Coventry Code of Business Conduct
and Ethics
Course Structure:
Compliance and Ethics Training Program
This module is the first of three in the Compliance and Ethics Training Program. They are:
Code of Business Conduct and Ethics Privacy and Security
Fraud, Waste, and Abuse
To receive credit for completing the Compliance and Ethics Training Program, you must complete all three modules, pass the test for each module, and sign the Attestation of Completion and the Confidentiality Agreement.
Training Purpose
You may be asking yourself; "Why is it necessary to understand compliance and ethics?"
While one of the most important reasons is to meet federal, state, and local laws and regulations, it is also a good business practice.
Operating our business in an ethical fashion shows our commitment to the communities in which we live and work.
The purpose of this training is to help you understand how we can be better corporate citizens by following the Coventry Code of Business Conduct and Ethics, and meeting our obligation to federal, state, and local regulations.
Module Objectives
At the end of this program, you will be able to:
• Explain the parts of the Coventry Code and how it applies to
you.
• Identify resources to report suspected non-compliance.
• Identify laws and regulations that apply to our organization, our
business, and our employees.
• Identify your responsibilities as they pertain to dealing with
Introduction to the Coventry Code
Principles of the Coventry Code
The Coventry Code outlines Coventry's business standards and ethics policy. It is an official statement of how Coventry, its companies, and employees will conduct our business.
The Coventry Code requires each of us to act in a manner that is honest and lawful, and prohibits us from trying to get others to do something dishonest or unlawful.
The Coventry Code is a part of the Compliance and Ethics Program.
In this course, we will explore the Coventry Code, and the policies of the Compliance and Ethics Program.
The Coventry Code and the policies of the Compliance and Ethics Program can be found on the Coventry Compliance Center on the Coventry Today
homepage. [insert picture of Coventry Compliance Center link on Coventry Today homepage]
At the end of this training module, you will be asked to attest that you have read the Coventry Code and the Compliance and Ethics Program Policies
Knowledge of Improper Conduct
The Coventry Code also requires us to report knowledge of suspected or actual illegal, unethical, or improper behavior. All reports will be treated as confidential and privileged to the fullest extent permitted by law.
There are five methods for reporting such situations.
Manager, Supervisor, or Human Resources
Legal Counsel Compliance Officer CFO Coventry Comply Line
One way you can report suspected non-compliance is through your manager, supervisor, or Human Resources representative.
Once reported to your supervisor, they will then forward it to the appropriate individual or department for review.
You can report suspected compliance issues to Coventry's Legal Counsel. They have experience in reviewing and determining if an issue is a compliance violation.
Reports of non-compliance can be made to any of the following:
Chief Compliance Officer:
Laura Kelley (301) 581-5715
lxkelley@cvty.com
Medicare Compliance Officer:
Debra Nuckols 610) 212-4978
djnuckols@cvty.com
Medicaid Compliance Officer:
Debra Waln 804-385-6018
djwaln@cvty.com
Compliance mailbox compliance@cvty.com
Chief Human Resources Officer
Patrisha Davis 301-581-5480
pdavis@cvty.com
Vice President – Human Resources
Anna Gill
You can report allegations related to financial, accounting, or auditing matters to the Chief Financial Officer.
Our Coventry Comply Line allows you to call in
compliance concerns. The Comply Line is answered by an outside service, 24 hours a day, 7days a week. When calling, you will be given the option of reporting your concern anonymously.
The number for the Coventry Comply Line is: 1-877-CHC-LINE
Assuring Protection – Good Faith
The Coventry Code assures protection from any retaliation for
individuals who, in good faith, report violations or suspected violations. Good faith means that the individual has a reasonably held belief that the report is true and has not been made either for personal gain or for any ulterior motive. Acts of retaliation will be treated as a serious
Knowledge of Improper Conduct
Way to go! Later in the course, we will review in detail what could be considered a compliance violation.
Now that you know the five methods for reporting a compliance violation, we will discuss what happens in a compliance investigation.
Investigating Compliance Issues
So, what happens if someone reports a compliance issue?
When a compliance report comes in, it will be assigned to appropriate compliance personnel for
immediate investigation.
The individual who the report is assigned to varies based on the characteristics of the report. Coventry Compliance Officers and others may be involved to
determine all the facts of the case.
