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Code of Ethics and Business Standards

Ethical Excellence

Health First values its reputation in our community and in the region for providing quality care and services to our patients. We attribute our excellent reputation to the commitment, skill, and ethical standards of our employees, physicians, and business associates. As the delivery of healthcare services at a reasonable cost becomes more and more challenging, we need to assure that, from one day to the next, we continue to maintain our values of integrity, compassion, accountability, respect, and excellence.

Here at Health First, we strive to encourage and practice integrity in everything we do. To assist in this, we have developed a Code of Ethics & Business Conduct to present a clear statement of our standards of ethical behavior. The Code, which is only one component of our Corporate Ethics and Compliance Program, is distributed to all Health First employees, medical staff, and Board members. It provides a framework for thinking about and approaching day-to-day decisions for individuals working in the healthcare industry.

The Code of Ethics & Business Conduct is also available to our business partners. We want our vendors, community members, and business associates to be familiar with the contents of this Code and have a clear understanding of the fundamental principles which support our commitment to professional business ethics. This Code embodies the philosophy we live by and the expectations we hold for our business community.

For more information or a printed copy of our Code of Ethics and Business Conduct, please call us at (321) 434-5657.

Code of Ethics & Business Conduct, 9th Edition

Privacy

Violations of information privacy policies and procedures will not be tolerated. Depending on the role of the workforce member, appropriate actions will be taken. For example, employees who violate privacy policies will be subject to disciplinary action based upon Health First Human Resource Policies and Procedures, contractors who violate privacy policies will be in violation of contract specifications and will be acted on in accordance to specific contract language. Medical Staff members who violate privacy policies will be subject to disciplinary action according to the Medical Staff By Laws of the Health First Facilities.

HIPAA Compliance and Responsibility for Information Privacy and Security

Contractors that regularly work with protected health information (PHI), will be asked to sign a Confidentiality / Non-Disclosure Agreement.

Contractor Agreements with Relation to Protected Health Information

False Claims and the Deficit Reduction Act

As Health First associates, agents, or contractors, we are all involved either directly or indirectly with the provision of medical services, supplies, or equipment to beneficiaries of federal or state health care programs, such as Medicare and Medicaid, for which reimbursement is sought. Acting on behalf of Health First, we are each responsible for being honest and accurate in our business dealings and submitting honest and accurate bills to Medicare, Medicaid, and other federal and state health care programs, and for submitting honest and accurate invoices to Health First.

In addition to complying with the Heath First Code of Ethics & Business Conduct and other applicable Health First policies and procedures, all employees, agents, and contractors are expected to comply with federal and state laws and administrative remedies designed to prevent fraud, abuse, and waste in federal and state health care programs.

False Claims and the Deficit Reduction Act