Ammon Analytical Laboratories

Code of Conduct

WORKPLACE CONDUCT AND EMPLOYMENT PRACTICES

We recognize that the greatest strengths of our organization lie in the effort and talent of our employees, who create our success in our reputation.

We treat each other with respect, dignity, courtesy and support each other as a team. Employees must be honest and lawful in all of their business dealings and avoid doing anything that could create even the appearance of impropriety. Employees must comply with the Code of Conduct and report any action they think may be unlawful. Specifically, phlebotomists, collectors, KAMs, sales, lab technicians, client service representatives, human resource representatives, billers, finance, and other employees must be truthful and honest. Ammon Lab employees do not implement contingencies that would cause others to engage in fraudulent, illegal, or unethical conduct.

Dress Code: All employees are expected to maintain a high level of professional conduct. Employees who work “in the field”, such as collectors and phlebotomists, or in the lab must dress professionally. Employees required to wear Ammon lab coats, or “green scrubs” or drivers, (black pants) must also wear name badges at all times. Additionally, gloved required procedures must be complied with by all applicably assigned employees. All applicable employees who are engaged in collecting specimens must utilize proper collecting and testing techniques.
Language: Employees who interact and work directly with Ammon’s clients must maintain a high level of professionalism. Profanity, making negative derogatory statements towards staff, clients or our client’s patients are never acceptable.
Interactions with Patients: Ammon staff are not to engage in inappropriate conduct, such as flirting, providing patients with your personal information, including but not limited to phone numbers, emails, addresses or social media accounts is prohibited. If patients are inappropriately contacting employees, this must be reported immediately to your supervisor.
Drug Testing: We support and require a workplace free of alcohol, drugs, tobacco, and smoking.
Sanctioned Persons: We do not employ, engage, or do business with employees who have been sanctioned by any regulatory agency and are not able to perform the designated responsibilities.
Non-Retaliatory We do not tolerate any act of retaliation or retribution against any employee who in good faith reports suspected violations of law or regulations, Ammon Lab policies, Ammon Lab Employee Handbook or our Code of Conduct.
Open Door Policy: We have a management team who fosters an” open-door policy” and creates a work environment in which ethical concerns will be addressed. Staff will receive appropriate training and orientation and have the proper qualifications, experience and expertise to perform the duties and meet the needs of our clients and patients.
Nondiscriminatory: We provide equal employment opportunity to prospective and current employees, based solely upon merit, qualifications, and abilities. Ammon Lab will not tolerate discrimination or harassment of any kind.
Harassment Free Environment: Each employee has the right to work in an environment free of harassment and disruptive behavior. We do not tolerate harassment by anyone based on the diverse characteristics or cultural backgrounds of those who work with us. Degrading or humiliating jokes, slurs, intimidation, or other harassing conduct is not acceptable in our workplace. Sexual harassment is prohibited. This prohibition includes unwelcome sexual advances or requests for sexual favors in connection with employment decisions. Moreover, verbal, and physical conduct of a sexual nature that interferes with an individual’s work performance or creates an intimidating, hostile or offensive work environment has no place at Ammon Labs. Ammon Lab employees are never allowed to engage in sexual relationships with patients. Harassment also includes the exploitation of persons over whom they have supervisory, evaluative, or other authorities such as supervisors and patients. Violation of this policy may result in termination.

Employees who observe or experience any form of harassment or violence should report the incident immediately to their supervisor or call the Human Resources Department immediately at 908-862-4404, (Ext 199).

2. COMMITMENT TO QUALITY OF LAB SERVICES

We make every effort to provide each client and all patients with the best possible lab services to reach optimal outcomes. We are committed to providing clear, accurate, honest, and transparent information about the quality of lab services that we offer to all of our patients and clients so that they can make informed healthcare and educational decisions. We strive to ensure that Ammon Analytical Laboratories maintains a high standard of quality of care and services. We believe all employees should strive for safe, effective, timely and equitable lab services.

A. TESTING ACCURACY

Ammon Analytical Laboratories (Ammon) maintains professional high-quality laboratories nationwide.

1) Upon specimen check-in, Ammon laboratory staff apply bar codes that will track the progress of a sample’s processing and testing throughout the lab

2) Lab personnel perform all sample analysis with state-of-the-art technology and the latest procedures

3) Laboratory technologist provides a “human review” to ensure the test results fall within reasonable medical expectations

4) Results are placed in a timely fashion into our online laboratory system for customer retrieval

B. Our laboratory technicians are highly trained, certified, and experienced
With consistent processes and equipment across Ammon laboratory locations, and over 95% of all testing completed by in-house laboratories, the risk of processing and human error is minimized. The result is that Ammon produces highly accurate and actionable results that providers and patients have come to rely on.

3. COMPUTER SECURITY AND CONFIDENTIALITY

We safeguard Ammon Lab’s information technology and proprietary information. We protect from improper use and access by maintaining and monitoring security systems, data backup systems and storage capabilities to ensure that information is maintained safely in accordance with federal and state requirements and Ammon Lab’s policy and procedures. We only allow authorized employees to have access to Ammon Lab’s computer systems and software on a “need to know” basis.

As an employee, if you are to utilize computer systems as part of your job description, you will be required to comply with security awareness training. Use due care and due diligence to maintain the confidentiality, availability, and integrity of information while you are employed with Ammon Lab. Because so much of our clinical and lab business information is generated and contained within our computer systems, it is essential that each employee protect our computer systems and the information contained in them by not sharing passwords and by reviewing and adhering to our information security policies and standards.