A thorough investigation will be conducted. It may include interviews with employees,
providers, or customers; reviews of files or electronic data; and
research of current or best practices.
Once the investigation is
completed, the person involved will develop a report that includes recommendations.
Based upon the recommendations, corrective action may be
necessary. Some of that corrective action may include:
•Policies or procedures may need to be updated, changed, or
removed
•Sanctions against parties found responsible for improper conduct that may include:
Written reprimand Verbal or written warning Suspension
Financial penalty
Demotion, delayed promotion, changes in responsibility, or termination of employment
Section 2 Knowledge Check
Allen Wise Our CEO, Allen Wise, does have responsibility for ensuring organization compliance. However, he is not our Chief Compliance Officer.
Harve DeMovick Sorry, that is not correct. Laura Kelley is the Chief Compliance Officer.
Laura Kelley That is correct. Laura Kelley is the Chief Compliance Officer.
Jim McGarry Sorry, that is not correct. Laura Kelley is the Chief Compliance Officer.
Coventry's Chief Compliance Officer is:
If you know or think you know of a potential compliance violation, what should you do? (Check all options that apply and click "Submit")
Contact the Coventry Chief Compliance Officer, a Deputy Compliance Officer, the Coventry Medicare Compliance Officer, or the Coventry Medicaid Compliance Officer.
Call the Coventry Comply Line.
Ignore it. Someone else will take care of it.
Speak with your supervisor, manager, or HR representative.
That is correct. You can report a violation or potential violation of the Coventry Code to any one of the following: 1) A Chief, Deputy, or Coventry Medicare Compliance Officer 2) A supervisor, manager, or HR representative 3) The Coventry Comply Line 4) Coventry Legal Counsel 5) Chief Financial Officer.
In a recent conversation with a co-worker, Joe explained how he was adding a few miles to each trip made to his expense report to make up for the high price of gas. He said that it only amounts to a few dollars on each expense check. Because it is such a trivial amount, you are not required to report this as a compliance violation.
True / False
That's right! Regardless of how large or small the expense, if it is a violation of the Coventry Code, it should be reported. .
Section Summary
The Coventry Code is Coventry's official statement of how Coventry and its companies will conduct business.
As a Coventry employee, you are required to behave honestly and lawfully. In addition, you must report violations or what you believe to be violations to a supervisor, manager, HR representative, the Chief Compliance Officer, the Medicare Compliance Officer, the Medicaid Compliance Officer, Coventry Legal Counsel or the Coventry Comply Line at 1-877-CHC-LINE. Retaliation for good faith reporting is not tolerated.
Reports of non-compliance will be investigated and action will be taken to correct the situation, which may include a change to a policy or procedure or sanctions on those parties involved.
Avoiding Conflicts of Interest
What is a Conflict of Interest?
A conflict of interest is any situation that may present itself as an opportunity for personal gain apart from your normal salary and benefits. It could also conflict with or appear to conflict with Coventry's interests.
Conflict of Interest Scenario
This is Dan. He is responsible for negotiating contracted provider rates for our health plan. This is Bob. He is the head administrator for a large physician practice with which Coventry contracts. He negotiates with Dan on contract rates.
Conflict of Interest Scenario
Bob's facility is about to begin rate negotiations for the next year. Suddenly, Dan gets a $500.00 gift card and box seats for the Pittsburgh Steelers opening game from Bob.
In this case, this would be a conflict of interest. Dan stands to gain personally from Bob's gifts; and they could influence him to make decisions that conflict with Coventry's best interests.
Prohibited Conduct
The Coventry Code specifies conduct that is prohibited. This includes the items listed here. Participating on Boards of Directors or as a Trustee of any organization that has or may have interests that conflict with Coventry, without prior approval
If you are a Coventry executive officer or director, accepting any loans or guarantees of obligations from Coventry, other Coventry employees, officers or directors, or from any other person or entity having or seeking business with Coventry, except as permitted by law
Accepting loans or guarantees of obligations from any person or entity, including suppliers and vendors, having or seeking business with Coventry
Using Coventry's assets for your own benefit
Pursuing personal financial interests that could conflict with Coventry's interests
Taking outside jobs or participating in activities that could conflict with your responsibilities to Coventry
Speaking on behalf of Coventry without permission of the CEO
Without the consent of the Coventry Board of Directors, taking any opportunity discovered through the use of Coventry property, information, or position
Proper Use of Coventry Resources
Coventry's employees are responsible for managing the use of the company’s, suppliers’, and customers’ resources in a way that reflects good judgment. Follow these guidelines to ensure you use Coventry's resources properly.
