgment.
If you are not sure about the appropriateness of a gift, contact the Ethics and Compliance Department.
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VlII. FRAUD AND ABUSE
Health Plus’s reputation for integrity and our continued success depends on each of us being honest and following all laws and regulations. Fraud, dishonesty, or criminal conduct on the part of any employee, officer or director or anyone doing business with the company will not be tolerated.
Fraud is knowingly lying, cheating, or withholding truth that results in an unauthorized benefit. Fraud includes but is not limited to:
- giving or receiving any incentive in exchange for referral of members or patients
- engaging in fraudulent or misleading marketing practices;
- providing false or misleading information to obtain payment;
- submitting false, fraudulent or misleading claims, such as:
- claims for services not delivered or received;
- claims for a service different from the service actually delivered or received;
- claims that do not follow applicable legal requirements
If you are not sure about the appropriateness of a gift, contact the Ethics and Compliance Department.
Abuse refers to practices that cheat or “game the system” and result in unnecessary cost to the state or federal government or to Health Plus. These include:
- providing more or fewer services than are medically necessary;
- payment or billing for services that are not medically necessary;
- failure to meet professionally recognized standards for quality health care
We must avoid situations or conduct that involves actual or potential fraud or abuse in our internal operations.
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lX. ACCURACY OF BOOKS, RECORDS, AND PUBLIC DISCLOSURES
We will ensure that all statements, communications, and representations to government agencies are accurate, complete, truthful, timely, and comply with applicable laws and regulations.
We must ensure that payments or other benefits to providers are supported by proper documentation that the services were, in fact, provided or, in the case of capitated agreements, available.
We will ensure that all time records, expense reports, and other reports that we prepare or submit are accurate. We will establish, maintain, support, and follow internal controls designed to reasonably ensure that transactions are authorized and that data are recorded and presented in a manner that is accurate, complete, current, and reliable.
We will retain and destroy records consistent with applicable laws, regulations, contracts, company policies, and business needs. We must never misrepresent facts or falsify or suppress records that may be relevant to a legal action or governmental investigation or audit. We will consult with and follow the instructions of management and the Ethics and Compliance Department.
We will not tolerate known false statements to a government agency or other payor. Any employee who makes a deliberate misstatement to a government agency or other payor risks criminal penalties and termination of employment.
We will cooperate with all reasonable requests for information from government and regulatory agencies. In so doing, it is essential that the legal rights of Health Plus and of our personnel involved are protected. Any governmental or regulatory inquiry, subpoena, or other legal document regarding our business, whether received at home or at the work place, must be forwarded immediately to the Legal Department.
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A. FALSE CLAIMS ACT
Under both the Federal and New York State False Claims Acts, it is illegal to knowingly present, or cause to be presented, a false or fraudulent claim or statement to the government. The term “knowingly” means acting not only with actual knowledge but also with deliberate ignorance or reckless disregard of the truth. Individuals or organizations violating the False Claims Act may be subject to large fines and possible exclusion from the right to participate in federal programs. Physicians and other providers are also subject to the False Claims Act. Health Plus has an obligation to monitor physician billing and follow-up on identified cases of potential fraud and abuse by providers.
Some examples of conduct that violates the False Claims Act are:
- knowingly submitting medical or premium claims to the Medicaid program for members not actually served by the plan;
- knowingly failing to provide members with services or access to services for which the plan has received premium payments; and
- knowingly submitting inaccurate, misleading, or incomplete Medicaid cost reports.
The penalty for filing a false claim, statement or concealing a material fact ranges from $5,000 to $12,000 per violation. The recoverable damages are between two and three times the value of the amount falsely received. In addition, the false claim filer may have to pay the government’s legal fees.
Individuals with knowledge of fraudulent or improper activity may file a lawsuit on behalf of the government, called Qui Tam. The Federal and New York state law prohibits retaliation against “whistleblowers” who file such lawsuits or otherwise assist the government in the prosecution of a violation of the False Claims Act. Whistleblowers may share in a percentage of the proceeds from such action or settlement. Health Plus adheres to a non-retaliation policy
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X. USE OF COMPANY RESOURCES
We will use and maintain Health Plus’s assets with care and respect, guarding against misuse, waste, abuse, loss, and theft. Health Plus’s assets include, but are not limited to, corporate data, business strategies and plans, financial data, and other trade secrets or confidential information about Health Plus business or its employees.
Health Plus’s property also includes all equipment, furniture, vehicles, office supplies, corporate funds, credit cards, employee time, and computer supplies and software.
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A. USE OF THE INTERNET AND OTHER ELECTRONIC SYSTEMS
Health Plus’s communication systems, including electronic mail, telephones, voice-mail, fax, and the Health Plus Intranet are the property of Health Plus and are provided for the company’s business use. However, occasional personal use is permissible as long as it does not affect job performance, cause a disruption to the workplace, or otherwise violate a company rule.
Company systems may not be used to send chain letters or personal broadcast messages or for viewing, sending, or receiving offensive or inappropriate materials. They also may not be used to conduct outside business or in support of any religious, political, or other outside activity not related to Health Plus’s business.
