Approved: December 20, 2008

Gainesville, Florida

The Council on the Global Integration of Healthcare is committed to providing insight and discussion into the global integration of healthcare delivery and medical tourism every day. The Advisory Board and Members represent a cross-section of industry, private business, labor, government and academia.

Our purpose is to create a sustainable organization made up of diverse individuals empowered to make decisions that will continuously build the medical travel and globally integrated health care industry.

We will build the organization as a collaborative project dedicated to providing and building the largest and most comprehensive knowledge base for medical tourism and globally integrated healthcare. The leadership role that The Council on the Global Integration of Healthcare enjoys is the direct result of the talented, dedicated, innovative, and resourceful Directors, Advisors, Staff, Associates, and Volunteers that make up the Council on the Global Integration of Healthcare.

Health care is a complex, highly regulated, interdisciplinary, service-oriented industry, which continually faces changes in technology, delivery systems, standards of care and treatment protocols, rules and regulations, funding and reimbursement, and finally and most importantly the service needs of our patients and their families.

With that complexity in mind and at the direction of our Board, The Council on the Global Integration of Healthcare has established the Code of Conduct. The development and implementation of this guide and related compliance activities is fundamental to establishing a culture, within our system, that promotes prevention, detection, and resolution of instances of conduct that do not conform to The Council on the Global Integration of Healthcare policies and procedures, federal and state laws, as well as ethical business practices.

The design and operation of this compliance plan represents a significant commitment and allocation of time, resources, and energy by the Board, Members, Advisors and the Executive leaders of this organization. We request that each person associated with The Council on the Global Integration of Healthcare make the same commitment to compliance in the performance of their duties. The information provided in this guide and your understanding and adherence to this guidance is essential.

Our shared responsibility and commitment in this effort will ensure that the mission “To provide insight and discussion into the global integration of healthcare delivery and medical tourism every day. The Advisory Board and Members represent a cross-section of industry, private business, labor, government and academia.

Our Purpose is to create a sustainable organization made up of diverse individuals empowered to make decisions that will continuously build the medical travel and globally integrated health care industry.
 
/s/  Maria K Todd
President and Chief Executive Officer
The Council on the Global Integration of Healthcare

 
Code of Conduct

I. Introduction

The Council on the Global Integration of Healthcare is made up of a Board, Advisors and members and other entities that provide insight and discussion into the global integration of healthcare delivery and medical tourism every day. The Advisory Board and Members represent a cross-section of industry, private business, labor, government and academia.  Our Purpose is to create a sustainable organization made up of diverse individuals empowered to make decisions that will continuously build the medical travel and globally integrated health care industry.

 This guide represents the formalization of a compliance program for The Council on the Global Integration of Healthcare  Each section of the Code of Conduct will identify the responsibilities that we have to The Council on the Global Integration of Healthcare as Directors, Board Members, Advisory Board and Members, Associates or Volunteers:

Personal Conduct - Conducting the Business Affairs of The Council on the Global Integration of Healthcare

Compliance Standards -  The guidance found in Code of Conduct and is just that, “a guide” and should not be considered the final word in all circumstances. If you have questions or need assistance in applying these guidelines, it is your responsibility to contact a member of the Executive Staff, a Board Member or Advisory Board The intent of the Code of Conduct is to bring together those Directors, Board Members, Advisory Board and members, Staff, and Volunteer policies that identify the personal Code of Conduct required of us as we work together to meet the business needs of The Council on the Global Integration of Healthcare.

Code of Conduct

A. Personal Conduct

1. Honesty/Fairness
Our actions are a reflection upon The Council on the Global Integration of Healthcare as an organization. Honesty and fairness in dealing with other Board members, Advisory Board Members, Directors, Members staff, Management Leaders, Volunteers, Vendors and Suppliers, Consultants, and Governmental Representatives are essential and expected of all individuals associated with The Council on the Global Integration of Healthcare.  Everyone with whom you come in contact is entitled to fair and evenhanded treatment regardless of his or her relationship to The Council on the Global Integration of Healthcare.  No one associated with The Council on the Global Integration of Healthcare shall knowingly make false or misleading statements during the performance of his or her job.


