CODE OF ETHICS                                          

POLICY:

HOH / SS requires that all employees, officers and directors comply with all laws, rules, regulations and contractual agreements and that they conduct themselves in accord with the highest ethical standards. This Code will help our employees understand some specific laws they are bound to obey as well as contractual obligations that require State and Federal monitoring.  Employees are expected to use good judgment and common sense in seeking to comply with all applicable laws, rules, contractual agreements and regulations and to ask for advice when they are uncertain about them.

This Code is intended to serve as a guide for employee’s ethical conduct and as a basis for the resolution of issues when the conduct of an employee is alleged to deviate from the standard expressed in this Code.

The Code represents standards of ethical behavior in professional relationships with those we serve, with all personnel, with individuals in the community, vendors, and other professionals. It also embodies specific standards of ethical behavior governing conduct by counselors.

Employees are expected to view ethical responsibility in an inclusive context.  As each situation unfolds and ethical judgment is required, the employee is expected to take into consideration the principles in this Code where ethical judgment is being exercised and professional intervention is planned. The course of action that the employee chooses is expected to be consistent with the spirit of as well as the Code.

CONFIDENTIAL AND PROPRIETARY INFORMATION

The use of PROPRIETARY INFORMATION obtained as a consequence of employment may only be used in the proper conduct of HOH / SS business.  Neither HOH / SS, a member of the Board of Trustee, nor any employee may use, or permit others to use, proprietary information for the purpose of furthering a private interest or as a means of making a profit.

All information about our persons served is CONFIDENTIAL INFORMATION and must never be disclosed to outsiders without a written authorization. Persons served information is protected by federal and state statutes and regulations. Records of the counseling relationship, including interview notes, test data, correspondence, computer-stored information, progress notes, and other documents, are to be considered part of the records of HOH / SS.  Disclosure of persons served protected health information may occur only with the expressed, written consent of the person served and only after appropriate authorization forms have been fully completed and signed.   All requests for person served records are subject to review by the Records Custodian.

Staff members should respect the privacy of persons served and hold in confidence all information obtained in the course of their professional service to persons served.

HONEST AND ETHICAL CONDUCT AND FAIR DEALING

Employees, officers and trustees should endeavor to deal honestly, ethically and fairly with the organization’s vendors, persons served, competitors and employees. Statements regarding the organization’s services must be true, honest and not misleading. Employees, officers and trustees must not take unfair advantage of anyone through manipulation, concealment, or abuse of privileged information.

PROTECTION AND PROPER USE OF CORPORATE ASSETS

Employees, officers and directors should seek to protect the Company’s assets. Theft, carelessness and waste have a direct impact on the financial performance of HOH / SS. Employees, officers and directors must use the assets and services of HOH / SS solely for legitimate business purposes.

ACCURACY OF BOOKS AND RECORDS AND PUBLIC REPORTS

Employees, officers and directors must honestly and accurately report all business transactions. Each individual is responsible for the accuracy of his/her records and reports. Accurate information is essential to the organization’s ability to meet legal and regulatory obligations.

All HOH / SS books, records and accounts shall be maintained in accordance with all applicable regulations and standards and accurately reflect the true nature of the transactions they record. The financial statements of HOH / SS shall conform to generally accepted accounting principles and rules and HOH / SS accounting policies and procedures. No false or misleading entries shall be made in HOH / SS books, records or clinical documentation for any reason and no disbursement of corporate funds or other corporate property shall be made without adequate supporting documentation.

It is the policy HOH / SS to provide full, fair, accurate, timely and understandable disclosure in reports.

DISCRIMINATION

It is against the law to discriminate against an employee, intern, or persons served on the basis of race, color, sexual orientation or gender, age, national origin, disability, or other protected status. Every employee has a responsibility to prevent and eliminate discrimination.  HOH / SS understands and appreciates the value that diversity contributes to our organization. Mutual respect is a core value of our organization.

CONFLICT OF INTEREST 

Employees, officers, directors and trustees must act in the best interests of the organization and must refrain from engaging in any activity or personal interest that presents a “conflict of interest.” A conflict of interest occurs when personal interest interferes, or appears to interfere, with the welfare of the organization. A conflict of interest can arise whenever you, as an officer, director, trustee or employee, take action or have an interest that prevents you from performing your duties and responsibilities honestly, objectively and effectively.

