Page 10 - Code-of-Conduct
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        that necessary to perform your duties.  physician’s immediate family member in
     •   You must adhere to the HIPAA rules at all    exchange for patient referrals
        times. If you have any questions about    If you have any questions about the laws listed
        how you may access, use, or disclose    in this section or any other rules affecting
        patient information you should contact    financial relationships with physicians, contact
        the Genesis Privacy Officer at    the Vice President of Legal Affairs.
        563-421-7262.
     •   See Permitted Uses and Disclosures of    ANTITRUST LAWS AND
        PHI for Treatment, Payment and Health    FAIR COMPETITION
        Care Operations policy.
     ANTI KICKBACK/                       Antitrust laws are designed to promote fair
                                          competition in the marketplace. At Genesis,
     SELF REFERRAL LAWS
                                          we believe that a healthy competitive
                                          marketplace is good for patients and
     PHYSICIAN RELATIONSHIPS              employees. Antitrust laws are designed to
     Do not enter into financial relationships with   encourage fair trade and competition in the
     physicians on behalf of Genesis that could   marketplace. We will not behave in a way
     violate state or federal laws such as the   that is anti-competitive or violates these laws.
     Anti-Kickback Statue or the physician   Consult with the Vice President of Legal Affairs
     self-referral law (the Stark Law).   when considering business decisions that
                                          could raise antitrust issues.
     For example, it is a violation of
     federal law and Genesis policy to:   Examples of conduct prohibited by
     •   provide free or significantly discounted    these laws include:
        billing, nursing or other staff services
     •   pay more than fair market value for goods   •   sharing strategic, marketing information
        or services                          or pricing of Genesis services with a
     •   provide or agree to provide any direct or    competing health care system or provider
        indirect compensation to a physician or a
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