Corporate Compliance

Corporate Compliance

Mission

Constellation Health Services was founded to be an innovative leader in the post-acute continuums by the development of core teams the embody clinical excellence, uniqueness within their communities and act with authentic intentions. We believe that service patients in the community setting is the most important activity of the organization. We are dedicated to providing the highest quality of patient care with compassion and respect for each person.

Values

Vision

Our vision is to help create a world where compassion, integrity and respect to others are the cornerstones of the communities in which we serve. We strive to support and environment of kindness, honesty, and well-being.

Values

At Constellation Health Services, we strive to create a compassionate environment filled with kindness and offering hope and encouragement to those we care for. We believe in a partnership of respect throughout the organization and with those we care for. Constellation Health Services holds itself accountable to regulatory and ethical standards and is committed to always acting in the best interests of our patients and their families.

Introduction

At Constellation HealthCare Services, we are dedicated to delivering exceptional care while strictly adhering to all healthcare regulations. Our Compliance Program is designed to support the company’s mission and core values by equipping our team to proactively prevent, identify, and address behaviors or issues that deviate from the Code of Conduct or applicable laws and regulations. It also helps the organization establish robust internal controls to ensure compliance with program guidelines, federal and state regulations, and to prevent misconduct, fraud, waste, and abuse in areas such as billing, coding, and claims submission.

We adhere to all federal and state laws, including the Health Insurance Portability and Accountability Act (HIPAA), to protect patient privacy and confidentiality. Additionally, we follow the Department of Health and Human Services (DHHS) Centers for Medicare & Medicaid Services (CMS) rules and guidelines, including those related to Medicare Shared Service Programs. Our Compliance Program aligns with the Federal Sentencing Guidelines and DHHS Office of Inspector General compliance standards associated with our business practices. To ensure continued compliance, we conduct annual and periodic evaluations of the program. Federal and state laws relevant to Constellation Health Services also shape the development of our internal compliance policies.

Every decision and action we take is grounded in our purpose, mission, and values. We are unwavering in our commitment to doing the right thing—always and without exception.

Elements of Constellation Health Services Compliance Program

Our compliance program was developed to ensure that our organization adheres to all relevant laws, regulations, and ethical standards as well as reducing the risk of misconduct. Our program aims to prevent, detect, and address any potential violations, ensuring that we operate with integrity and transparency.  According to the Office of the Inspector General (OIG), an effective compliance program should have a strong foundation and include the following seven elements.

Element 1: Written Policies and Procedures

Our Code of Conduct outlines the ethical standards and expectations that guide our behavior in all aspects of our work. It serves as a foundation for promoting integrity, accountability, and respect within our organization. All employees, vendors, contractors, partners and stakeholders are expected to act in a manner that upholds our core values, including compassion, integrity, and respect for others. The Code of Conduct emphasizes our compliance with laws, regulations, and company policies, ensuring a safe and inclusive environment for everyone. By adhering to these principles, we strive to foster trust, transparency, and excellence in every action and decision we make.

The Code of Conduct is the primary element of the Compliance Program as it provides the standards for employees, vendors, and others to follow. The Code is also a guide to appropriate workplace behavior; it helps everyone to make the right decisions in the context of risks relevant to our organization. The Code emphasizes:

The company develops and adopts written policies and procedures through the Corporate Compliance Committee to ensure alignment with the various regulations governing each business line. All covered individuals are expected to understand and comply with these policies, follow established procedures, and seek additional guidance when necessary to fulfill their responsibilities. Updates to policies and procedures are communicated through various channels, including electronic newsletters, web-based announcements, postings, and in-person educational sessions. Subject matter experts and management are responsible for integrating these policies and procedures into daily operations.

Service-line-specific, departmental, or function-based policies are created, reviewed, and updated by subject matter experts with specialized knowledge in their operational areas. These policies and procedures are accessible to all employees via the company’s internal communication platform. Actions that deviate from these policies and procedures are strictly prohibited.

Constellation Healthcare Services provides information to all covered individuals about federal and state fraud laws, including the False Claims Act, the remedies available, and whistleblower protections for reporting violations. Detailed information can be found in the Employee Handbook and related supplemental policies.

All employees and representatives of Constellation Health Services must conduct themselves in a manner that upholds the highest standards of ethics and integrity, adhering to the guidelines outlined in our Code of Conduct, as well as our policies and procedures, without exception.

Element 2: Compliance Leadership and Oversight

While compliance is a shared responsibility among all covered individuals, Constellation Health Services designates high-level personnel to oversee the administration, maintenance, and implementation of the Compliance Program. These roles and responsibilities are as follows:

Element 3: Training and Education

Constellation Health Services actively promotes its Compliance Program by publicizing its key elements, including standards, the Code of Conduct, HIPAA requirements, and high-risk policies and procedures. Covered individuals receive thorough training on the objectives of the Compliance Program, with management and the Compliance team closely monitoring training completion. A robust learning and development program equips team members with the knowledge needed to fulfill their responsibilities, and they are encouraged to ask questions about applying standards to their roles.

New employees must complete general orientation and compliance training within 30 days of hire, with annual refresher courses and ad hoc training as needed—such as in response to identified risks, legislative mandates, or changes in policies or the Compliance Program. As part of this training, employees acknowledge the Code of Conduct, report any actual or perceived conflicts of interest, and address any previously unreported or unresolved concerns. Failure to report such concerns may constitute a violation of the Code of Conduct. Reported issues are investigated following the Investigation of Non-Compliance process, and conflicts of interest are managed per relevant policies and procedures. Acknowledgements are electronically retained.

Constellation Health Services also ensures that contracted team members, Board members, vendors, and volunteers receive appropriate training or information to comply with the Code of Conduct and related regulatory requirements.

