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CL Cressler Inc. "CCM"

Code of Conduct and Ethics


I. Overview

CL Cressler Inc., d.b.a. Care Capital Management “CCM” and d.b.a. Medicine Shoppe Pharmacy is committed to providing the highest level of quality service and products to its customers. The Code of Conduct and Ethics “Code” summarizes the values, principles and business practices that guide our business conduct. CCM’s “Code” outlines a set of basic principles to guide workforce members regarding the minimum requirements expected of them.

It is the responsibility of all workforce members to maintain a work environment that fosters fairness, respect, integrity and compliance with law and regulations. It is CCM’s policy to be lawful, highly principled and socially responsible in all business practices. All workforce members are responsible for ensuring they thoroughly understand and follow the standards and apply these guiding principles in the daily performance of their job responsibilities.

All of CCM’s workforce members must act in an ethical manner and adhere to all applicable legal requirements in the course of performing their duties on behalf of the Organization. This Code of Conduct, which is part of the Organization’s Compliance Program, is intended to be a clear and concise summary of fundamental ethical standards with which all its workforce members must comply when conducting business on the Organizations behalf.

Ethical Code:
1. We provide quality services to our customers and to the community in accordance with the highest professional and ethical standards.
2. We will abide by Federal, State, and local laws, and prevent abuse of any federal, state and private payer health care programs.
3. We do not discriminate on the basis of age, sex, race, creed, color, national origin or disability.
4. We fulfill our obligation to orient employees to their roles and to provide staff development education to maintain currency of knowledge and skills needed to competently serve our clients.
5. We adhere to standards of integrity in advertising, marketing, billing practices and managing the services we offer.
6. We take appropriate precautions necessary to ensure the safety of our employees and customers.
7. We take appropriate measures to provide our customers with respect, emotional support, and personal dignity.
8. We do not take advantage of anyone through manipulation, concealment, abuse of privileged information or any other unfair dealing practice.

II. Rules of Conduct

A. General Rules The “Code” provides broad-based standards and principles for CCM workforce members. Policies and procedures have been developed that provide day-to-day guidance.

B. Responsibility of the Employee Each employee of CCM is responsible for having read and understood the “Code and conducting themselves according to the principles and standards outlined in it. Workforce members must use their judgment as well as consult the sources of assistance listed below if they encounter questionable situations or ones on which they require additional guidance. Workforce members, at all times, must avoid even the appearance of illegal, fraudulent, or inappropriate behavior. CCM expects all workforce members and officers to conduct business on its behalf in an honest, fair, and ethical manner and in CCM’s best interest, without regard to personal considerations. Workforce members therefore must refrain from participating in any activities or business endeavors that could pose a conflict with their responsibilities to CCM and its customers.

C. Sources of Assistance All workforce members are expected to seek the advice of the Compliance Officer, Manager, or Human Resources when questions arise about issues discussed in this “Code” or that implicate the ethical standards or integrity of CCM or any of its workforce members. Workforce members are required to report suspected violations.

III. Definitions: SEE COMPLIANCE GLOSSARY

IV. Compliance With Laws, Rules, and Regulations
Workforce members must comply with all Federal, State and Local laws and regulations pertaining to their job duties, whether or not specifically addressed in these policies. As a provider of healthcare products and services, CCM is subject to numerous laws, including: fraud and abuse, false claims, anti-trust and anti-discrimination laws. This commitment helps ensure CCM’s reputation for honesty, quality and integrity. CCM expects full compliance with the laws and regulations that govern our business. The following are some of the activities that CCM utilizes to assure compliance:

  • Verifying that workforce members and other personnel are licensed or credentialed for their specific function within CCM
  • Screening potential and existing workforce members to ensure that they are not on the Office of Inspector General (OIG), the General Services Administration (GSA), or State Medicaid excluded list
  • Ensuring that enrollments and reenrollments in the Medicare and Medicaid programs occur on a timely basis and that changes of information are reported in accordance with the program requirements
  • Reviewing and updating policies to reflect changes in the supplier and quality standards.
  • Maintains accreditation with a Center for Medicare and Medicaid Services (CMS) approved accrediting body in order to continue to serve Medicaid and Medicare patients.
  • Auditing and monitoring business areas including but not limited to: billing, medication supplies, training, and marketing