2. Confidentiality
All information and records pertaining to patients, as well as proprietary information, of the Council are private and confidential and only authorized persons who must refer to them as a business necessity shall have access to them. Proprietary information is the property of The Council on the Global Integration of Healthcare and includes, but is not limited to, patient information, business strategies, pricing of services, contracts, competitive bids, products, ideas, designs, plans, pending projects and proposals, financial information, and information concerning individuals associated with The Council on the Global Integration of Healthcare. Confidentiality of proprietary information is an essential element in complying with antitrust, trade, and other similar laws that regulate competition. This information must be kept in strict confidence. You must never discuss The Council on the Global Integration of Healthcare’s business either inside or outside The Council on the Global Integration of Healthcare where unauthorized persons could hear it. Confidentiality is a serious concern.

3. Communication
Open communication among Associates, Directors, Trustees, Allied Personnel, Medical Staff, Management Leaders, Volunteers, Patients and their Families, Payers, Vendors and Suppliers, Consultants, and Governmental Representatives is essential. Recognizing that fact, The Council on the Global Integration of Healthcare is dedicated to communicating its activities and encourages you to make suggestions and to voice your opinions and concerns. Meetings, bulletin boards, memos, etc. are used to inform you of items of general interest as well as specific items pertaining to your work area. In turn, everyone is encouraged to participate actively in meetings in order to promote mutual understanding in the work environment.

4. Work Environment
Physical conditions are only one component of work environment. The Council on the Global Integration of Healthcare must also be free of discrimination and harassment. Actions, words, jokes, or comments based on an individual’s gender, race, ethnicity, national origin, age, religion, disability, veteran status, or any other legally-protected characteristic will not be tolerated. A prompt investigation will be conducted, and The Council on the Global Integration of Healthcare will take appropriate corrective action where it is warranted.

Sexual harassment is a form of misconduct that undermines the integrity of the employment relationship. No male or female should be subject to unsolicited and unwelcome sexual overture or conduct, either verbal or physical. Sexual harassment does not refer to occasional compliments of a socially acceptable nature. It refers to behavior that is not welcome, that is personally offensive, which undermines morale, and therefore interferes with work effectiveness. Sexual harassment, whether committed by Associates, Directors, Trustees, Allied Personnel, Medical Staff, Management Leaders Volunteers, Patients and their Families, Payers, Vendors and Suppliers, Consultants, and Governmental Representatives is specifically prohibited as unlawful and against The Council on the Global Integration of Healthcare’s policy. Any individual who has reason to believe that he or she is the victim of harassment or discrimination should promptly report the facts of the incident to one or more Officers or Directors of the Council.

An outline of the compliance reporting system can be found in the Appendix of this guide to assist you in reporting suspected violations.

5. Gifts and Entertainment

Your conduct should be in a manner that is free from unlawful or otherwise inappropriate offers or solicitations of gifts and favors or other improper inducements in exchange for influence or assistance.

The following will provide guidance in this area:

6. Expense Reports

Business expenses properly incurred in performing The Council on the Global Integration of Healthcare business must be documented promptly with accuracy and completeness on an expense report. When traveling on The Council on the Global Integration of Healthcare business, all expenses will be paid by The Council on the Global Integration of Healthcare except those of a personal nature-- for example, non-business-related long-distance calls, entertainment, etc. The cost of travel related expenditures should be reasonable and cost effective. The reporting of other routine expenses incurred in the course of your duties should be recorded on the appropriate form for reimbursement.

C. When Conducting Business on Behalf of The Council on the Global Integration of Healthcare

1. Vendors, Consultants, Contract Individuals or Services and Other Third Parties

It is your responsibility to inform all vendors, consultants, contract individuals or services and other third parties that compliance with the “The Council on the Global Integration of Healthcare Standards of Conduct and Compliance,” and all local, state, and federal laws, statutes, rules, and regulations, is a required condition of doing business with The Council on the Global Integration of Healthcare. In choosing vendors, consultants, contract individuals or services and other third parties, everyone should be treated fairly, and any inducements, kickbacks, and/or special treatment in the selection process is strictly prohibited. Whenever possible, materials, supplies, equipment, consulting, and other services should be procured from qualified suppliers at the lowest cost, keeping in mind the requirements for quality, performance, and the vendor’s ability to meet delivery schedules. As a representative of The Council on the Global Integration of Healthcare, you are expected always to employ the highest ethical business practices in source selection, negotiation, determination of awards, and the administration of all purchasing activities. Any rebates, discounts and allowances that are customary business practices are acceptable so long as they do not constitute unlawful or unethical payments and are given to The Council on the Global Integration of Healthcare. Such payments should be properly documented, of reasonable value, competitively justified, and properly invoiced/credited to the entity originating the agreement. Any such payments to individual Associates of The Council on the Global Integration of Healthcare are strictly prohibited. Payments made to vendors will be made only for goods and services acquired in accordance with established Materials Management policies and procedures.

