Ethical Codes of Conduct
- Circle of Hope PHP is committed to delivering high-quality behavioral health services utilizing the available community and organization resources.
- Circle of Hope PHP does not discriminate against or refuse professional services to anyone based on race, color, creed, age, sex, disability, religion, national affiliation, sexual orientation, or gender expression.
- Circle of Hope PHP personnel shall not engage in, or condone, any form of harassment, bullying, intimidation, or discrimination against fellow employees or the people we serve.
- Circle of Hope PHP respects the rights of people served to receive high-quality healthcare and to private and confidential services. Confidentiality will only be breached when required by law or in potentially life-threatening situations.
- Circle of Hope PHP will not engage in any marketing campaigns or appeals for support that stigmatizes the people we serve.
- Circle of Hope PHP will be alerted to and avoid conflicts of interest that interfere with the exercise of professional discretion and impartial judgment.
- Circle of Hope PHP personnel will avoid dual relationships with people served as they may impair clinical objectivity and professional judgement. All personnel will avoid providing behavioral and/or physical health services directly to friends or family members and will actively disclose any existing or previous business or personal relationship with people served to the Director of Operations.
- Circle of Hope PHP personnel will not engage in business ventures with people served. Circle of Hope PHP personnel will not accept outside employment from or personally employ people served while at the same time providing services to the person served.
- Circle of Hope PHP personnel will not engage in personal relationships with people currently or formerly served by Circle of Hope PHP, including financial, sexual or emotional relationships. Further, personnel will not take unfair advantage of any professional relationship or exploit people served in any way.
- Circle of Hope PHP personnel shall not engage in romantic relationships with supervisors or supervisees and/or where a power differential exists (e.g., evaluative capacity or supervision).
- Circle of Hope PHP personnel will not solicit or accept personal gifts or gratuities from the people we serve or vendors except that nominal gifts from people served may be accepted on behalf of Circle of Hope PHP as a whole and shared with all Circle of Hope PHP personnel. Circle of Hope PHP personnel will not give personal money or gifts to those we serve.
- Circle of Hope PHP personnel shall respect and reasonably safeguard the personal property of the people we serve, visitors, fellow employees, and all Circle of Hope PHP property.
- Circle of Hope PHP personnel will not use Circle of Hope PHP property or services to advance their personal business or financial interests.
- Circle of Hope PHP personnel may be asked to witness documents such as authorizations for Release(s) of Information, other organizational documents, and legal documents. Neither Circle of Hope PHP, nor Circle of Hope PHP personnel, in their role as an employee will assume the legal role of guardian, conservator, personal payee, power of attorney, or legal representative for the people we serve.
- Circle of Hope PHP personnel are prohibited from going door-to-door (office) to solicit for personal fundraising efforts. Personnel are allowed to place a sign-up sheet in the break room accompanied by an email announcing to staff that sign-up is available.
- Circle of Hope PHP personnel will exercise extraordinary care when making spoken, electronic, or written professional recommendations or opinions to the public. Personnel will not engage in interviews with the media (e.g., TV, radio, or newspaper) without consent from the Director of Operations or an owner.
- Circle of Hope PHP personnel will appropriately represent their credentials and not claim licenses, certifications, or academic degrees which have not been legitimately conferred by an accredited institution, or which are unrelated to their practice of work at Circle of Hope PHP. Personnel will work within the scope of their education and credentials.
- Circle of Hope PHP personnel will abide by the ethical guidelines of their affiliated professional associations. Should the ethical guidelines of either Circle of Hope PHP or the professional organization conflict, the more stringent of the two should prevail.
- Circle of Hope PHP personnel are committed to the assessment of personal strengths, needs, abilities and preferences, and to the maintenance of proficiency and competency in delivery of services to the people we serve. Personnel will recognize the boundaries of their competencies. Personnel shall maintain licensure and certifications as required by Circle of Hope PHP and its external regulatory organizations.
- Circle of Hope PHP will ensure that all employed or contracted personnel, volunteers, and students comply with all local, state, and federal regulations and Circle of Hope PHP policies and procedures, and conform to CARF standards.
- Circle of Hope PHP personnel will dutifully report situations which may cause potential harm or psychological damage to the people we serve. This includes the reporting of Circle of Hope PHP employees engaging in behavior harmful to people served, or employees impaired to the extent that their professional judgment and/or performance may be compromised. Circle of Hope PHP personnel will make reports to the Director of Operations. Circle of Hope PHP follows the rights of a whistleblower for protection against retaliation within the Michigans’ Whistleblowers Protection Act (469 P.A. 1980).