• You are prohibited from using any Coventry assets, facilities, or services for
any unlawful, improper, or unauthorized purpose.
• You may only use Coventry's assets for non-Coventry purposes when
specifically authorized by Coventry's policies or procedures, or as expressly authorized by your supervisor.
A Practical Guide
On the next few pages, we will review some practical examples dealing with the Coventry Code. You will be given a scenario and asked to select the best possible answer.
Example 1
Read the example at the right. Click on the best possible answer.
John Dory is a customer service representative. He also volunteers with a local charity that is holding a major fundraising event in two weeks. According to the Coventry Code, which of the following WOULD BE considered prohibited conduct?
Making 1000 copies of charity flyers using the office copier after work.
Soliciting his manager and co-workers for a donation for the charity during breaks, lunch, or outside work hours.
Telling his close friends about his involvement and the important work this charity is doing.
Offering the CEO of the local health plan an opportunity to advertise in the event's program.
That is correct! The only one of these that is a violation of the Coventry Code is the first choice. Using Coventry resources without direct supervisory approval is a violation of the Coventry Code.
Example 2
Jeanine Dularo works in Provider Credentialing. Which of the following is NOT considered prohibited conduct under the Coventry Code?
Taking home a box of copy paper for her personal use.
Speaking as a Coventry employee, to a reporter, about a story involving Coventry's business practices.
Using her company-issued cell phone to contact her airline before she leaves for the airport. She is traveling on company business.
Starting an independent consulting company specializing in provider credentialing. Her work is all done after hours, not on Coventry time.
That is correct! All of these actions, with the exception of using her company cell phone to contact her airline while traveling on company business, could potentially be a violation of Coventry Code.
Example 3
Michael O'Flaraty is a manager in Provider Relations. He has worked with
Physicians General Hospital for about 4 years. Which of the following could be considered prohibited conduct?
Going to lunch with the medical director of the hospital.
Selecting this hospital for his upcoming surgery because he knows a good surgeon who works there.
Taking an unpaid, volunteer position as a director on the hospital's board. Speaking to a friend about the excellent services at this facility.
Perfect! The only action in this list that is a violation of the Coventry Code is taking on a board position regardless of pay.
Coventry employees must get approval before beginning jobs that may compete with Coventry's interests.
Reporting of Conflicts
If you believe you have a conflict of interest, have questions about a given situation, or know of any situation that may be a conflict of interest, you can use any of the four reporting methods listed in the previous section.
They are:
A supervisor, Manager, or an HR Officer Coventry Legal Counsel
Chief, Deputy, Medicare or Medicaid Compliance Officer The Coventry Comply Line 1-877-CHC-LINE
Summary
The Coventry Code prohibits employees from engaging in specific conduct. You may not:
• Use Coventry's assets for your own benefit
• Pursue financial interests that could conflict with Coventry's interests • Take outside jobs or participate in activities that could conflict with your
responsibilities to Coventry
• Take any opportunity discovered through the use of Coventry property, information, or position without the approval of the Board of Directors
• Participate on Boards of Directors or serve as a Trustee of any organization whose interests may conflict with Coventry without prior approval from Coventry Legal Counsel
• Accept loans or guarantees of obligations from any person or entity, including suppliers and vendors, having or seeking business from Coventry
• If you are a Coventry executive officer or director, accept loans or guarantees of obligations from Coventry, other Coventry employees, officers or directors on behalf of Coventry, or from any other person or entity having or seeking business with Coventry, except as permitted by law
Compliance Related Laws and Coventry
Policies
Compliance Laws: The Practical Impact
This section reviews the many laws and regulations that govern Coventry and its businesses. The practical impact of failing to follow these laws and regulations can have a negative impact on Coventry and its employees.
Compliance Laws: The Practical Impact
Take a look at these actual newspaper headlines:
Justice Department used the False Claims Act to recover approximately $3 billion since January 2009 for fraud against federal health care programs.
