Code of Conduct

This Executive Summary outlines the commitments in our Code of Conduct (Code). The Code of Conduct applies organization-wide to all employed and non-employed team members (collectively referred to as Care Team Members) including providers, contractors, consultants, agents, students, volunteers and suppliers.

Commitment to Integrity

We pledge to serve those who depend on Carter Nursing and Rehabilitation’s services. We promise to honor this commitment with integrity through quality care, service excellence, responsible stewardship, and respectful teamwork. We acknowledge that it isn’t always easy to do the right thing. If we are unsure of the right thing to do, we ask for help. We raise concerns and we evaluate through a fair and just culture. We do not allow retaliation against anyone seeking help or raising concerns in good faith.

Commitment to Quality

We provide our residents and patients with excellent care and services necessary to experience the highest physical, mental, and psychological well-being they individually can achieve. Our teamwork and dedication to this principle create the highest quality of care.

Commitment to Resident and Patient Rights

We are devoted to the preservation of dignity, self-respect and resident and patient rights in a loving and caring environment. It is Carter Nursing and Rehabilitations policy that all residents and patients in its nursing facilities, Home Health Agencies, and Hospice have, among other rights, the right to a dignified existence, self-determination, and communication with, and access to people and services both inside and outside the facility. We are committed to ensuring that each resident and patient is aware of his or her rights.

Commitment to Safeguarding the Resident and Patient Privacy

It is our duty and legal obligation to safeguard our residents’ and patients’ Protected Health Information (PHI) to prevent inappropriate access, use and disclosure. We will follow all laws, rules and regulations related to resident and patient privacy, we only access and use PHI needed to do our jobs or when required by law or regulation.

Commitment to Gifts, Entertainment, or Business Courtesies

We avoid real or perceived conflicts related to gifts, entertainment, or business courtesies. We will never offer or accept such courtesies if the intent is to influence objective business decision-making or in exchange for any referrals to the Carter Nursing and Rehabilitation facility.

Commitment to Diversity, Equality, and Harassment Free Workplace

Carter Nursing and Rehabilitation brings together a workforce with various skills, perspectives, experiences, and other personality characteristics. This diversity of talent creates strong teams that consistently deliver the best quality care. We respect Care Team Members, job applicants, and Care Partners (Third Party Partners) judging them only on their qualifications, skills and achievements. We will serve everyone in our communities, without regard to race, color, sex, national origin, handicap/disability, age, HIV status, marital status, sexual orientation, gender identity, gender expression, religious beliefs, sources of payment for care or other protected status or category. We work to create environments free of harassment, violence and intolerance.

Commitment to Personal Privacy

We are dedicated to protecting the private information of our Care Team Members, Care Partners, and others outside of Carter Nursing and Rehabilitation. We will protect this information by accessing, using and disclosing only when necessary to do our jobs.

Commitment to Safety, Health and Environment

We provide a safe and healthy work environment for Care Team Members, Care Partners, and visitors to our facilities. We promote a positive work environment for everyone. We act in safe and healthy ways and do our jobs with clear minds. Each of us is responsible for acting in a way that protects the health and safety of our Care Team Members, our residents and patients, and others in the workplace. We also have a responsibility to protect and preserve the natural environment.

Commitment to Billing for Services

We strive to ensure and maintain complete and accurate documentation of medical services provided. We comply with all payor rules and prepare accurate, properly coded billing statements that reflect only medically necessary and billable services provided and documented in the medical record. We report and return any overpayment once identified from a government health care program, commercial payor, resident or patient.

Commitment to Conflicts of Interest

To best serve those in our care, we set aside our own interests when they conflict with those of Carter Nursing and Rehabilitation, our residents and patients. We will not divide our loyalties or use our position for our own benefit or for that of our families and friends.

Commitment to Protecting Company Resources

We use Carter Nursing and Rehabilitation resources wisely and for appropriate purposes. Each of us is personally responsible for protecting our resources. These resources include our Care Team Members, facilities, funding, information technology, equipment, intellectual property, confidential information, and medical supplies. We share or allow others access to these resources only for legitimate business purposes and with proper authorization. We are careful to secure confidential information.

Commitment to Creating and Managing Our Business Records

We commit to the accuracy and completeness of our business records and disclosures. Every Care Team Member is responsible for maintaining truthful and complete records of all types, including patient records, work records, financial records, and all other organizational documents in a way that is consistent with our policies.

Commitment to Antitrust and Fair Competition

We are committed to avoiding practices that limit free and open competition. We never seek to gain competitive advantages through unethical or illegal means, but rather through excellent care and services.

Commitment to Business Relationships

Our Care Partners, suppliers, vendors, and competitors play an important part in the success of our business. Third party partners (Care Partners) provide Carter Nursing and Rehabilitation with critical services and goods that further our mission. Competitors motivate us to find new and better ways to deliver quality care and serve others. We value these third parties and treat them fairly, honestly and ethically.