V. INTERACTIONS WITH HEALTHCARE PROVIDERS & VENDORS

CCM expects workforce members to refrain from any conduct that could improperly influence any Healthcare Provider or Vendor to do business with CCM. Conduct that improperly influences Healthcare Providers or Vendors is illegal, unethical, and against CCM’s policies. Examples of improper influence include, but are not limited to:

  • Giving cash or gift certificates
  • Performing work on behalf of Healthcare Providers
  • Giving gifts of value (e.g. free merchandise, tickets to sporting events)

A. SALES AND PROMOTIONAL MEETINGS

It is appropriate for CCM to meet with Healthcare Providers or Vendors to discuss products and services. However, CCM’s workforce members shall not give Healthcare Providers or Vendors gifts, meals, tickets to sporting events, or other items that have independent value or that may improperly influence a Healthcare Provider’s or Vendor’s decision to do business with CCM. Also, any meeting with a Healthcare Provider or Vendor should occur at or close to the Healthcare Provider’s place of business.

The only exception is that CCM may pay for modest meals for business meetings with Healthcare Providers or Vendors and for receptions for attendees. However, the Healthcare Provider or Vendor must have a legitimate professional interest in the information being shared at the meeting or reception.

B. PROVISION OF SERVICES AND INFORMATION

It is appropriate to work with Healthcare Providers in a team approach to meet the interest of the patients. However, it is improper for CCM to undertake activities that are the responsibilities of a Healthcare Provider.

For example, while it is appropriate for CCM to provide instruction and education regarding insurance documentation requirements or the use of medications, it would be impermissible for CCM to coordinate a patient’s care or perform a hospital’s discharge planning.

VI. Interactions With Patients and Patient Groups

A. GIFTS TO PATIENTS

CCM expects Workforce Members to refrain from any conduct that could improperly influence any patient to purchase from CCM. Conduct that improperly influences patients is illegal, unethical, and against CCM’s policies. The only exceptions to this policy are blood glucose monitors and advertising items such as key-chains, water bottles, pens and the like. Under both exceptions, items should be no more than $10 individually, and no more than $50 in the aggregate annually per patient.

For the health benefit of patients, Workforce Members may give diabetic patients a blood glucose monitor in accordance with the Blood Glucose Monitor Policy. This exception only applies when a patient informs a pharmacist that his or her blood glucose monitor is non-functional. See Compliance: Blood Glucose Monitor Policy for more information on CCM’s policies and procedures.

B. GIFTS FROM PATIENTS

CCM does not allow workforce members to accept cash or gifts of value from patients. For example, workforce members should not accept tips from patients. However, workforce members may accept gifts of nominal value such as Holiday cards or home-made baked goods.

C. HEALTH FAIRS

As a community education effort, CCM may participate in community, hospital-sponsored or other health fairs. During the health fair CCM may hand out advertising items such as key chains, water bottles and the like or partner with Healthcare Providers to provide routine health screenings to the public.

However, it is inappropriate for CCM to give attendees free home medical equipment, supplies, accessories, parts, repair service, clinical advice or other services that would otherwise be billable to the Patient’s insurer. Raffles or chance drawings may be acceptable if all participants have an equal opportunity to win and the value of the gift meets established CCM guidelines or as approved by the Compliance Officer.

D. CONFIDENTIALITY

CCM is committed to protecting patient’s private health information from dissemination or un-authorized disclosure. Workforce members will maintain the confidentiality of all patient information and ensure any disclosure of information is in accordance with patient wishes, applicable law, and CCM policies. See HIPAA Privacy & Security Policies for more information on CCM’s policy.