Employees may not use Ammon Lab’s devices or provided communication channels or access the Internet or social media to view, post, store, transmit, download or distribute any threatening materials; knowingly, recklessly, or maliciously false materials; or anything constituting or encouraging a criminal offense giving rise to civil liability or otherwise violating any laws.

4. RESPECTING PATIENT PRIVACY: HIPAA

All our employees must respect and protect the privacy of our patients, clients, and our employees. All confidential information obtained in ethical, or consulting relationships should be discussed in appropriate areas where patient’s confidential information cannot be maintained. All employees must not share or create situations likely to result in the sharing of any identifying information of patients, clients/facilities, or employees within social media contacts. Violation of this policy may result in disciplinary procedures, including termination.

We do not discuss patients or employer information in any public area, including hallways, restrooms, waiting areas or in the lab area where conversations may be overheard. You are required to maintain confidential information appropriately.

We believe protected health information in written form should never be exposed for others to see who are not authorized to see it. For example, lab test results or face sheets, requisitions, should not be left unattended in open areas for unauthorized persons to see. Computer screens also with protected health information should not be left unattended.

We comply with the HIPAA privacy and security laws. For example, we must never disclose confidential information without the consent of the patient, except as mandated by law, or were permitted by law for a valid purpose. Confidential information refers to sensitive information such as personal client data, clinical lab data, patient financial information, company financial information, Social Security numbers, passwords, pricing and cost data, information pertaining to strategic plans and marketing strategies and techniques. Sensitive data may also include photos and videos. If you find that you or coworker believes HIPAA law has been violated, please contact the Chief Ethics & Compliance Officer.

Patient Test Results: Under no circumstances should employees disclose test results to a patient. This violation is a terminable offense.

5. ENSURE ACCURACY OF CODING AND BILLING

A) OVERTIME: Employees are expected to work their designated number of hours. If overtime is required, an employee MUST obtain approval by their immediate supervisor.

B) TIME PUNCHES: It is Ammon Lab’s policy that employees’ work ethic requires honesty and truthfulness.

An excellent work ethic includes employees accurately clocking in and clocking out IN PAYLOCITY. It is considered highly unethical to have another employee clocking in for a friend and should be reported as a violation of their code conduct. Time Cards MUST be approved by supervisors. Clocking in Paylocity EARLY before your shift begins or LATE after your shift endedwill not be allowed unless approved by the supervisor.

C) REQUISITIONS: We ensure that all payments and requisitions are properly authorized with provider signatures. We must ensure that every requisition has an appropriate ICD-10 Code and that we maintain accurate documentation. We notify the payer of payment errors and process refunds within 60 days according to the overpayment rule in accordance with law.

D)CLIENT BILLING: We utilize only those codes that correspond to the lab services rendered.

E) CLAIMS: We process and submit accurate and complete claims and will only bill for services and care provided according to medical necessity guidelines. We ensure that coding and billing are performed in accordance with Medicare and Medicaid and other applicable federal and state regulations as well as any other payer coverage and billing requirements.

6. AVOID CONFLICT OF INTEREST

All employees are to disclose to the Chief Ethics and Compliance Officer any conflicts of interest in outside companies. Conflict of interests can include both financial interest in nonfinancial relationships with entities that compete or do business with healthcare and include any interest that otherwise could create an appearance of a conflict. Conflicts must be reported. We avoid engaging in any activity, practice or act that creates an actual conflict. No employee shall accept any gifts, business courtesies, or gratuities of material value. Employees are not allowed to accept gift cards or anything else of value from patients or clients. We avoid conflicts of interest or appearance of conflict of interest between our own individual interests in the interest of your employer.

7. MANDATORY REPORTING

We are ensuring that suspected violations of law, regulations, policies and procedures or the Code of Conduct are properly addressed.

You may ask, “What should I do if I believe someone is in violation of our Code of Conduct”?

Answer: You should report the concern to the Chief Compliance Officer or through the Compliance Hotline.

All reported concerns are investigated, and investigations may reveal there is a need for correction, education, or clarification.

Reporting your concern is an important part of the effectiveness of Ammon Lab’s Compliance Program. An employee MUST report a suspected violation of the following:

Activities that you suspect a harmful to a patient or staff member.
Activities you suspect are illegal or unethical.
Activities that violate any state or federal healthcare requirement; and/or activities that violate this Code of Conduct.

8. HOW TO REPORT A CONCERN

Concerns, complaints and potential violations of this Code or any other compliance related policy may be reported to the Chief Ethics and Compliance Officer in 3ways:

1. Compliance Hotline: 888-515-6023

2. Email: Compliance@ammonlabs.com 3. Telephone: 908-862-4404, Ext 149

9. INVESTIGATIONS

Reported concerns and issues will be investigated.

Additionally, Ammon Lab requires timely responding and reporting of information. All employees must cooperate with compliance related inquiries and actively work to correct any unethical, illegal, or improper practices that are identified.

10. CONCLUSION

This Code of Conduct covers a wide range of topics. It is intended to offer a framework to help you make good decisions that are compliant with our policies and the law in connection with your employment. However, no manual or guidebook can address every possible situation that may implicate the standards.

Please ask questions if you are ever unsure about how to proceed.

To report any Fraud, Waste and Abuse call:

Donna Rooney, Chief Ethics and Compliance Officer

Compliance Hotline: 888-515-6023