L.A. Care Health Plan Vendor Code of Conduct

L.A. Care Health Plan (L.A. Care) is firmly committed to comply with its legal and ethical obligations under all state and federal laws, as well as its obligations with its state and federal contracts and grants. L.A. Care requires its vendors to operate in accordance with the principles in this L.A. Care Vendor Code of Conduct ("Code") and in full compliance with all applicable laws and regulations. This Code applies to L.A. Care vendors and business associates, and their subsidiaries, affiliates and subcontractors (each a "Vendor") providing goods or services to L.A. Care.

L.A. Care will assess its Vendors' compliance with this Code, and any violations of this Code may jeopardize a Vendor's business relationship with L.A. Care, up to and including termination.

I. Compliance with Laws and Regulations

Anti-discrimination/Anti-Harassment

Vendor shall not unlawfully discriminate or engage in unlawful harassment against any worker based on any protected categories, including without limitation age, disability, ethnicity, gender, marital status, national origin, race, religion, sexual orientation in hiring and other employment practices.

Wages and Benefits

Vendor shall ensure that all workers receive at least the legally mandated minimum wages and benefits, as required by law. Vendor shall communicate pay structure and pay periods to all workers, to the extent required by law. Vendor shall pay accurate wages in a timely manner, and wage deductions shall not be used as a disciplinary measure.

Health and Safety

Worker health, safety, and well-being is important to L.A. Care. Vendor shall provide and maintain a safe work environment and integrate sound health and safety management practices into its business. Workers shall have the right to refuse unsafe work and to report unhealthy working conditions.

Occupational Health, Safety, and Hazard Prevention

Vendor shall identify, evaluate, and manage occupational health and safety hazards through a prioritized process of hazard elimination, engineering controls, and/or administrative controls. Vendor shall provide workers with job-related, appropriately maintained personal protective equipment and instruction on its proper use.

False Claims Act

L.A. Care provides services to the federal and state of California governments. The Federal False Claims Act and similar state laws make it a crime to present a false or fraudulent claim to the government for payment. Vendor shall comply with all requirements of the Federal False Claims Act and similar state laws in its billing practices to L.A. Care.

II. Ethics

L.A. Care expects the highest standards of ethical conduct in all of our endeavors. Vendor shall always be ethical in every aspect of its business, including relationships, practices, sourcing, and operations.

Business Integrity, Gifts and Courtesies

Vendor shall not engage in corruption, extortion, embezzlement, or bribery to obtain an unfair or improper advantage. Vendors shall not offer or provide gifts, meals, entertainment, or other business courtesies to L.A. Care employees. L.A. Care discourages its vendors from providing gifts, meals, entertainment, or other business courtesies to its employees. L.A. Care is a public entity and required to comply with applicable rules relating to conflicts of interest, honoraria and acceptance of gifts.

Conflicts of Interest

Vendor shall comply with all applicable federal, state, and local laws and regulations pertaining to conflict of interest laws, including without limitation L.A. Care's Conflict of Interest Code, the California Political Reform Act (Government Code Section 81000 et seq.) and Government Code Section 1090 et seq. (collectively, the "Conflict of Interest Laws"). Where applicable, Vendor shall comply with requirements for filing of Statement of Economic Interests (Form 700).

Exclusion from government programs

L.A. Care will not do business with any Vendor if it or any of its officers, directors or employees are, or becomes excluded by, debarred from, or ineligible to participate in any Federal or State program, whether as a contractor or grantee, or is convicted of a criminal offense in relation to the provision of health care. Vendors must disclose to L.A. Care if they are currently suspended, debarred or otherwise ineligible to participate in any Federal or State program, including Medicare or Medi-Cal.

III. Business Practices

Protection of Property & Confidential or Proprietary Information

Vendor shall protect L.A. Care's confidential or proprietary information, including member information, from improper disclosure and shall not use confidential or proprietary information for its own benefit or the benefit of any other person or entity. Vendor shall protect L.A. Care property, physical assets, and proprietary information provided to Vendor from loss, theft, destruction, misappropriation and misuse.

Fraud, Waste and Abuse

Vendor shall investigate and take corrective action in response to suspected Fraud, Waste or Abuse incidents perpetrated by employees, contractors/subcontractors and agents, and report to L.A. Care, as well as State and Federal regulatory agencies as applicable.

Documentation and Records

Vendor shall keep fair and accurate financial records in accordance with all federal and state laws and regulations. Vendor shall have processes to identify, understand, and implement applicable laws and regulations and requirements and shall maintain documents and records to ensure regulatory compliance. Vendor shall not alter its records for any improper use, including unauthorized payment.

Required Licenses, Credentials or Certifications

Vendor shall obtain and maintain valid licenses, credentials, certifications or registrations required in order to furnish goods or services to L.A. Care.

Corrective Action Process

Vendor shall have a process for timely correction of any deficiencies or violations identified by an internal or external audit, assessment, inspection, investigation, or review.

IV. Reporting Potential Violations, Non-retaliation

Non-retaliation Policy

Vendor shall not retaliate against any employee who reports or participates in the investigation of incidents of non-compliance with applicable laws, regulations, policies and other compliance issues, if such reports are made in good faith.

Reporting Violations of this Code

If any Vendor becomes aware of any violation of this Code, including fraud, waste, abuse, or any violation of a legal or ethical obligation, the Vendor must report the matter immediately so it can be investigated. L.A. Care holds all entities doing business with L.A. Care responsible for carrying out and monitoring compliance with this commitment.

Reports may be submitted by telephone to:

Phone:
Toll Free Compliance Hot Line 1-800-400-4889

L.A. Care will take all necessary steps to investigate any potential violations of our policy and will take appropriate action to correct any violations or incorrect perceptions that are found to exist.