VII. Interactions With Payers

CCM’s commitment to ethical business practices includes a responsibility to public and private sector third party Payers. This responsibility also extends to patients who are self-pay and patients’ co-insurance, co-pays and deductibles. CCM recognizes the importance of being informed about basic billing rules and procedures of Payers.

VIII. Conflicts of Interest

A “conflict of interest” exists when a person’s private interest interferes in any way, or even just appears to interfere, with the interests of CCM. CCM expects and requires its workforce members to act honestly and ethically and not to have conflicts of interest with CCM. For example, working for another company that is in competition with CCM or making decisions about CCM doing business with a company that a close family member or spouse works at are both conflicts of interest. See Compliance: Conflicts of Interest for more information on CCM’s policy.

IX. Business Ethics

CCM seeks to excel while operating honestly and ethically, and not by taking unfair advantage of others. Each employee should deal fairly with CCM’s customers, suppliers, competitors and other workforce members. No employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation or any other unfair-dealing practice.

Workforce members involved in marketing, sales and purchasing, contracts or in discussions with competitors have a particular responsibility to ensure that they understand CCM standards and are familiar with applicable laws. Because these laws are complex and can vary. Workforce members should consult with the Corporate Compliance Officer or CEO when questions arise.

X. Discrimination and Harassment

CCM is committed to providing a work environment that values diversity among its workforce members. All human resources policies and activities of CCM intend to create a respectful workplace in which every individual has the incentive and opportunity to reach his or her highest potential. CCM is firmly committed to providing equal employment opportunities to all individuals and will not tolerate any illegal discrimination or harassment of any kind. See Human Resources: Employee Handbook, for more information on CCM’s policy.

XI. Health and Safety

Each employee has a responsibility to ensure that CCM’s operations and products meet government and CCM standards. Since these laws are complex and subject to frequent changes, workforce members should consult with management if they have any doubt as to the lawfulness of any action or inaction. Violence or threats of violence and physical intimidation are not permitted. Likewise, substance abuse on the job compromises everyone‘s safety and will not be tolerated. See Human Resources: Drug and Alcohol Policy for more information on CCM’s policy.

XII. Accounting Records, Record-Keeping and Retention

CCM requires honest and accurate recording and reporting of information that is basic to our reputation for integrity. Workforce members, governmental agencies and auditors depend upon these reports to be accurate and truthful for a variety of reasons. It is the responsibility of each workforce member to protect and properly retain information required by law. See Pharmacy Operation: Maintenance & Retention of Records Policy for more information on CCM’s policy.

XIII. Obligation To Report

All CCM Workforce Members who become aware of a compliance concern or who observe actual or suspected violations of law or regulation; CCM policy, procedure, or the Code; and/or unethical or wrongful conduct, regardless of whether such violations are intentional are required to promptly report such situations. See Compliance: Reporting Compliance Concerns Policy for more information on CCM’s policy.

XIV. Non-Retaliation

No person who in good faith reports an actual or suspected violation of the law or regulation; CCM policy, procedure, or the Code; and/or unethical or wrongful conduct, will experience any retaliation or retribution for reporting, regardless of whether, upon investigation, a violation is found to have occurred. Retaliation is a violation of the CCM Compliance Program, and will not be tolerated. Workforce members who notice any retaliation must report it immediately. See Compliance: Non-Retaliation Policy for more information on CCM’s policy.

XV. Failure To Follow The Code

Violations of CCM’s Code, policies, or procedures; the law or regulation, unethical or wrongful conduct will result in disciplinary action up to and including termination. See Compliance: Enforcement of Standards through Discipline Policy for more information on CCM’s policy.

XVI. Regulatory and Industry Reference(s)

OIG Compliance Program Guidance for Durable Medical Equipment published in the Federal Register/ Vol. 64. No. 128/ Tuesday, July 6. 1999/ Notices, as well as any Guidance for Pharmacy/ Pharmacist Notices as published: http://oig.hhs.gov/authorities/docs/frdme.pdf

B. Federal False Claims Act
D. Federal Anti-Kickback Statute
E. Stark Law
F. www.dos.state.pa.us
G. New York State Board of Pharmacy