2. Relationships with and Guidance Received from Outside Officials
What is acceptable practice in a business environment, such as providing education, transportation, entertainment, or other things of value, may be entirely unacceptable and may even violate certain federal, state, or local laws and regulations in dealings with government employees or those who act on the government’s behalf. Therefore, you must be aware of and adhere to the relevant laws and regulations governing relations between government customers and suppliers.

The administration and governance of local, state, and federal health care programs is very complex. Therefore, when obtaining an interpretation of the many rules and regulations, you should work with your supervisor and require that all such communication be in writing no matter the source of the information (i.e., consultants, vendors, government agencies). When written documentation cannot be obtained, the information received cannot be used or relied upon in the conduct of The Council on the Global Integration of Healthcare’s affairs.

3. Conflict of Interest
The purpose of our conflict of interest policy is to assure that persons make decisions in an objective manner without undue influence from persons with a private interest.

4. Information Provided to Outsiders
Distribution of false, dishonest, incomplete, inaccurate, and/or misleading information to organizations, media, or other sources of public information, government agencies or their agents, accrediting organizations and/or any other authorized users of The Council on the Global Integration of Healthcare’s information, is prohibited. If someone outside The Council on the Global Integration of Healthcare asks you questions directly or through another person, do not attempt to answer them unless you are certain you are authorized to do so. If you are not authorized to release the information, refer them to the appropriate source within The Council on the Global Integration of Healthcare, or Human Resources and the administrative person on call.

5. Excluded Business Relationships
Any individual, including Director, Trustees, Associates, Physicians, Vendors, Consultants, Contract Individuals or services and other third parties that have been sanctioned by the Medicare, Medicaid, and/or other federal health care programs, are excluded from any business or other relationship with any entity of the The Council on the Global Integration of Healthcare. Only upon reinstatement by the governing agency can a business relationship be considered. Sanctions represent a full range of administrative remedies and actions available to the government to deal with questionable, improper, or abusive practices under the Medicare and Medicaid programs. Sanction results when a health care provider violates obligations and requirements governing items and services he/she renders bills for and gets paid for on behalf of Medicare or Medicaid beneficiaries. 6. Not-For-Profit Tax-Exempt Status
The Council on the Global Integration of Healthcare is exempt from federal income tax, state sales tax and certain other taxes as prescribed by law.  Maintenance of tax-exempt status requires that these entities engage in activities in furtherance of their educational purposes, ensuring that their resources are used in a manner that furthers the public good rather than private or personal interest of any individual(s). All transactions must be in the best interest of the entity and negotiated at fair market value. Your adherence to The Council on the Global Integration of Healthcare Conflict of Interest Policy is essential to the maintenance of this tax-exempt status. The Council on the Global Integration of Healthcare will make available, as required, all necessary information in support of an entity’s exemption to include, but not limited to, state sales tax exemption forms duly signed and authorized, evidence of exempt status granted by the Internal Revenue Service (IRS), etc.

III. Compliance Standards
A. The Council on the Global Integration of Healthcare has high ethical standards in the conduct of its business. These ethical standards are supported by The Council on the Global Integration of Healthcare’s mission statement.  It remains the policy of The Council on the Global Integration of Healthcare to comply with all federal, state and local laws, regulations and statutes applicable to its operations and business dealings with the public and at all governmental levels. This policy applies to all Associates of  The Council on the Global Integration of Healthcare and must be strictly observed.

The Board will establish a mechanism for monitoring:

A.  Management’s development and maintenance of a code of conduct and a compliance program relating to the conduct of business to assure that high standards of compliance are met.

