December 12, 2017

The holidays are approaching, and with that comes the gift-giving season! In your role at Texas Children’s, you might have encountered situations where patients, Health Plan members, or vendors want to give you gifts to express their gratitude. And you’ve probably thought to yourself, can I accept the gift? Depending on your job, accepting a gift may interfere with your professional responsibilities, and could trigger violations of certain laws or ethical rules. So what is appropriate? Below are some FAQs to ensure you and your staff are appropriately handling gifts among Texas Children’s workforce members, patients, Health Plan members, and vendors.

Patients and Health Plan members

Can I accept cash or cash equivalents from a patient, Health Plan member, or their family?

No. Never accept cash or cash equivalents (including gift cards) from patients or Health Plan Members. Even a $5 gift card to Starbucks is not appropriate.

What other gifts can I not accept from a patient, Health Plan member, or their family?

It is not appropriate to accept high dollar value gifts such as expensive pens, jewelry, electronics, tickets to sporting events or concerts, or other extravagant items.

What can I accept from a patient, Health Plan member, or their family?

Gifts with nominal value are acceptable if they are infrequent and do not create an obligation on your part. Examples include food, flowers, and balloons. These types of gifts should be shared with your co-workers.

Can I give a gift to a patient, Health Plan Member, or their family?

Yes, you can give nominal gifts, valued under $15 per item, or $75 annually per patient or Health Plan member.

Never give cash, cash equivalents (including gift cards), or high dollar value gifts.

How can I politely decline a gift without offending a patient, Health Plan member, or their family?

  • Always express gratitude, even when you cannot accept the gift.
  • Clarify that Texas Children’s does not generally allow you to accept gifts.
  • Stress that you do not want other patients or Health Plan members to feel like they have to give gifts.
  • In the rare circumstances where return of a gift is not possible, the gift must be delivered to the Office of Philanthropy, who will use it for the benefit of patients and families.
Vendors

Can I accept cash or cash equivalents from a vendor?

No. Never accept cash or cash equivalents (including gift cards) from vendors.

What other gifts can I not accept from a vendors?

It is not appropriate to accept gifts from vendors that may influence or appear to influence their decision-making on behalf of Texas Children’s.

What can I accept from a vendor?

Gifts with nominal value are acceptable if they are infrequent, of nominal value and do not create an obligation on your part. Examples include food, flowers, and balloons. These types of gifts should be shared with your co-workers.

Unsolicited offers of entertainment or social events (e.g. attendance at a sporting or cultural event, participating in a sporting activity) as long as long as they are infrequent, do not improperly influence behavior, and will not influence any part of a decision making process.

Can I accept gifts from vendors that are involved in a bid/award process?

No. If a vendor is involved in a Request for Proposal, Request for Information, or Request for Quote, you may not accept any gift or meal, regardless of its value.

Colleagues

Can I give or accept a gift from a co-worker?

Yes, you can exchange gifts with your colleagues, as long as you paid for the gift yourself. You may not use Texas Children’s funds (e.g. eReimbursement, ProCard) for gifts for colleagues.

If you have a question about giving or receiving gifts, please contact Compliance and Privacy (ext. 4-2085 or compliance@texaschildrens.org).

October 31, 2017

At Texas Children’s, we are committed to leading tirelessly in maintaining an ethical workplace. Every day, we hold each other accountable to the highest standards of integrity and ethical behavior.

To recognize and promote the importance of integrity and ethics at Texas Children’s, we will be celebrating National Corporate Compliance and Ethics Week during the week of November 6 – 10.

During the week, the Compliance and Privacy Office will be hosting a series of awareness events throughout the organization. This is a wonderful opportunity to meet members of the Compliance and Privacy Office, learn more about what we do, play games and win prizes. For a complete schedule of events, click here.

Thank you for your continued support of our Compliance and Privacy programs. If you have any questions, please contact the Compliance and Privacy Office at ext. 4-2085 or compliance@texaschildrens.org.

November 8, 2016

11916compliancelancelightfoot175At Texas Children’s, doing what’s right is of the utmost importance to maintaining the quality of care we provide our patients, their families, and our Health Plan members. That’s why the role of the Compliance and Privacy Office is integral to our organization’s health and success.

The office’s team is committed to maintaining the highest ethical, legal and professional standards by providing leadership and oversight of all Texas Children’s business practices. Areas of prominent interest to the office include:

  • Safeguarding protected health information
  • Adhering to private payer billing standards
  • Complying with all state and federal laws and regulations as well as Texas Children’s policies and procedures

“At Texas Children’s, we are committed to leading tirelessly in maintaining an ethical workplace,” said Texas Children’s Vice President and Compliance and Privacy Officer Lance Lightfoot. “By upholding the highest standards of integrity and ethical behavior, we enable Texas Children’s to better fulfill its important mission of creating a healthier future for children and women.”

To recognize and promote the importance of integrity and ethics at Texas Children’s, the Compliance and Privacy Office will be celebrating National Corporate Compliance and Ethics Week (Monday, November 7 – Friday, November 11) by hosting a series of awareness events throughout the organization. These events are wonderful opportunities to meet members of the Compliance and Privacy Office team, learn more about what they do, play games and win prizes.