Officers, directors, trustees or employees should not have independent relationships with those who do business with HOH / SS and should not use our property for their personal benefit. 

 RELATED PARTIES

Avoid conducting the organization’s business with related parties, that is, with a relative or significant other, or with a business in which a relative or significant other is associated in any significant role.  Because the possibility that a conflict of interest may exist is greatest when executive officers or trustees are involved in a business transaction with the organization, such transactions are generally discouraged.

If such a related party transaction is unavoidable, the organization’s Corporate Compliance Officer must be informed of the nature of the transaction. The most significant related party transactions, particularly those involving HOH / SS executive officers or trustees must be reviewed and approved by the Board of Trustees. Full disclosure will be made to the external CPA for disclosure in the audited financial Statement.

BUSINESS TRANACTIONS

All employees should avoid representing HOH / SS in any transaction with any person or organization with which the employee, or any member of the employee's family, has any connection or in which he owns a substantial interest.

Employees who serve as an officer or a board member of any other organization shall not represent HOH / SS in any transactions with that organization.

All transactions with outside vendors should be conducted on a business-like basis in the best interest of HOH / SS. Decisions should be governed by a customer-business relationship and not by personal friendship.

CIVIC ACTIVITIES

Active participation by employees in religious, community, professional or charitable organizations is encouraged. Approval is not required to participate in or accept appointment as a trustee, director or officer of a non-profit organization unless there is a potential conflict of interest between the organization and HOH / SS. Participation should not include representing the policies or views of HOH / SS.

POLITICAL ACTIVITIES

Employees are encouraged to participate in political activities on their own time and in accordance with their individual desires and political preferences. However, it must be clear at all times that an employee's participation is done as an individual and not as a representative of HOH / SS. Before the employee becomes a candidate or appointee to a public office, the employee must advise his or her supervisor.

FIDUCIARY ACTIVITIES FOR PERSONS SERVED

Employees must not accept appointment as executor, administrator, guardian, trustee or act in any similar fiduciary capacity for another employee or person served unless the appointment arises out of a relationship with a member of the employee's immediate family. Approval for an exception to this policy shall not imply that an employee is serving at the direction or request of HOH / SS.

OUTSIDE EMPLOYMENT AND AFFILIATIONS

No outside activity shall interfere or conflict with the interests of HOH / SS.  Acceptance of outside employment, election to directorships of other organizations, and participation in the affairs of outside organizations may pose a conflict of interest.

Employees should avoid outside employment or participation in activities that would divert their time, interests or talents from their responsibilities HOH / SS. Of particular concern is when off duty work activities are such as to reflect unfavorably on the employee, fellow employees, or HOH / SS in general. Outside employment includes services performed both for wages and for fees. HOH / SS employees must obtain prior approval from the Chief Executive Officer before undertaking outside employment or participating in an activity that could be deemed in conflict with the operating philosophy of the organization or in conflict with the employee's specific job responsibilities.

No staff member of HOH / SS will be a director or officer of any other treatment facility or any other entity which competes directly or indirectly with HOH / SS without prior approval of the Chief Executive Officer, and/or the Board of Directors, whichever is appropriate.

Outside activities that may create a conflict of interest include:

1. Being employed by a business or personally engaging in any activity that is competitive with HOH / SS.

2. Using HOH / SS equipment, supplies, files, letterhead, or facilities for purposes other than HOH / SS related activities.

3. Personal conduct involving the use of mood altering substances or gambling activities outside of work hours which may prove embarrassing or reflect adversely on HOH / SS.

4. Statements or circumstances that may imply sponsorship or support by HOH / SS of an outside employer or of a political, charitable, civic, religious, or similar organization when such is not the case.

5. Private professional, technical, or counseling services, when these activities are done for people other than immediate family and when they may be in competition with services performed by HOH / SS.

