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Home | About Us | Good Governance | Compliance | Business Partners

Guidance for Business Partners

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This information is intended to familiarize you with Iowa Health System (IHS) and its policies and practices regarding compliance with laws and regulations governing its operations. We value the vital contribution that our business partners make to the high quality of care we provide to Iowans, and hope that you will take a few minutes to review this pamphlet to better enable your company and our affiliates to conduct business in a mutually satisfactory manner.

Corporate Compliance Program

Iowa Health System (IHS) is committed to the highest ethical and legal business practices and has a policy to consistently and fully comply with all civil, criminal, and health care laws and regulations pertaining to its operations. Pursuant to this commitment, the organization has established a Corporate Compliance Program (Program). The Program includes policies, procedures and guidelines designed to assist IHS and its employees and business partners in achieving compliance. It focuses on the detection and prevention of violations of federal, state and local laws. It fosters an environment in which employees, affiliates and business partners are encouraged to report concerns about business practices.

Iowa Health System (IHS) is committed to the highest ethical and legal business practices and has a policy to consistently and fully comply with all civil, criminal, and health care laws and regulations pertaining to its operations. Pursuant to this commitment, the organization has established a Corporate Compliance Program (Program). The Program includes policies, procedures and guidelines designed to assist IHS and its employees and business partners in achieving compliance. It focuses on the detection and prevention of violations of federal, state and local laws. It fosters an environment in which employees, affiliates and business partners are encouraged to report concerns about business practices. The program is structured to encourage collaborative participation at all levels of IHS and conforms to the standards set forth in the Federal Sentencing Guide-lines for Organizations, effective November 1, 1991.

Business Ethics

Integrity is a key principle for the selection and retention of those who represent Iowa Health System.

We expect our business partners to pursue the best interests of Iowa Health System and its affiliates, as well as the patients and communities we serve.

Business partners are expected to:

• Operate in compliance with all applicable legal requirements.
• Never pursue any business opportunity or relationship which would compromise IHS ethical standards, or violate a law or regulation.
• Respect the rights and dignity of our employees and patients. IHS will not tolerate any form of abuse, harassment or intimidation in the workplace. Harassment or illegal discrimination of any kind is unacceptable.
• Protect the physical and intellectual property of Iowa Health System and any assets entrusted to your care against loss, theft, destruction, misappropriation and misuse.
• Not use for personal gain any information obtained as a business partner of Iowa Health System.
• Comply with all relevant government requirements regarding record, document, and data retention, including the confidentiality of medical records and other proprietary information.
• Report suspected violation of any law, regulation or policy to the compliance officer of the facility with which you have a relationship. Retaliation against anyone who, in good faith, reports such violations will not be permitted.

We recognize the need to provide employees with practical guidelines for the ethical business conduct which is expected of them. IHS has provided each employee with a brochure entitled, "Guide to Employee Conduct." The brochure addresses some of the more common business ethical issues that employees encounter on a day to day basis. There are a couple of guidelines in the IHS code of conduct that vendors must be especially aware of. They are as follows:

Business Courtesies and Gifts

Employees may not solicit or accept any substantial gift from a business partner that might influence their objectivity.

Example: A business partner offers to give an employee four movie tickets each month; no strings attached. The value of four movie tickets is not substantial. May the employee accept? Initially perhaps. But over time (within a 12-month period) the cumulative value of these recurring gifts becomes substantial, and the employee at some point must decline.

Example: A business partner wants to cater a luncheon for the Pharmacy department of an IHS affiliate. Acceptable? Probably. So long as the gift is for the entire department, is insubstantial in value, and is not provided on a frequently recurring basis. But remember, perceptions of partiality, whether justified or not, would render the gift unacceptable.

IHS strictly prohibits an employee's solicitation, receipt, or offers of payment of money or anything of value, either directly or indirectly, in exchange for the referral of any item or service to be provided by IHS or any of its affiliates.

Solicitation

Solicitation, canvass, advertisement, or distribution of literature by persons not employed by IHS will NOT be permitted on IHS Affiliate properties at any time. Employees may not solicit, canvass, advertise or distribute literature in work areas, unless authorized.

In an effort to help our employees abide by these guidelines, we are requesting that vendors refrain from making any offerings to IHS employees which might violate (or be perceived as violating) these guidelines.

Compliance Helpline

IHS has established a Corporate Compliance Helpline. This toll-free Helpline was established as an internal reporting mechanism whereby employees, medical staff, business partners and others associated with IHS can report suspected violations and noncompliance issues without fear of retribution. The Compliance Helpline number is 1-800-548-8778. Callers may remain anonymous, if desired.