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Code of Conduct




NYPCC is committed to conducting its activities in compliance with all federal, state and local laws and regulations and with the highest professional and ethical standards. This includes a commitment to promoting evidence-based services; effective patient engagement; and cost-effective, high quality, patient-centered care. All NYPCC Board and committee members, employees, contractors, and practitioners (hereinafter referred to as “Participants”) play an integral role in helping achieve these goals.    

This Code of Conduct has been adopted by the NYPCC Board of Directors in support of the NYPCC’s Compliance Program. The Code of Conduct describes the standards by which all Participants are expected to conduct themselves when working for or on behalf of NYPCC.  Participants are required to adhere to both the spirit and letter of the Code of Conduct.  In addition to the Code of Conduct, Participants are expected to follow all policies and procedures affecting their activities in NYPCC.    

Participants remain subject to the requirements of their own organization’s compliance programs and Code of Conduct, in addition to the requirements of NYPCC’s Compliance Program and this Code of Conduct.    

Standards of Conduct 

Honest and Lawful Conduct: NYPCC and Participants will abide by all applicable laws and regulations.  All Participants must maintain a high level of integrity and honesty in their conduct relating to the operations and performance of the NYPCC and will be held accountable for behaviors and actions inconsistent with this Code of Conduct.    

Quality of Care:  NYPCC treats all patients with respect and dignity, providing care that is both necessary and appropriate.  NYPCC is committed to providing high quality health care to its patients and to delivering health care services in an ethical, professional and effective manner.  NYPCC and Participants are committed to delivering people-centered, high quality health care services with compassion, dignity and respect for each individual.    

No Reduction in Medically Necessary Services: NYPCC and Participants are committed to improving health, enhancing quality of care, and lowering the costs of health care services. NYPCC and Participants will not deny, reduce or limit the provision of medically necessary services to any patient.   

No Discrimination: NYPCC prohibits any form of discrimination in the provision of services, marketing, or enrollment practices.  NYPCC and Participants will not deny, limit, or condition services to patients on the basis of race, color, religion, gender, sexual orientation, marital status, national origin, citizenship, age, disability, or any other characteristic protected by law or any factor that is related to health status, such as nature and extent of medical condition, medical history, or genetic information. NYPCC prohibits any practice that would reasonably be expected to have the effect of denying or discouraging the provision of medically necessary services to eligible individuals.   

Licensure: All individuals and entities providing care to NYPCC patients will be properly licensed or permitted in New York State or designated or approved by the Office to provide services and possess the necessary experience and expertise to deliver high quality, effective care. Only qualified Participants will be permitted to make clinical assessments or to develop plans of treatment for patients.  Participants will confirm licensure of all employees, agents and contractors rendering services to NYPCC patients. Complying with licensure requirements is an important component of NYPCC’s commitment to ensuring that patients receive high quality, effective care. 

Gifts to Medicare Beneficiaries: Participants are prohibited from offering or providing gifts or remuneration to Medicare beneficiaries, either individually or on behalf of NYPCC, as inducements for receiving services or remaining in NYPCC or with a particular provider within NYPCC.  Limited in-kind items or services may be provided by NYPCC to Medicare beneficiaries for free or below fair market value provided they are either 1) preventative care in nature; or 2) advance the clinical goals of the Medicare beneficiary.  Limited in-kind items or services will not be provided directly by physicians or practices to Medicare beneficiaries except as part of a program approved by the Board of Directors.    

Eligibility to Participate in Federal and State Health Care Programs: NYPCC and Participants will not knowingly hire, employ, contract, or do business with any individual or entity excluded, debarred, or otherwise ineligible to participate in federal or state health care programs such as Medicare and Medicaid, or whose officers, directors or employees are excluded from participating in federal or state health care programs.  Participants are responsible for taking all necessary steps to ensure employees involved in providing goods or services to NYPCC, directly or indirectly, remain eligible to participate in federal and state health care programs.  

Documentation, Coding and Billing:  All Participants will adhere to federal and state laws and regulations governing billing, coding and documentation requirements for medical services billed to Medicare, Medicaid and other payers.  All billing, coding and documentation must be accurate and truthful. Only medically necessary services that are consistent with accepted standards of medical care may be billed.  Billing and coding are to be based on adequate documentation of the medical justification for the service provided and for the claim submitted, and medical documentation must comply with applicable payer requirements. Only codes that correspond to the service rendered and documented are to be used.  

Mandatory Reporting: NYPCC will ensure that all incidents that are required to be reported under applicable federal and state mandatory reporting laws, rules and regulations are reported timely. This includes, but is not limited to, the reporting of probable violations of law to an appropriate law enforcement agency and the disclosure and repayment of identified overpayments from Medicare or other third-party payers as required by law.  

Accuracy and Integrity of Records: NYPCC and Participants shall maintain accurate and complete records relating to all business activities, claim submissions, arrangements or transactions.    