COOPERATION WITH LAW ENFORCEMENT

Federal and state agencies have broad rights to investigate matters involving persons served care and billing. Employees shall cooperate with enforcement investigations and activities within the bounds permitted by law. Any employee who is contacted, orally or in writing, at home or at work, by a person stating that he or she is investigating on behalf of the government or an insurer, may refer the investigator to the Corporate Compliance Officer or legal counsel. Employees who are presented with a subpoena, warrant, or court order have the right to an attorney when speaking with a government investigator. The Corporate Compliance Officer or legal counsel will coordinate the disclosure of documentation. Employees who elect to speak with an investigator should tell the complete truth.

MARKETING

It is prohibited to pay for person served referrals. Payment can be anything of value, such as a discount or free service or equipment. Employees should avoid receiving or giving gifts of more than token value to those who can refer persons served or business to HOH / SS.

HOH / SS may use marketing and advertising activities to educate the public, provide information to the community stakeholders, increase awareness of our services, and to recruit colleagues. HOH / SS will present only truthful, fully informative, and non-deceptive information in these materials.

Antitrust laws are designed to create a level playing field in the marketplace and to promote fair competition. These laws could be violated by discussing HOH / SS business with a competitor, such as how HOH / SS fees are set, disclosing the terms of vendor relationships, allocating markets among competitors, or agreeing with a competitor to refuse to deal with a vendor. Employees should not engage in discussion or consultation with competitors relating to prices or terms. Any agreement or understanding with a competitor to divide markets is prohibited. This prohibition includes an agreement allocating shares of a market among competitors, dividing territories, or dividing service lines or consumers.

Any agreement with competitors to boycott or refuse to deal with a particular person or persons, such as a vendor, payer, or other health care provider is prohibited.

BILLING

When claiming payment for services, HOH / SS has an obligation to our persons served, third party payers, and the state and federal governments to exercise diligence, care, and integrity. HOH / SS is committed to maintaining the accuracy of every claim. Employees are expected to monitor compliance with applicable billing rules and established coding guidelines. Any false, inaccurate, or questionable claims should be reported immediately to a supervisor or the Corporate Compliance Officer.

It is against the law to knowingly submit false claims for payment. Submitting a false claim may include using the wrong billing codes, falsifying the treatment record, or billing for services that are not provided or are not therapeutically necessary. Violations of these laws can be punished by fines, prison, or both. The policy of HOH / SS is to bill accurately and only necessary treatment services that are provided and documented.

NONPROFIT STATUS

HOH / SS is tax-exempt 501(c)3 because of our charitable mission. A tax-exempt entity may not permit insiders (directors or officers who can influence organization decisions) to benefit personally from dealing with the organization. Nor may any private person (insider or not) receive a benefit from the organization beyond what is necessary to let the organization fulfill its mission (e.g. employees may be paid a fair salary). Those HOH / SS does business with should not receive more than fair market value for the goods or services they provide. Violation of the tax rules can result in loss of HOH / SS tax exemption status or can cause the IRS to penalize the person receiving an excess benefit and the personnel who approved the payment.

WASTE DISPOSAL

HOH / SS will comply with various environmental laws in the way it disposes of medical waste and other hazardous materials. Employees should follow the Health & Safety Manual – Hazard Waste Procedures.

CONTROLLED SUBSTANCES

Federal and state laws affect the handling and dispensing of controlled substances, including narcotics. HOH / SS will not tolerate unauthorized distribution or possession of controlled substances. Anyone having knowledge of a violation of this policy or the law should report it promptly, or may be subject to immediate dismissal.

EMPLOYEE INTEGRITY AND COMPETENCE

Employees shall be dedicated to maintaining high standards of professional competence and integrity.

1. Employees who (a) are convicted of felonies, (b) are convicted of misdemeanors related to their qualifications or functions, (c) engage in conduct which could lead to conviction of felonies or misdemeanors related to their qualifications or functions, (d) are expelled from other professional organizations, or (e) have their licenses or certificates suspended or revoked, are subject to termination of employment.

2. Employees shall seek appropriate professional assistance for personal problems or conflicts that are likely to impair their work performance or their clinical judgment.

3. Employees shall not engage in verbal, emotional or behavioral harassment of persons served, trainees, interns or colleagues.

4. Employees shall not attempt to diagnose, treat, or advise persons served on problems outside the recognized boundaries of their competence.

