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All PHT/JHS employees must comply with all Federal, State, and local laws as well as all other government regulations. Any actual or perceived violation of this Code must be immediately reported to the PHT/JHS Office of Compliance.

A. Non-Discrimination
PHT/JHS is committed to making employment decisions and providing services without regard to race, color, creed, national origin, political beliefs, sex, gender or sexual preference or in any way participate in any unlawful discrimination.

B. Quality of Service
PHT/JHS is committed to providing services that meet all contractual obligations and PHT/JHS standards.

C. Contract Negotiations
PHT/JHS has an affirmative duty to disclose current, accurate and complete cost and pricing data where disclosure of such data is required under appropriate Federal or State laws or other regulations.

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D. Marketing and Advertising Activity
In conducting all marketing and advertising, PHT/JHS will provide honest information to the general public.

E. Anti-Trust and Trade Laws
It is the policy of PHT/JHS to comply with applicable anti-trust, trade, and similar laws that regulate competition.

F. Fraud and Abuse Issues
Federal and state laws prohibit PHT/JHS and its employees from offering payments or any items of value to induce anyone to purchase services from or to refer a patient to PHT/JHS. In addition, there are laws that prohibit filing false claims. These are highly complex areas of the law and employees must take special care in their respective area. Promptly refer any questions to the Compliance Office.

PHT/JHS has adopted various policies designed to ensure compliance with Federal and State anti-kickback laws. Examples of the types of action that could violate the Federal False Claims Act and other Federal false billing laws include, but are not limited to, the following:

1. Filing a claim for services that were not rendered at all or were not rendered as described on the claim form.
2. Filing a claim for services that were rendered but were medically unnecessary.
3. Submitting a claim containing information you know to be false.

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G. Charging Cost/Time Card Reporting
Employees must be particularly careful to ensure that hours worked and costs incurred are applied to the account for which the effort was required.

H. Billing and Reimbursement
PHT/JHS is committed to ensuring that its billing and reimbursement practices comply with all Federal and State laws, regulations, guidelines and policies. Further, we are dedicated to ensuring that all bills are accurate and reflect current payment methodologies, that all patients and customers receive timely bills, and that all questions regarding billing are answered timely, accurately and directly.

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I. Emergency Care
PHT/JHS will provide treatment to all individuals, regardless of the ability to pay, who have an emergency medical condition. PHT/JHS employees may not delay such treatment or the provision of an appropriate medical screening in order to inquire about the individual’s method of payment or insurance coverage. An individual may only be transferred from PHT/JHS to another facility in limited circumstances only after the individual has been stabilized and in accordance with the requirements set forth under governing Federal and State laws.

J. Advance Directive and Patient and Resident Rights
Employees shall comply with all PHT/JHS policies and procedures and Federal and State laws and regulations governing advance directives and patient and resident rights.

K. Providing Business Courtesies to Patients or Sources of Affiliates, Vendors or Agents
PHT/JHS’s success as a health care provider results from providing quality services. PHT/JHS does not seek to gain an improper advantage by offering business courtesies such as entertainment, meals, transportation or lodging to customers, referred sources, or purchasers of PHT/JHS services.

L. Receiving Business Courtesies from Patients, Affiliates, Vendors or Agents
In accordance with Miami-Dade County Code 2-11.1 (e) (3), it is the policy of the Public Health Trust (PHT) to prohibit employees from soliciting or demanding any gift. In addition, the PHT prohibits any employee from accepting, soliciting or receiving any gift having a value of more than fifty dollars ($50.00) from patients, relatives or friends of patients, or from firms or individuals doing business with or soliciting business from the PHT.

IV. Reporting to the Public Health Trust Board of Trustees
At least annually, the Chief Compliance Officer shall report to the PHT/JHS Board of Trustees concerning (1) the PHT/JHS adherence to standards of conduct contained in the Corporate Policy on the Code of Conduct, and (2) the compliance program in general.

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V. Reservation of Rights
PHT/JHS reserves the right to amend the Code of Conduct, in whole or in part, at any time and solely at its discretion, in accordance with the provisions set forth by the PHT/JHS administrative policies and procedures.

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To download the Compliance Standards & Code of Conduct, please click here.