No communications using Health Plus’s communication systems are private. All such communications, and information contained on an employee’s company-issued computer or other electronic device, are subject to review by Health Plus management.
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B. UNAUTHORIZED SOFTWARE
We will follow state and federal laws pertaining to copyright protection. This includes the duplication of print materials or licensed computer software. The unauthorized copying or use of software may violate of federal copyright laws and could result in civil and/or criminal liability. Also, we must not take any of Health Plus’s commercial software products home for personal use. .
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Xl. CONTACTS WITH THE PUBLIC
We will avoid unauthorized communications with the public or press regarding company business. If you receive an inquiry from a newspaper or television or radio reporter, refer him or her to the Director of Marketing Communications and External Affairs.
You should not offer any information or attempt to respond to any questions posed by a reporter, no matter how innocent the question may appear. A reporter can distort even the most casual comment, however well intentioned.
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Xll. POLITICAL AND CIVIC ACTIVITIES
Employees are encouraged to vote and actively participate in the political affairs of their communities. These activities, however, must take place on your own time and at your own expense.
Health Plus will not participate in or support any political campaign on behalf of (or in opposition to) any candidate for public office. Employees must not associate Health Plus with or imply Health Plus’s endorsement of any personal political activity.
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Xlll. LOBBYING
Health Plus’s corporate funds may not be used to support or oppose any political candidate or political party. Health Plus will not pay any person to influence or attempt to influence an officer or employee of a public agency or a member of Congress or a state, city, or other legislature (or his or her employee) in connection with the award of a federal, state, or other government contract, grant, loan, or agreement.
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XlV. RESPECTING OUR FELLOW EMPLOYEES
Health Plus is committed to maintaining a work environment where we treat each other with honesty, dignity, and respect. Health Plus values diversity and the cultural contributions of all employees, regardless of their position, ethnicity, family status, age, race, sex, disability, religion, sexual orientation, or national origin. All employment practices are based on ability and performance.
- Health Plus seeks to be a responsible employer by providing opportunities for professional satisfaction, pride of work, and career growth for all employees.
- We have a fundamental responsibility to show appropriate respect for and consideration of one another, regardless of position, station, or relationship.
- Health Plus will not tolerate sexual advances, actions, comments, inappropriate physical contact, or any other conduct that is unwelcome, intimidating, or which otherwise creates an offensive or hostile work environment.
- Health Plus respects the right to work in an environment free from harassment, intimidation, violence, and discrimination, where employees’ privacy and dignity are valued and protected from offensive, obscene, or threatening behavior.
- Health Plus maintains a non-solicitation policy. An employee may not engage in a commercial activity, solicit contributions, or distribute non-work related materials in work areas or during the employee’s work time or that of the employees to whom it is directed. Exceptions for company-authorized activities may be authorized by Human Resources or the Executive Director. Additionally, modest departmental parties, such as baby and bridal showers, may be permitted by the department’s manager.
- Health Plus maintains a drug-free work place. We will not tolerate the possession, distribution, or use of illegal drugs or an employee being under the influence of illegal drugs or alcohol while on duty. The use of alcohol on company premises is not permitted unless approved by Human Resources or the Executive Director.
- Health Plus’s employees shall conform to the standards of their professions and exercise judgment and objectivity in the performance of their duties. Any differences of opinion in professional judgment should be referred to appropriate management levels for resolution.
- Employee safety is important to Health Plus. Health Plus will make a special effort to protect and help keep safe its employees who work in or outside of Health Plus’s offices. Health Plus has specific internal policies and procedures to address employee safety. Health Plus is committed to working cooperatively with employees to resolve safety concerns.
- We shall not permit any action of retaliation or punishment to be taken against an employee who in good faith reports a violation or suspicion of a violation of a law, regulation, company policy, or this Code of Ethics and Business Conduct.
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XV. CODE OF ETHICS AND BUSINESS CONDUCT ACKNOWLEDGMENT
When you begin working for Health Plus, and each year after that, you must certify that:
- You have received, read, understand, and agree to abide by the Health Plus Code of Ethics and Business Conduct.
- You understand that all employees of Health Plus are expected to abide by the Code of Ethics and Business Conduct and that it is not a guarantee of continued employment with Health Plus.
- You understand that you have a responsibility to report questions or concerns regarding compliance with laws, regulations, contract provisions, or Health Plus policies to your supervisor, another member of management, or the Ethics and Compliance Hotline or Department.
- You understand that there will be no retaliation for raising a compliance issue in good faith.
- You understand that any violation of the Code of Ethics and Business Conduct may result in corrective action and/or disciplinary action up to and including termination.
- You understand that your failure to cooperate in a compliance investigation can be grounds for termination.
We count on you to do the right thing!
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XVl. REFERENCES FOR MORE INFORMATION
Ethics and Compliance Department 1-718-840-4592
Ethics and Compliance Officer 1-718-491-8386
Human Resources 1-718-491-8326
Marketing Communications and External Affairs (for media inquiries and contacts) 1-718-491-7493
Ethics and Compliance Hotline 1-800-826-6762
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What is Health Plus?
