• CONFLICT OF INTEREST POLICY

  • The Board of Directors of Hospicare has adopted the following policy on conflicts of interest:

    Definition of Staff Member/Employee, Volunteer, and Patients "Staff/Employee" is meant to include those persons employed and paid by Hospicare. "Volunteer" is meant to include individuals who volunteer or donate their services, usually on a part- time basis, and without contemplation of pay. "Patients" refers to the people we serve.

    Personal Gain - You may not use your position, or knowledge that you obtain in pursuit of your employment, for your own personal gain or for the gain of any person other than a patient.

    Employee Gift Acceptance Policies - It is the policy of Hospicare that all employees shall comply with the provisions of state and federal laws governing the acceptance of gifts and gratuities and applicable conflict of interest regulations. In addition, employees must avoid the appearance of favoritism with regard to business relationships and are expected to act with integrity in the performance of their duties.

    Individual staff members may not accept gifts or services from vendors.

    Items received at conferences, seminars, or training events that are distributed to all attendees are not considered gifts. These items would include t-shirts, pens, trade show bags, or similar giveaways. Likewise, food and beverages provided to all attendees at receptions, breaks, or dinners are also not considered gifts. Door prizes awarded at these events are also not considered gifts, provided that all attendees had an opportunity to register and receive the prize.

    Acceptance of Gifts from Patients or their Families

    Employees may not accept any tip or gratuity from patients or their family members on a personal basis.

    Employees should disclose to their supervisors any gifts or offers of gifts.

    Employees should disclose to their supervisors any gifts or offers of gifts including those having a monetary value under $25 from patients or their family members.

    Cards, thank you notes, certificates, or other written forms of thanks and recognition are always acceptable.

    Giving gifts to patients or their family members

    Employees may not give gifts to patients or their family members, nor may they borrow money from them or lend money to them, nor engage with patients in the purchase or sale of any item.

    De minimis items such as pens, mugs, calendars, books, and other trinkets valued at less than $25 are not considered gifts. It is deemed that these logo items are gestures of good will and not significant enough to influence a person's decisions.

    Employees may not serve as a patient's executor, trustee, administrator, guardian, health care proxy, nor provide financial services, nor act for a patient under a power of attorney, except in those cases where the employee and the patient are related by blood, marriage, or domestic partnership.

    Employees must disclose to the Executive Director all known, potential, or possible conflicts of interest. Exceptions may be made in those cases where the employee and the patient have had a long-standing, prior relationship. The Executive Director shall disclose such conflicts involving himself or herself to the Board of Directors. The Board alone may grant approval for exceptions to this policy.

    Each employee is expected to conform to the letter and spirit of this policy. If an employee has any question as to whether there is a conflict of interest, the employee should speak with a supervisor, the Director of HR, or the Executive Director.

    A violation of this policy is grounds for discipline, up to and including termination or dismissal.

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