Element 4: Effective Lines of Communication with the Compliance Officer and Disclosure Program

Constellation Health Services is committed to identifying and addressing concerns related to compliance and regulatory standards. The “When In Doubt, Speak Out” initiative provides a comprehensive reporting process that encourages management and employees to collaboratively tackle issues such as fraud, waste, abuse, and workplace misconduct, fostering a positive and ethical work environment.

Employees and stakeholders can report concerns or seek guidance through multiple channels, including a confidential, toll-free hotline available 24/7. A strict non-retaliation policy ensures reporters can raise issues without fear of reprisal, retaliation, or punishment. Any act of retaliation against a reporter will result in disciplinary action.

All covered individuals share responsibility for upholding compliance with operational standards. They are required to promptly report any observed or suspected unethical, illegal, or unprofessional behavior, as well as clinical, ethical, financial, or Code of Conduct violations. Such issues must be reported to the Compliance Department for appropriate guidance and oversight. Failure to report suspected misconduct undermines the company’s integrity and may constitute a violation of the Code of Conduct.

The “When In Doubt, Speak Out” initiative underscores the importance of reporting concerns to maintain compliance and improve practices as needed. Team members are expected to use sound judgment and avoid baseless allegations. Any employee found to have intentionally filed a false report will face disciplinary action, up to and including termination.

Anyone can report a compliance concern:

Constellation Health Services acknowledges that an anonymous reporting mechanism is a vital component of an effective compliance program. While reports can be submitted anonymously, they must include sufficient detail to initiate the investigative process.

Element 5: Enforcing Standards: Consequences and Incentives

Enforcing standards in healthcare is essential to maintaining ethical, legal, and professional integrity while fostering a culture of accountability. Constellation Healthcare Services achieves this through a balance of consequences and incentives. Reasonable, effective, and efficient steps are taken to respond to any detected compliance issues, including those identified after confidential disclosure, monitoring or auditing. Non-compliance may result in disciplinary actions, ranging from warnings to termination, with thorough investigations ensuring appropriate resolutions. Failure to report unethical behavior is also addressed as a breach of the Code of Conduct. At the same time, incentives such as recognition, regular training, and a supportive environment encourage adherence to standards. By protecting whistleblowers from retaliation and rewarding ethical behavior, Constellation Healthcare Services upholds their commitment to quality care and organizational integrity.

Element 6: Risk Assessment, Auditing and Monitoring

Effective risk assessment, auditing, and monitoring are essential to ensuring compliance in our operations. These processes identify potential risks, promote adherence to regulatory standards, and support the delivery of high-quality care. Risk assessments proactively identify areas of vulnerability, while audits systematically review operations, billing, and clinical documentation to uncover inaccuracies or instances of non-compliance. Ongoing monitoring ensures corrective actions are effectively implemented and maintained. Together, these efforts create a strong framework for managing risks, improving efficiency, and building trust with patients and regulatory bodies.

Constellation Health Services has established comprehensive auditing and monitoring programs to evaluate internal controls and ensure compliance with all applicable laws, regulations, and standards. Guided by the Office of Inspector General’s identified areas of concern, our compliance department has developed targeted work plans and audit tools to assess and address risks specific to our business. Compliance professionals collaborate with other departments to achieve the goals and objectives outlined in each compliance work plan, fostering a culture of accountability and continuous improvement.

Element 7: Responding to Detected Offenses and Developing Corrective Action Initiatives

Responding to detected offenses and implementing corrective action plans are vital to maintaining compliance and improving operations in our business. When issues are identified, a thorough investigation is conducted to determine the root cause and scope of the problem. Based on findings, tailored corrective action plans are developed to address deficiencies, prevent recurrence, and ensure compliance with regulatory standards. These plans may include policy updates, staff retraining, process improvements, or disciplinary actions. By implementing swift and effective measures, Constellation Healthcare Services reaffirms its commitment to integrity, improves service quality, and strengthens trust with patients, families, and regulators.

Compliance Resources

Our compliance resources provide the tools and guidance needed to uphold ethical standards, adhere to regulations, and foster a culture of accountability across all aspects of our organization.

Industry Links:

Office of Inspector General, US Department of Health and Human Services: http://oig.hhs.gov

Centers for Medicare and Medicaid Services: http://www.cms.gov

Medicare Benefit Policy Manual- Chapter 7- Home Health Services: Medicare Benefit Policy Manual

Medicare Benefit Policy Manual- Chapter 9- Coverage of Hospice Services: Medicare Benefit Policy Manual

Code of Federal Regulations: eCFR :: 42 CFR 411.354 — Financial relationship, compensation, and ownership or investment interest.

Health Care Compliance Association: http://www.hcca-info.org

National Association for Home Care and Hospice: http://www.nahc.com

American Association for Homecare: http://www.aahomecare.org

American Academy of Hospice and Palliative Medicine: http://www.aahpm.org

National Hospice and Palliative Care Organization: http://www.nhpco.org

Corporate Compliance /
Non-Discrimination Statement

It is the policy of Constellation to fully comply with all federal and state laws governing fraud and abuse in healthcare programs and to expect all employees, contractors, and consultants to conduct themselves in an ethical and responsible manner.

This company does not discriminate on the basis of race, color, national origin, disability, past/present history of mental disorder, veteran status, or age in admission or access to treatment or employment in programs and activities as required by Title VI of the Civil Rights act of 1964, Section 504 of the Rehabilitation Act of 1973 and the Age Discrimination Act of 1975. Other agency guidelines prohibit discrimination on the basis of decisions regarding advanced directives, creed, religion, marital status, sex, sexual orientation, gender or any other category protected by law

For further details, or to make an anonymous compliance complaint, please call toll-free (888) 375-9366, send us a message through the form below, or email us directly at compliance@constellationhs.com.


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