5. The solicitation or acceptance of commissions, fees, or gifts of monetary value on the part of an employee from persons served, vendors, or any other source as compensation for the performance of HOH / SS duties, is unethical, improper and, in some cases, illegal. Consideration for an appropriate gift must include: the persons served motives, the effect on their treatment, the value of the gift, the effect on the therapeutic relationship, and the context within which it is given.

6.  Engaging in any form of financial agreement such as lending or borrowing money or making a monetary investment with a persons served either during treatment or after discharge from treatment is improper and a misuse of influence.

7. If an employee is unable to be of professional assistance to the persons served or perceives an ethical conflict, the employee must share the concerns with his supervisor. The supervisor will determine the most appropriate action to be taken.

8. Employees will not engage in personal relationships with persons served of HOH / SS, including dating, sexual relations, or fraternizing. A dating relationship with a persons served is highly unethical. Exceptions exist only when a committed relationship was established prior to a persons served admission for services. It is the employee's responsibility to report such relationships to clinical staff, and they are to exclude themselves from direct services to the person served whenever possible. It is ill-advised to ever engage in friendship or sexual relationships with former persons served, regardless of how much time has passed.

ETHICAL RESPONSIBILITY TO COLLEAGUES

Employees shall treat colleagues with respect, courtesy, fairness and good faith.

1. The employee should cooperate with colleagues to promote professional interests and concerns.

2. The employee should respect confidences shared by colleagues in the course of their professional relationships and transactions.

3. The employee should create and maintain conditions of practice that facilitate ethical and competent professional performance by colleagues.

4. Any employee having knowledge of unethical practices on the part of another colleague should report such practices to a supervisor or the Corporate Compliance Officer.

5. An employee who replaces or is replaced by a colleague should act with consideration for the interest, character, and reputation of that employee.

6. The employee should extend to colleagues of other professions the same respect and cooperation that is extended to coworkers.

7. The necessity to confront colleagues regarding unethical or substandard treatment practice can contribute significantly to overall quality of professional services. In the event a colleague is using drugs, alcohol, or exhibits other addictive behaviors, which display impairment or distress in their work performance, direct confrontation is essential. Employees are encouraged to self-disclose their personal addiction and emotional problems to supervisors in an effort to receive rehabilitation services.

8. The employee should be mindful that attitudes and behaviors that are negative in nature adversely affect the workplace and HOH / SS. Therefore, all grievances, whether personal, procedural, or policy related should be directed to those in supervisory positions.  Employees may initiate a formal grievance procedure.

ETHICAL RESPONSIBILITY TO HOUSE OF HOPE/STEPPING STONES

1. Employees should adhere to commitments made to HOH / SS.

2. Employees should work to improve the efficiency and effectiveness of HOH / SS services and to follow policies and procedures.

3. Employees should use the resources of HOH / SS with scrupulous regard and only for the purpose for which they are intended. Every employee has a responsibility to protect the assets of HOH / SS against loss, theft, and misuse.

4. Employees are expected to maintain complete and open communication with
   management regarding HOH / SS matters. No employee will deliberately conceal information or mislead management auditors or counsel.

COUNSELING RELATIONSHIP

1. A counselor's primary duty is to respect the rights and integrity and promote the welfare of the persons served, whether the persons served is assisted individually or in a group. In a group setting, the counselor assumes responsibility for protecting individuals from physical or psychological suffering resulting from participation in the group.

2. In a group counseling setting, the standard of confidentiality should be firmly established regarding all participants' disclosures. Persons served information should be shared with colleagues or other staff members on a need to know basis.

3. If an individual is already in a counseling relationship with another professional, the counselor does not enter into a counseling relationship without first contacting the other professional and also obtaining proper releases for the exchange of relevant information regarding the person served. If the counselor discovers that the person served is in another counseling relationship after the counseling relationship begins, the counselor must gain the consent of the other professional or terminate the relationship, unless the person served elects to terminate the other relationship.

4. When the persons served condition indicates that there is clear and imminent danger to self or others, including the abuse or neglect of children, the elderly, or the developmentally disabled, the counselor must take reasonable action to prevent harm and/or inform responsible authorities. The Clinical Director or Chief Executive Officer must be consulted when possible. The assumption of responsibility for the persons served behavior must be taken only after careful deliberation. The person served must be involved in the resumption of responsibility as quickly as possible.

