Code of Conduct

Premier Customer Service through Compliance is Our Goal

Premier Customer Service through Compliance is Our Goal

Touchstone developed this Code of Conduct to serve as a guide for your behavior as a Touchstone Team Member. This Code of Conduct will not cover every situation that you might find yourself in, and some of the statements below may not be applicable to your job. However, it is Touchstone’s expectation that you will always try to do the right thing and act in a way that is consistent with Touchstone’s Purpose Vision and Mission.

I will always try to do the right thing, and I will do my best to act ethically and in compliance with the law and Touchstone policies.


I will do my best to abide by the Touchstone Purpose, Vision, and Mission and the Operating Agreement.

  • I will do my best to provide quality care to residents and I will respect resident rights.

  • I will do my best to make sure all care provided to residents is documented promptly and accurately.

  • I will not mistreat, neglect or abuse residents, and I will not take any resident property.

  • I will not tolerate any other person mistreating, abusing or neglecting residents, or taking their property.

  • I will immediately report any resident mistreatment, abuse, or neglect, or theft of resident property, to my supervisor, Community administrator, or law enforcement authorities.

  • I will treat other Team Members with respect.

  • I will not discriminate against any resident or Team Member on the basis of their sex, race, age, disability or any other protected category.

  • I will not offer, pay, ask for, or accept anything of value in exchange for the referral of a patient or other business that is paid for by Medicaid, Medicare or other government programs.

  • I will keep residents’ medical records and other protected health information confidential and secure.

  • I will do my best to make sure that all claims for reimbursement accurately reflect the care provided and are consistent with billing rules and guidelines.

  • I will do my best to make sure that all Medicaid and Medicare cost reports are accurate and consistent with applicable rules and guidelines.

  • I will do my best to make sure that any overpayments from Medicare, Medicaid or other government programs are promptly reported and repaid.

  • I will do my best to make sure that all business transactions are accurately recorded in the company books and represent payment for goods or services actually provided.

  • I will respect company property, and will not waste it or use it for personal gain.

  • I will report any actual or suspected violations of applicable laws, of this Code of Conduct, to my supervisor, the Community administrator, or the Touchstone Compliance Department, by calling (877) 995-0950 or visiting the website (www.mycompliancereport.com). I understand reports are confidential and can be anonymous.

  • I will not retaliate or discriminate against anyone who reports a violation, or a suspected violation, of any applicable law or this Code of Conduct.

High-Level Oversight

Resources

Screening

Communication and Training

Consistent Enforcement

Response to Violations

Annual Review

Carl Fellbaum is chief compliance officer, Touchstone’s senior management team serves as the Compliance Committee and meets quarterly, Community administrators are local compliance liaisons

Touchstone devotes necessary resources to its compliance and ethics program, including a third party to monitor compliance hotline and a third party claims auditor

Touchstone screens Team Members and contractors monthly against the OIG exclusion list and conducts criminal background checks on all new Team Members upon hire

Team Members receive compliance training upon hire and annually, compliance posters are hung in all communities, Team Members acknowledge the Code of Conduct and Team Member handbook; additional issue-specific training is provided as needed

Violations of Touchstone’s compliance policies are subject to disciplinary actions including termination

Touchstone responds to violations on a case by case basis. Responses may include disciplinary action, training, review of practices at other Communities, reporting and repayment as necessary

Touchstone is reviewing and revising its compliance policies as part of its annual review process

Touchstone has adopted written compliance policies and procedures, a Code of Conduct, and incorporates compliance provisions in its Team Member handbook

Written Standards

Compliance and Ethics Program Overview

We Care.

Element

Touchstone Compliance and Ethics Program

Carl Fellbaum is chief compliance officer, Touchstone’s senior management team serves as the Compliance Committee and meets quarterly, Community administrators are local compliance liaisons

Touchstone devotes necessary resources to its compliance and ethics program, including a third party to monitor compliance hotline and a third party claims auditor

Touchstone screens Team Members and contractors monthly against the OIG exclusion list and conducts criminal background checks on all new Team Members upon hire

Team Members receive compliance training upon hire and annually, compliance posters are hung in all communities, Team Members acknowledge the Code of Conduct and Team Member handbook; additional issue-specific training is provided as needed

Violations of Touchstone’s compliance policies are subject to disciplinary actions including termination

Touchstone responds to violations on a case by case basis. Responses may include disciplinary action, training, review of practices at other Communities, reporting and repayment as necessary

Touchstone is reviewing and revising its compliance policies as part of its annual review process

Response to Violations

Annual Review