The events also offer a chance to keep your personal information secure as well as our patients’ and our Health Plan members’. Twice during National Corporate Compliance and Ethics Week, the office is providing employees a free, safe and secure opportunity to destroy any confidential personal documents that are ready for disposal. The Shred Days will be held Tuesday, November 8 at West Campus, and Friday, November 11 at Main Campus. For a complete schedule of this week’s events, click here.

For more information about the Compliance and Privacy Office click here and if you have any questions, please call the office at Ext. 4-2085 or send an email to compliance@texaschildrens.org.

How can you help?
Unethical, illegal or questionable activity should be reported to one of the following sources:

  • Your immediate supervisor
  • The Compliance and Privacy Office at Ext. 4-2085
  • The Texas Children’s Confidential Hotline at 1-866-478-9070 (available 24 hours a day, 7 days a week)

Retaliation for voicing concerns made in good faith is a violation of Texas Children’s policy.

March 30, 2016

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The Texas Children’s Code of Ethical Behavior sets forth the guidelines that govern our interactions among workforce members, patients, and vendors, and sets expectations for our behavior, in order to ensure we achieve our purpose in full compliance with our values and the law.

 

Frequently Asked Questions

1. Why does Texas Children’s have a Code of Ethical Behavior?

  • Ethics are an essential and integral part of any successful company, especially in health care. Since we work in a complex and highly regulated industry, it is essential that we have a uniform code that guides workforce members on carrying out the Texas Children’s mission ethically and with integrity, and protects Texas Children’s, its employees, and its patients.

2. What is the Texas Children’s Code of Ethical Behavior?

The general principles that guide our behavior at work. These include:

  • Following the law: Not sure about whether something is legal? Contact the Compliance and Privacy Office at 832-824-2085 or at compliance@texaschildrens.org and ask!
  • Ethical business practices: Texas Children’s values openness, honesty, and expects its workforce to adhere to the highest standards of ethical business practices.
  • Avoiding conflicts of interest: Taking part in an activity that may influence or appear to influence your decision making.
  • Following Texas Children’s policies and procedures: All Texas Children’s policies and procedures are available on PolicyTech, accessible here: https://texaschildrens.policytech.com/
  • Reporting inappropriate or unethical conduct or activity: Texas Children’s provides a confidential and anonymous way to report compliance or ethical concerns, for which regular channels may be uncomfortable or otherwise inappropriate. To make an anonymous report, workforce members can either: 1) call the Texas Children’s Confidential Hotline (1-866-478-9070) to report their concerns, or 2) make a report online at http://mycompliancereport.com (enter password TEX).
  • Maintaining confidentiality: Every Texas Children’s workforce member has a duty to safeguard the health information of our patients and members, and shall not access/use/disclose any patient/member protected health information except for the purposes of payment, treatment, or operations. No one may access a patient’s or member’s protected health information unless it relates to their work-duties at Texas Children’s.
  • Keeping accurate and complete records: It is essential that all documentation and records are accurate. When a mistake is made, Texas Children’s expects that error to be reported so it can be corrected.
  • Doing what is right, not what it easy: Sometimes doing nothing, or taking the wrong action, is easier than doing the right thing. All Texas Children’s workforce members are expected to take action and report unethical behavior, even if it is difficult.

3. To whom does the Code of Ethical Behavior apply?

  • The Code of Ethical Behavior applies to all Texas Children’s entities, and all Texas Children’s workforce members individually, including employees, medical staff, volunteers, contractors, consultants, temporary employees, trainees, or other persons whose performance of work is under the direction or supervision or on behalf of Texas Children’s, whether or not they are paid by Texas Children’s.

Remember, if you see something that you believe to be unethical or illegal, you should raise your concerns or ask questions. Thank you for your commitment to ensuring Texas Children’s continues its high standard of ethical practices in order to best serve our patients.

May 6, 2014

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The level of integrity of corporations has gained worldwide attention – often for the wrong reasons. But increasingly, organizations are recognizing that a strong compliance and ethics program is not just a smart idea, it’s good for business. To acknowledge the positive impact of corporate compliance and ethics on organizations, the Health Care Compliance Association and the Society of Corporate Compliance and Ethics have designated May 4-10 Corporate Compliance and Ethics Week. This week reminds us the importance that integrity, privacy and compliance have to our mission.

“In today’s environment, where our patients, health plan members and the government all expect us to do the right thing and protect them from harm, Compliance Week offers Texas Children’s an opportunity to focus on all of our practices to make sure we are meeting those expectations,” said Lance Lightfoot, General Counsel, Compliance Officer and Privacy Officer.

Employees work diligently to keep patients’ information secure, and it’s just as important to keep personal information secure as well. As a part of Corporate Compliance and Ethics Week, the Compliance Services Office and Records Management Department are providing employees a free, safe and secure opportunity to destroy their personal documents. Come to the Meyer Building visitor’s lot from 8 a.m. to 10 a.m. Wednesday, May 7, or from 2 p.m. to 4 p.m. Friday, May 9.

What should be shredded? Anything with confidential or identifying information – including old paycheck stubs, bank statements and items that list social security numbers.

Take advantage of this great opportunity as part of Corporate Compliance and Ethics Week!