Privacy and Security of Patient Information: Federal and state laws require NYPCC and Participants to maintain the privacy and security of patient health information (“PHI”) in all forms – paper, electronic records, films and images, and verbal discussions. All Participants will keep PHI confidential, except when disclosure is authorized by the patient or permitted by law. Personnel:   

  • Will not access or use PHI except as necessary to perform their jobs.  
  • Will access, use and disclose only the minimum amount of PHI necessary to perform their jobs.   
  • Will not discuss PHI with others who do not have a job-related need to know such information, including co-workers, family and friends.  
  • Will not leave PHI unattended, unsecured or otherwise available to the public.  
  • Will not store PHI on laptops, tablets, storage media or other portable devices unless authorized and approved for use by NYPCC or their employer organization.  
  • Immediately notify their supervisor or their organization’s Privacy Official if PHI has been lost, stolen or accessed inappropriately.  

Cooperation with NYPCC Compliance Program: All Participants will cooperate with and support NYPCC’s Integrity and Compliance Program through adherence to the standards described herein and participation in activities such as:  

  • Periodic internal audits, including allowing NYPCC staff or agents to conduct audits of Participants’ medical records documentation, quality data collection, and claims submission.  
  • Compliance and other training of Participants as required by CMS regulations, including distribution of compliance communication and training materials such as this Code of Conduct.  
  • Implementation of procedures to ensure the accurate collection, submission or transmission of quality data, as required.   
  • Responding to compliance audits, investigations, reviews and inquiries, and implementation of corrective actions, as needed.    

Compliance with Fraud and Abuse Laws: Federal and state laws prohibit the exchange of anything of value in order to induce or reward patient referrals for business payable by a federal or state health care program, except as permitted by law. In accordance with these laws, NYPCC and Participants will not offer, solicit, pay or receive anything of value, directly or indirectly, for referring a patient or furnishing or arranging for a good or service payable by a federal, state or other third-party payer.  All referral decisions will be based solely on the health care needs of NYPCC patients.   

Conflicts of Interest: A conflict of interest exists whenever an individual’s outside personal or financial interests influence, or appears to influence, decisions made involving NYPCC.   Participants are expected to exercise good judgment, maintain objective business relationships with external parties conducting business with NYPCC, and avoid conflicts of interest.  NYPCC decisions are to be made fairly and objectively, without favor or preference based on personal considerations. Participants may not use their positions or knowledge gained through their relationship with NYPCC for personal advantage.   Personnel may occasionally find their duties to NYPCC in conflict, or may appear to be in conflict, with other relationships and responsibilities. Such matters should be disclosed to the individual’s supervisor, a higher-level manager or NYPCC’s Compliance Officer to ensure appropriate actions are taken to manage any conflicts of interest.   

Reporting Requirement: NYPCC promotes an environment that encourages all Participants to seek answers to questions and report issues and concerns. Participants are expected to report, in good faith, any actual or suspected fraud, waste, and abuse, violations of law, regulation, professional standards or NYPCC policies.  Participants may choose one or more of the following methods for reporting:  

  • Participant Organization Management:  Participants are encouraged, but not required, to report compliance matters directly to their direct supervisor, to other management of their organization, or to their own organization’s compliance officer.  
  • NYPCC Compliance Officer:  Participants may at any time report compliance matters directly to NYPCC’s Compliance Officer as follows:  
  • Jonathan Keigher, Compliance Officer  
  • NYPCC Compliance, 176-20 148th Avenue, Jamaica NY 11434   
  • 718-553-1100 or   
  • Compliance Hotline:  NYPCC has established a Compliance Hotline that is available to all Participants to confidentially report any issues or concerns or to seek advice or clarification on compliance and other issues. You have the option to remain anonymous when reporting if you so choose. The Compliance Hotline is available 24 hours a day, 365 days a year. You may file a report via telephone at 718-244-0413.  

No Retaliation: NYPCC prohibits retaliation, in any form, against any individual reporting issues and concerns in good faith. Retaliation is subject to discipline up to, and including, termination of employment, or termination of participation in or business relationships with NYPCC.  NYPCC will attempt to maintain, within limits of the law, the confidentiality and identity of individuals reporting issues and concerns.    

Investigation of Alleged Fraud, Waste and Abuse:  NYPCC will promptly investigate any reports of alleged violations of law, regulations or policies related to NYPCC activities. Participants are expected to fully cooperate in such investigations and, where appropriate, in taking corrective actions in response to matters identified, as needed. The Federal False Claims Act and similar state laws make it a crime to present a false claim to the government for payment. These laws also protect “whistleblowers” (people who report noncompliance or fraud, or who assist in investigations) from retaliation. NYPCC strictly prohibits retaliation or reprisal against individuals exercising their rights under the Federal False Claims Act or similar state laws.  

Lines of communication to the compliance officer are made available to all recipients of service: 

  • Compliance Officer: Jonathan Keigher 
  • Compliance fax: 718-553-1111 (not anonymous)
  • Compliance hotline: 718-244-0413 (anonymous)
  • Compliance email: (not anonymous)
  • Compliance mailing address: NYPCC Compliance, 176-20 148th Avenue, Jamaica NY 11434 (anonymous if leave off return address)