Commitment to Communicating with the Public

Carter Nursing and Rehabilitation must speak with one voice when communicating to the public about disclosures, announcements, or other information. This helps us deliver messages that are objective, transparent and consistent. We communicate professionally and honestly with the public according to the highest standards of integrity. Our social media posts and internet communications reflect good judgment and personal responsibility.

Our Commitment to Health Care Laws and Regulations

Carter Nursing and Rehabilitation operates in a highly regulated industry governed by laws and regulations that can be lengthy and complicated. We understand that compliance with these rules is critical to Carter Nursing and Rehabilitation’s success. We are committed to upholding all the legal standards that apply to our jobs and Carter Nursing and Rehabilitation.

Commitment to Licensure

We ensure all applicable Care Team Members (employed and contracted) are properly licensed and follow the laws and regulations governing their respective professions.

Commitment to Regulated Pharmaceuticals

We are conscientious and vigilant in carrying out our obligations to handle and dispense prescription drugs and controlled substances at Carter Nursing and Rehabilitation in accordance with all applicable laws, regulations, and Carter Nursing and Rehabilitation’s procedures.

Commitment to Political Activities and Supporting our Communities

Carter Nursing and Rehabilitation supports and encourages voluntary participation of Care Team Members in the political process, on your own behalf. No Care Team Member should ever engage in lobbying, without prior authorization from the Chief Executive Officer. While we each are encouraged to be active in our community by supporting events and causes, we avoid pressuring others to contribute to our favorite charities.

Commitment to Our Compliance & Ethics Program

Carter Nursing and Rehabilitation is committed to conducting its business ethically and compliantly. This includes preventing and detecting fraud, waste and abuse and complying with all state and federal laws that apply to our jobs and our business to deliver quality care to our residents and patients. Carter Nursing and Rehabilitation designed and implemented a Compliance & Ethics Program to promote and support ethical and legal conduct and a culture of integrity through accountability to a system of compliance and ethics standards.

How Can I Report a Concern?

You can report a concern in several ways. Our hotline is available 24 hours a day, seven days a week. An outside company receives these calls and online submissions. The Office of Corporate Compliance & Ethics receives the report and reviews it for follow-up or investigation. All contacts are confidential, to the limit allowed by law. If you prefer, you can make an anonymous report. Providing as much information as possible will help us review the validity of the report and investigate any potential misconduct.

Your Supervisor

Your supervisor (or Care Team Leader) can answer your questions and help decide the best course of action in most situations – or connect you to other Carter Nursing and Rehabilitation Resources that can.

Another Supervisor in Your Chain of Command

For issues involving your supervisor or if you are uncomfortable speaking directly to them, speak to another supervisor in your reporting chain or another leader with whom you feel most comfortable.

Information Technology Customer Support Center

For suspected violations of Carter Nursing and Rehabilitation’s network or computer systems, call the Customer Support Center.

Human Resources Department

For a human resources or general workplace issue that you are unable to resolve with your supervisor, contact your facility human resources manager, division human resources director, or the corporate Human Resources Department.

Legal and Risk Services Department

For any legal issues that arise such as contacts by law enforcement, notice of investigations, or receipt of subpoenas, contact the Legal and Risk Services department.

Corporate Compliance & Privacy Officer

If you have a question or concern about an actual or suspected HIPPA Privacy issue, please contact Carter Nursing and Rehabilitation’s Corporate Compliance & Privacy Officer at 317-759-8523 or compliance@bluegrasscg.com.

Corporate Compliance & Ethics Department

Questions or concerns also may be reported directly to the Compliance Department in one of the following ways:

Contact the confidential disclosure system:

• Call the toll-free hotline (without caller ID) at 1-833-230-0006
• Use the internet: www.lighthouse-services.com/carternr
• Lighthouse is available 24/7/365 and managed by a third-party vendor.
• If you choose to submit an anonymous report to Lighthouse, a six-digit case number will be provided so you may later submit more information related to your original report. This also allows the Office of Corporate Compliance & Ethics to communicate with you (e.g., ask questions) and still protect your anonymity. No one at Carter Nursing and Rehabilitation has access to your case number.
• You may also submit a report including your name but request anonymity. If you do so, your anonymity will be protected up to the limits of the law.
• Translation services are available for both written and verbal reports.

Email: compliance@bluegrasscg.com

Mail a written description of the matter: Corporate Compliance & Privacy Officer | 777 E. Main St. Westfield, IN 46074

A Final Message

A message from our Corporate Compliance & Privacy Officer:
Thank you for reading our Code. We have designed it to outline what is expected from all of us, and as a useful resource when you have questions or are unsure what to do in a difficult or questionable situation.

Remember, however, that you do not have to tackle problems on your own. All the resources listed in the Code are ready to help when you need them. Please feel free to contact the Office of Corporate Compliance & Ethics if you have any questions or concerns. Our residents and patients count on us to always do the right thing and give them excellent quality care. Their trust in us reinforces our continuing commitment to serve.

Angela Rewa, Corporate Compliance & Privacy Officer