OIG excludes 1,935 individuals and entities from participating in Federal health care programs in first half of FY 2010.
Insurer faces up to $7 million state fine for claims handling violations.
As you can see, failure to follow laws and regulations can have a negative impact on our company, its reputation, and even impact our employees directly.
Applicable Laws and Coventry Policies
As illustrated on the previous page, failure to follow laws and regulations can have a negative impact on our business. There are a number of laws and regulations that we must follow. We are going to focus on four areas for this training.
Corporate Governance and Securities Laws
Since Coventry is a public company whose shares are traded on the New York Stock Exchange, we are subject to certain federal and state corporate governance and securities laws. Further, Coventry maintains and adheres to its own policies and procedures in this area.
Here are some of the highlights of those laws and policies.
• It is illegal for you to buy or sell Coventry stock if you know material, non-public information. • It is illegal for you to give non-public information to anyone who might buy or sell Coventry stock. • Blackout periods may be instituted for any number of reasons (e.g. corporate earnings season,
changes to record keeping policies).
• Officers and directors are prohibited from trading stock of their companies during blackout periods (including their 401(k)).
Corporate Governance and Securities Laws
To ensure compliance with all federal and state security laws, Coventry strictly forbids:
• Sharing important, private, or confidential Coventry information with any unauthorized person, including family members
• Buying or selling Coventry stock while you possess material non-public information
• Buying or selling Coventry stock, except in your 401(k) plan account, without first getting approval from Coventry Legal
• Speculatively trading in Coventry stock
• Discussing Coventry business with news media, securities analysts, or investors
• Posting information about Coventry on Coventry's websites, blogs, or forums without approval from Coventry's Legal Department
Introduction to Federal and State Health Care
Programs
Coventry offers several products tied to federal and state health care programs.
Medicare is the program run and paid for by the federal government. In general, it provides medical care for those over the age of 65, and in some cases, for those with permanent disabilities. The Centers for Medicare & Medicaid Services is the agency responsible for
administering and enforcing Medicare programs.
Medicaid programs are funded by both federal and state governments. Each state then operates its own program. Medicaid provides hospital and medical coverage for people with low incomes or those without
resources. In addition, many states offer programs to cover health care for children.
Fraud, Waste and Abuse Regulations
Our Medicare and most Medicaid products are subject to a range of legal requirements that may be very different from our commercial products. One of the most important is known as fraud, waste and abuse regulations.
Click on each of the four main areas covered by fraud, waste, and abuse. Then click Next to continue.
False Claims: Submitting or encouraging others to submit false, fraudulent, or misleading claims for payment from the government or third party payors is a violation.
False Representations: Providing, making, or encouraging others to submit false information on an application or any attempt to get or keep government services or payments is considered fraud.
Referrals or Kickbacks: You cannot offer or accept anything of value for the referral of a member or service that would be paid by the government.
Hiring Excluded Persons or Organizations: Failure to follow regulations can result in
being placed on an excluded list. Our company cannot hire or contract with anyone who has been excluded from federal or state health care programs.
Antitrust Laws
Coventry is also subject to antitrust laws that prohibit conduct that harms competition.
Coventry is prohibited from entering into any agreement to:
• Fix prices, including premiums and provider payments
• Fix the terms of other services
• Allocate customers or markets
• Boycott or jointly refuse to deal with a supplier, customer or provider
• Buy a company in a similar lie of business where the effect is to
substantially lessen competition
Record Retention and Document Destruction Policy
Many of the documents we work with on a daily basis are required to be retained. Some of our other documents are Official Records and each employee is required to follow Coventry's Record Retention and Destruction Policy. This policy can be found on essentials under Compliance.
Before beginning destruction of company documents, check with your
department's Record Coordinator or your supervisor. They can confirm the policy and verify if a document is considered an Official Record.
In general, Official Records may be:
in any form (paper, electronic, email)
related to business activities such as contracts, claims, HR files, official correspondence, or medical records
This policy applies to all documents, regardless of whether they are paper or electronic.
Record Retention and Document Destruction Policy
Great job! As you can see, Coventry and its businesses must follow multiple compliance and ethics related laws when doing business. You will have an opportunity to review these laws in more depth when you take the "Privacy and Security" and "Fraud, Waste, and Abuse" modules.