B. Reviewing the activities of the compliance program to ensure that high standards of business, legal, and personal compliance are being met.

C. Professional Organizations: Laws, Standards, Oaths, Licensing, Registrations or Other Such Requirements
Many, if not all, health care and business professional organizations have established standards of conduct for its members. The “State Nurse Practice Act” governs, for example, nurses in each State. The Council on the Global Integration of Healthcare requires you to conform to any laws, standards, oaths, licensing, registrations, or other such requirements of established professional organizations during your employment to the extent that they do not conflict with The Council on the Global Integration of Healthcare. If you have questions or concerns about potential conflicts with The Council on the Global Integration of Healthcare policy contact your supervisor. It is your responsibility to ensure that any required licensure, registration, certification, permit, etc. is maintained in a current status during your association with The Council on the Global Integration of Healthcare.

F. Submission of Reports
The Council on the Global Integration of Healthcare may be required, either by law, statute, regulation or contract, to report information for a prescribed time period. All reporting done by The Council on the Global Integration of Healthcare will be done utilizing the following guidance:

Only authorized individuals may submit, report, file, or communicate information on behalf of The Council on the Global Integration of Healthcare.

Reports will be submitted within the prescribed time allowed for their submission.

Reports will be prepared in a professional manner and include any supporting documentation that may be required.

Prior to the submission of any report, it must be reviewed and approved by all appropriate individuals.

This guidance is offered in support of The Council on the Global Integration of Healthcare’s intent to submit and report only accurate, timely, consistent, and clear information in accordance with defined rules, regulations, and directions and/or instructions.

IV. Reporting Suspected Violations of the Code of Conduct

A.     Reporting System

The Council on the Global Integration of Healthcare requests, wants, expects, encourages, and requires that you report any suspected violations of the Code of Conduct, laws, statutes, rules, and/or regulations. No concern you may have regarding conduct or compliance policies is too small or unimportant. Reports can be made to the Executive Board of The Council on the Global Integration of Healthcare.

B. Non-retaliation/Non-retribution Related to Reports
Reprisals of any nature against individuals reporting suspected violations will not be tolerated. Retaliation or retribution for reporting suspected violations by any individual is prohibited.

V. Investigations
A. Internal
Internal investigations will be authorized and directed by Board.  All internal investigations will be conducted in a prompt and professional manner. Most internal investigations will require audit/review of The Council on the Global Integration of Healthcare’s records, policies, and other relevant documents, and interviews with those individuals directly involved in the focus of the investigation. All investigations will be guided by a work plan, approved by THE COUNCIL OF THE GLOBAL INTEGRATION OF HEALTHCARE , which identifies the scope and authority of those individuals conducting the investigation. Your assistance in the conduct of an investigation is essential; failure to do so could result in disciplinary action and in some instances may be a violation of the law. THE COUNCIL OF THE GLOBAL INTEGRATION OF HEALTHCARE, based on the facts and on the advice of legal counsel, will comply with all self-reporting requirements for non-compliance as may be necessary upon completion of all internal investigations.

B. External
There are basically two types of externally conducted investigation: first, an investigation conducted by an outside third party at the request of and on behalf of The Council on the Global Integration of Healthcare; second, an investigation conducted by an outside third party at the direction of a regulatory agency or other government entity to determine compliance with state and federal laws, statutes, rules, and regulations as they relate to The Council on the Global Integration of Healthcare’s activities. The Council on the Global Integration of Healthcare’s policy requires that you provide full cooperation with those individuals conducting a third party investigation. In most instances, The Council on the Global Integration of Healthcare has agreed to provide regulatory and government agencies access to relevant data and records as a “condition of participation” in a given program. The Council on the Global Integration of Healthcare has certain legal rights that must be protected in any investigative process, and you must follow all related policies and procedures in your response to subpoenas, search warrants, unannounced site visits, requests for interviews, and any other requests to access The Council on the Global Integration of Healthcare property and information. Prescribed policies and procedures in this area not only protect the rights of The Council on the Global Integration of Healthcare as an organization but also assure that investigators receive the full cooperation necessary to complete their work. The Council on the Global Integration of Healthcare has a responsibility to protect the integrity and confidentiality, as appropriate, of any and all records under its control.