- Circle of Hope PHP personnel are mandated to report any known or suspected abuse, neglect, or exploitation of children to the Michigan Department of Health and Human Services (MDHHS); Children’s Protective Services (CPS). In addition, Circle of Hope PHP personnel are also mandated to report any known or suspected immediate danger of a child to law enforcement. Circle of Hope PHP personnel are mandated to report any known or suspected abuse, neglect, or exploitation of vulnerable adults to the Michigan Department of Health and Human Services (MDHHS); Adult Protective Services (APS). In addition, Circle of Hope PHP personnel are also mandated to report any known or suspected immediate danger of a vulnerable adult to law enforcement.
- Circle of Hope PHP personnel are mandated to protect identifiable third parties when a person served makes a serious threat of violence toward an identified victim(s). Per the 1976 California Supreme Court case, Tarasoff v. Regents of the University of California, when a person served expresses a serious threat to an identifiable victim(s), the mental health professional must take reasonable steps to protect the person(s), which can include notifying the potential victim and/or law enforcement.
- Circle of Hope PHP personnel shall accept the responsibility to advocate for the people we serve and protect the community in which we live against unethical and damaging practices by individuals or organizations.
- Circle of Hope PHP personnel will remain sensitive to the religious convictions and spiritual needs of people served. When indicated, personnel will refer people served to a spiritual advisor.
- Circle of Hope PHP personnel will adhere to honest business practices and not engage in deceptive billing to enhance Circle of Hope PHP’s reimbursement:
- Circle of Hope PHP personnel will bill only for those items and services which are actually rendered.
- Circle of Hope PHP personnel will not overstate the time required that has been approved to perform the services in order to obtain greater reimbursement.
- Circle of Hope PHP personnel will bill only for items and services that are medically necessary and reasonable as warranted by the severity of the symptoms.
- Circle of Hope PHP personnel will not use a billing code that provides a higher payment than the billing code that actually reflects the services rendered to the person served.
- When diagnosing, Circle of Hope PHP personnel shall render diagnoses consistent with the person’s symptoms and clinical conditions.
- Circle of Hope PHP personnel shall not submit more than one bill for the same service or bill for a portion of another service (double billing or overlapping billing).
- Circle of Hope PHP personnel will understand the service requirements and billing codes within the service area so that fraudulent and abusive billing practices do not occur.
- Circle of Hope PHP personnel will make every effort to stay current on Medicaid regulations.
- Circle of Hope PHP personnel will submit documentation of services rendered in a timely manner.
- Circle of Hope PHP personnel will not knowingly violate federal, state and other regulatory requirements and standards.
- Circle of Hope PHP forbids discharging individuals from treatment based solely on their inability to pay or the fact that their continued stay is not subject to third party reimbursement.
- In accordance with Human Resources (HR), Circle of Hope PHP personnel shall adhere to the highest standards of ethical and professional behavior as it is the foundation of fair, respectful, and effective workplace practices. This includes, but not limited to:
- Pursuing Circle of Hope PHP objectives in a manner consistent with community interest.
- Upholding all laws and regulations relating to Circle of Hope PHP activities.
- Promoting fair and equitable treatment of all personnel and candidates for employment.
- Treating people with dignity, respect and compassion.
- Fostering a work environment that is free of harassment, intimidation and unlawful discrimination.
- Assuring an environment of inclusiveness and a commitment to diversity within the organization.
- Ensuring that only appropriate and accurate information is used in decisions affecting employment relationships.
- Safeguarding restricted and/or confidential information.
- Upon termination or resignation, Circle of Hope PHP personnel shall maintain the confidentiality of people served and co-workers, as well as shall hold confidential any sensitive situations arising with the practice.
- Circle of Hope PHP personnel will report suspected violations of this ethical code and any concerns about potential or actual waste, fraud, abuse, or other wrongdoings to the Director of Operations. Circle of Hope PHP appreciates and respects the reporters and has a no-reprisal approach for personnel reporting suspected ethical violations and incidents of waste, fraud, abuse or other questionable activities and practices:
- The Director of Operations is responsible for investigations of reports. The investigation will be initiated within 3 business days and be completed within 30 days of receipt.
- Names of personnel or other reporting activities will not be made public unless it is necessary to substantiate the report.
- If there are questions/concerns about legality, the Director of Operations will refer issues to the owners who can contact legal counsel.
- If appropriate, findings will be shared with the quality improvement team for analysis and planning system improvement.
- Circle of Hope PHP personnel and other stakeholders (if applicable), will be educated on the Ethical Codes of Conduct during employee orientation. Personnel and other stakeholders (if applicable), will receive re-education on the Ethical Codes of Conduct one time per calendar year.