The next section will explain the consequences of failing to follow these laws and policies.
Consequences of Non-compliance
While Coventry faces penalties for non-compliance, many people do not realize that failure to follow these laws or regulations can impact them personally.
Employees who fail to adhere to these policies, procedures, laws, and regulations can potentially face...
Company sanctions or corrective action, Termination,
Section 4 Knowledge Check
Margaret works in a department that must keep files for 3 years. However, they have never had files destroyed and now have files that date back more than 10 years. Margaret's department receives a notice from the Legal Department that there is a record freeze due to an investigation. What should Margaret do? (Click all that apply and click submit)
Not disclose to the Compliance or Legal department that these additional files exist. Retain all files until cleared by the Legal or Compliance Department.
Contact Coventry Legal and explain the situation with the outdated files.
Contact a company who specializes in record destruction and have the outdated records beyond the 3 year window destroyed.
That's right! You should notify Coventry Legal of the situation and retain all the files until you are informed that the record freeze has been lifted. Only after Coventry Legal lifts the record freeze should the manager hire a company or contractor to destroy the outdated files.
That is incorrect. If you receive a record freeze notice, no files, regardless of age should be destroyed. Also, you should contact Coventry Legal and explain the situation.
Ellie Dandiee works as a director in the finance department. She is responsible for reviewing and approving a key financial report that is sent to senior management. It appears that earnings for this quarter are going to be lower than last. For which of the following does she need approval? (Click the best answer and click submit)
Sell some of her Coventry stock that she purchased through her own personal broker. We are in an open window period.
Great! You got it. Ellie does need to get approval from Coventry's Legal Department prior to selling shares of her Coventry stock.
Reduce the amount of money going into her 401(k). That is incorrect. Ellie is not required to get approval before reducing her contribution to her 401(k). However, she is required to get approval before she sells any Coventry stock.
Neither of these require approval. That is incorrect. Actually, Ellie is required to get approval prior to selling her Coventry stock. However, you are correct that she may reduce her contributions to her 401(k) during any open window period without prior approval.
Both of these require approval. That is incorrect. She is only required to get approval prior to selling shares of her Coventry stock. She may reduce her contributions to her 401(k) during any open window period without prior approval.
Summary
Coventry is required to follow many federal, state, and local laws and regulations. Failure to follow these laws and regulations places Coventry, its business, and its employees at risk for sanctions, fines, or other regulatory oversight. Laws and regulations include:
•Federal and state laws
•Fraud, waste, and abuse laws and regulations
•Corporate governance laws such as Sarbanes-Oxley •Antitrust laws
•Record retention regulations
Working with Outside Parties
Guidelines when Working with
Those Outside of Coventry
Working with Outside Parties
It is not unusual for Coventry to work with outside parties. Some of those may include contractors, lawyers, or federal and state agencies. Coventry is committed to being honest and straightforward in all our dealings with
outside parties.
This section will explain some important points when you are contacted by or working with an outside party.
Working with Outside Parties
This section will explain some important things to remember when you are contacted by or working with an outside party.
Take a look at these posted guidelines, then click Next to continue.
Marketing and advertising for Coventry products must only contain straight forward, honest, and fully informative content.
If you are involved in the pricing of contracts or
negotiations, you must ensure that all data generated and supplied to others is current, accurate, and complete.
Agreements with outside contractors must be in writing and clearly state the services to be performed, the basis for payment, and the applicable rate or fee.
Government Agencies
You may on occasion be contacted by federal or state government agencies, contractors with enforcement, or other auditing or regulatory authority over Coventry operations.
Actions if Contacted by a Government Agency
If a representative from any of these regulatory agencies contacts you and requests information, documents, an interview, or access to Coventry premises, here are some things to consider.
• Be courteous at all times.
• Get the representative's name, agency, contact information, and nature and substance of the request.
• If possible, defer responding until you receive instructions from Legal or Compliance. • Request a written copy of the request and instructions for responding.
• Do not destroy any documents that may be covered by the request.
• Immediately contact a Coventry Compliance Officer or Legal Counsel. Provide copies of all the documents.