5. In recognition of the fact that the relationship between counselor and persons served is one in which the utmost discretion, good judgment and ethical behavior is of paramount importance, certain restrictions as to the scope of that relationship need to be carefully outlined and adhered to. This needs to be done in order to ensure the relationship's integrity and therapeutic soundness. Therefore, activities such as in-kind payment for services (i.e., a persons served offering free meals at a restaurant to a counselor in exchange for counseling services), any financial transactions between counselor and persons served such as lending/borrowing money, entering into loan agreements, formation of social relationships secondary to the ongoing therapeutic relationship, or the sponsoring in a 12-Step program of active persons served are all considered to be unethical and are not to be engaged in by the counselor.

6. If the counselor has other relationships, particularly of an administrative, supervisory, and/or evaluative nature, with an individual seeking counseling services, the counselor must not serve as the counselor but should refer the individual to another appropriate clinical staff member. Only in instances where such an alternative is unavailable and where the individual's situation warrants counseling intervention should the employee enter into or maintain a counseling relationship. Dual relationships with persons served who are close friends or relatives may impair the counselor's objectivity and professional judgment and therefore must be avoided. In such cases, the person served will be referred to another clinical staff member.

7. Counseling staff have a duty of care to persons served. Once a person served is admitted or involved in an ongoing counseling relationship, the counselor shall provide the care necessary regardless of the source or type of payment. Clinical care and judgment must be based upon the clinical needs of the persons served. When financial considerations arise, the counselor shall base recommendations for care solely on the persons served clinical needs and refer financial issues to a director or the Chief Executive Officer.

8. Because the counselor's primary responsibility is to provide clinical services to the persons served, the organization discourages such outside activities as foster parenting, facilitation of outside therapeutic groups, or any other activity that may adversely affect the counselor's job performance at HOH / SS. It is the obligation of every counselor, when contemplating participation in such outside activities, to obtain permission from the Clinical Director.

9. Counselors must attempt to prevent the distortion or misuse of their clinical findings.

10. Because of their ability to influence and alter the lives of others, counselors must exercise special care when making public their professional recommendations and opinions through testimony or other public statements.

COUNSELORS' RESPONSIBLITY TO PROFESSION

1. Counselors remain accountable to the standards of the profession when acting as members or employees of organizations.

2. Counselors recognize a responsibility to participate in activities that contribute to a better community and society.

3. Counselors should be concerned with developing laws and regulations pertaining to their field that serve the public interest, and with altering such laws and regulations that are not in the public interest.

4. Counselors recognize the need for continuing education and are open to new procedures and changes in expectations and values over time.

5. Counselors recognize that personal problems and conflicts may interfere with professional effectiveness. Accordingly, they refrain from undertaking any activity in which their personal problems are likely to lead to inadequate performance or harm to a persons served or colleague. It is the counselor's obligation to bring such conflicts to the attention of their immediate supervisor so that a determination can be made as to whether they should suspend, terminate or limit the scope of their professional activity.

INTERPRETATION OF CODE OF ETHICAL CONDUCT

Difficult questions of judgment may arise in connection with the Code of Ethical Conduct. If any doubt exists regarding the propriety of any action or activity, the employee should seek advice and written approval from the Chief Executive Officer, or the Corporate Compliance Officer. All employees are expected to promptly report the existence of any relationships, interests, or actions which might violate or appear to violate the Code of Ethical Conduct.

EMPLOYEE TRAINING:

New employee will be trained on the Code of Ethical Conduct prior to starting work in any program of the HOH/SS.

After receiving training, employees will sign and date documentation of training as well as attestation to their intent to conform to the Code of Ethical Conduct in all HOH / SS settings.

All employees of HOH/SS shall receive a minimum 1 hour of training annually to review updates on the Code of Ethical Conduct.

VIOLATIONS OF CODE OF CONDUCT

Any suspected violations of the Code should be referred to the Chief Executive Officer or Corporate Compliance Officer. Violations of the Code are grounds for discipline or dismissal.   Disciplinary actions are outlined in the Guide for Disciplinary Action Policy.  In situations where infractions of the Code may have violated federal or state law, such infractions will be disclosed as appropriate and reported to enforcement agencies as required.

Top