Introduction

All vendor representatives are expected to be familiar with this Code of Conduct. Vendors are expected to self-monitor their compliance with this Code of Conduct while conducting business with OHI. In doing business with OHI, vendors are expected to honor all business commitments and display professional behavior, fairness, and reliability in all business transactions. Vendors are expected to timely report any instances of non-compliance. We reserve the right to monitor compliance with this Code of Conduct using a reasonable and risk-based approach. This may include verification with questionnaires, audits, testing and other acceptable means. A vendor arrangement, and vendor access, may be terminated for failure to follow this Code of Conduct.

Vendor representatives are required to conduct business activities in compliance with all applicable laws and regulations, including those pertaining to Medicare/Medicaid, fraud and abuse, and antitrust.

During the course of the vendor representative’s relationship with OHI, the vendor representative may incidentally come in contact with sensitive and confidential information about OHI business, patients and their care. Vendor representatives who are responsible for providing services at OHI are accountable to the requirements of the Health Insurance Portability and Accountability Act (HIPAA) Privacy and Security rules and state laws that provide more stringent safeguarding of protected health information (PHI). Representatives are subject to additional OHI HIPAA policies and procedures, which may be updated from time to time. Vendor representatives are prohibited from accessing OHI computers or electronic medical records (unless approved by management). Vendors will:

• Not use or disclose confidential information or PHI without prior written authorization from OHI, or as outlined or described in underlying contracts and/or business associate agreements.
• Not email, remove from, or in any way, divulge, copy, release, sell, loan, review, alter or destroy any PHI or confidential information obtained during approved business activities except as otherwise necessary for the vendor to provide treatment, payment, health care operations or services to the patient directly, if applicable.
• Not photograph or audio/video record patients, team members or visitors without OHI advance approval and patient consent under any circumstances.
• Remain vigilant against security threats, such as social engineering and phishing attempts and will report any suspicious activity to management and/or IT/CE.

OHI does not conduct business with any individual, supplier or entity excluded, debarred or ineligible to participate in federal or state healthcare programs such as Medicare or Medicaid, or those whose officers, directors or employees are excluded from participating in federal or state healthcare programs. Vendors are responsible for taking all necessary measures to ensure officers, directors and personnel involved in providing goods and services at OHI, directly and indirectly, remain eligible to participate in federal and state healthcare programs.

Vendors may not provide team members, physicians, patients or affiliates with gifts, entertainment, food or business courtesies that could reasonably be perceived by anyone as an attempt to affect the judgment of the recipient or to induce or secure the ordering of a supply or service. All product and service presentations provided at OHI will have a primary purpose of furthering knowledge relevant to each team member.

Vendor representatives may not conduct business in any OHI facility without prior approval from OHI Supply Chain. Vendor representatives may not leave any products in any areas (e.g., nursing, cardiovascular and surgical units) without prior approval from OHI Supply Chain. Only purchase contracts signed by OHI Supply Chain, Asset Strategy or Information Technology will be honored.

Conflicts of interest, or the appearance of conflicts, between Vendor and any OHI team members should be avoided. If an actual or perceived conflict of interest arises, Vendors must disclose the actual or perceived conflict of interest to OHI. If a Vendor’s employee has a family, financial or other personal relationship with an OHI team member, the Vendor must disclose this fact to OHI and discuss whether there might be a conflict of interest to resolve. To prevent conflicts of interest, Vendors may not engage in any business dealings with an OHI team member with whom they have a personal, family or financial relationship with. It is not possible to list every type of conflict of interest; however, when in doubt, the Vendor should timely notify OHI with the facts of the situation so that we may attempt to mitigate or resolve the conflict.

Vendor representatives with prior OHI employment may not represent a vendor at any OHI facility for a period of twelve (12) months after leaving the employment of OHI. Reasonable exceptions may be approved by OHI Compliance or Supply Chain.

Vendors may not issue testimonials or engage in any advertising or endorsement activities that use the name or likeness of OHI, or any of its facilities, services, programs, or patients, in any written or verbal communication, to include social media, press releases and press events, or any other general announcements. Vendors may not contact or ask OHI team members, physicians, patients to participate in such events or actions, without OHI’s advance written approval.

OHI requires vendors to retain and make available, records related to business activities with OHI in accordance with applicable law, regulation and contract requirements.

As a community leader in healthcare, OHI is dedicated to promoting an environment that helps to improve the overall wellness of our patients, team members and visitors. Smoking, including vaping, and any form of tobacco use is prohibited on all OHI properties.

All vendor representatives must be credentialed, registered and appropriately identified prior to entering an OHI acute care affiliate. Requirements may be changed from time to time and are summarized within the Vendormate system.

OHI’s confidential Compliance Hotline is a simple, confidential and risk-free way for any person who represents OHI to report activities that may involve ethical violations, criminal conduct or violations of the Code of Conduct. Vendors should contact the confidential Compliance Hotline immediately to report any concerns. OHI prohibits retaliation against anyone who raises concerns in good faith. The confidential Compliance Hotline is available 24 hours a day, 365 days a year and callers may remain anonymous. If you wish to report a concern, please contact the confidential Compliance Hotline at (888) 464-6747, OrlandoHealth.EthicsPoint.com or BayfrontHealth.EthicsPoint.com.