• If possible, defer responding until you receive instructions from Legal or Compliance.
• Do not feel pressured to speak with a representative from a government agency without first contacting a Corporate Compliance Officer or Legal Counsel.
Final note on releasing company information:
Keep in mind that documents, records, computer files, and other company materials may contain proprietary information protected by law against disclosure.
These protections may be compromised if you disclose such materials without observing proper procedures.
Importance of Responding Properly to Government
and Regulatory Agencies
Is it really that important for us to follow these procedures when
a government or regulatory agency requests information?
Why is this so important?
Yes, it is very important. If you release information without working through Coventry's Legal Department or
Corporate Compliance, we risk possibly providing outdated, misleading, or incomplete information.
Providing inaccurate, outdated, or misleading information, whether intentional or unintentional, could
subject you or Coventry to civil or criminal penalties.
The bottom line is that we should get Corporate Compliance or Legal involved as early as possible when
Gifts and/or Entertainment Involving Outside Parties
In order to avoid the appearance of improper relations with outside
parties, the Coventry Code prohibits the following with anyone who does or may do business with Coventry:
• Accepting any gifts of cash or cash equivalents (e.g., gift
cards), or asking for gifts, gratuities, or any other kind of personal benefit or favor
• You or your family members accepting any non-cash gift
worth more than $100 or smaller gifts that total more than $100 in a single calendar year from a single business or individual
• Encouraging or asking for meals or entertainment
• Offering or giving anything of value to federal, state, or
Section 5 Knowledge Check
Thank the hospital for such a nice gift and split it with her staff.
That is not correct. Dr. Dixon should contact the Chief Compliance Officer first before taking any action. Return the gift basket to the hospital. That is not correct. Dr. Dixon should contact the Chief
Compliance Officer first before taking any action.
Report receiving the gift to the Chief Compliance Officer.
That is correct. You must first contact the Chief
Compliance Officer before taking any other action with the gift basket.
Re-gift the basket to other companies that Coventry does business.
That is not correct. Dr. Dixon should contact the Chief Compliance Officer first before taking any action.
A government official has arrived at your office and has requested Coventry to provide copies of records retained by your department. Which of the following should you do? (Select all that apply and click "Submit")
Request a written copy of the request and the instructions on how the agency would like for us to respond.
Be courteous to the representative, get their name, agency and contact information, and determine the nature and substance of their request.
Politely and quickly escort the official to the area with the records so they can review them and make copies.
Contact a Compliance Officer to advise them of this request. If possible, delay responding to the agency until speaking to a Chief Compliance Officer.
That is correct! The only thing that you should not do from this list is escort the officials to the records area. All of the others are correct answers.
That is not correct. All of the above are correct with the exception of escorting the official to the area with the records.
Dr. Dixon is a medical director of a Coventry health plan. This year, she received a gift basket from a local hospital that Coventry does business. She estimates the value to be $300.00. Which of the following is the correct thing for her to do? (Click the best answer and click Submit)
Summary
Coventry strives to be honest and straightforward in all its dealings with outside parties.
Outside parties may contact Coventry to request documents or access to our premises for multiple reasons. When a request comes in, be sure to contact a Corporate Compliance officer or legal counsel as soon as possible.
In order to avoid the appearance of improper relations with outside parties, Coventry prohibits all employees from receiving or asking for gifts of cash or cash equivalents, and from asking for gifts, gratuities or any other kind of
personal benefit or favor. If you receive a non-cash gift worth more than $100 you must report it to the Chief Compliance Officer or the General Counsel, who will determine if the gift can be accepted or must be returned.
Final Assessment
Instructions
For this quiz you will be given a series of 5 questions, Select the best choice for each question. You must pass the quiz with at least 80% in order to complete this module.
Conclusion
As you can see, compliance and ethics are an important part of how
Coventry does business. We must remain committed to the Coventry Code and be good stewards of the corporate community.
Once you have passed the quiz, you will have completed the module on Code of Business Conduct and Ethics. There are two other modules that must be completed as part of the Coventry Compliance and Ethics Training Program. They are titled "Privacy and Security" and "Fraud, Waste, and Abuse."
In addition, you must sign the Attestation of Completion and the Confidentiality Agreement.
To close this course, click on the close button (x) in the upper right hand corner.
