We Rely on our Code

One of my direct reports spoke with me about an ethical dilemma he is facing. I want to be certain I’m giving him the right guidance. If I’m not sure how to respond, what should I do?

Our Code is always a good place to start. If you cannot find the answer in our Code, ask your manager for advice, but be careful to protect the confidentiality of your direct report. If you are still unsure, contact any of the resources listed in the Code.

I know that our Code contains general guidelines for what to do, and what not to do. Do I have to consider anything else when deciding what to do?

You’re right . . . our Code provides general guidelines for how we conduct business. We also have Company policies, many of which are referenced and linked in our Code. And then there are additional legal requirements, which may change from time to time as laws and regulations get adopted or amended. If you’re unsure of what to do, ask your manager or any of the other compliance resources listed in our Code. Refer to Speak Up for more information.

As a manager, how can I promote ethical behavior?

First and foremost, lead by example. Include discussions about workplace ethics in team meetings. Allow team members to feel comfortable asking questions when they have concerns. Remind team members they will not be retaliated against for reporting information in good faith. Additionally, ensure all your decisions are made with the best interests of the Company in mind.

I have a concern, but it is not covered in our Code of Conduct. Does that mean there is no problem?

No. Our Code cannot possibly address every situation or ethical dilemma. However, our Values and other guidance discussed in our Code, including the ethical decision-making model, can help you make the right decision. We are all expected to use sound judgment and act ethically in the absence of a Company policy. Seek guidance from your manager or any of the Speak Up resources identified in our Code whenever you are unsure about a particular situation.

What should I do if my manager directs me to engage in conduct that would benefit Change Healthcare, but would violate our Code?

None of us should commit dishonest, unethical or illegal acts, even if directed to do so by a manager. In addition, never violate our Code, even if it would appear to benefit Change Healthcare. You should contact the Office of Compliance and Ethics.

I hear from coworkers that our manager typically does nothing when concerns about potential misconduct are brought to his attention. I am aware of some potential unethical behavior by a team member. What should I do?

Change Healthcare managers have the additional responsibility under our Code to lead with integrity. This means, in part, that managers must foster an inclusive environment, encourage team members to raise issues, listen and respond to team members’ concerns, and ensure that team members are not retaliated against when they do speak up. You should discuss your manager’s apparent lack of response to ethical concerns to Human Resources, Employee Relations or another Speak Up resource identified in our Code.

We Speak Up

What if I just want to be sure I understand our Code? If it is not misconduct, should I still use Change Healthcare’s EthicsLine?

To ask about the meaning of our Code, please contact any of the following:

  • Your manager
  • Another manager
  • Human Resources
  • Office of Compliance and Ethics
  • Legal

If you need to report potential misconduct, you can use any of the resources noted above or you can report the matter through ChangeHealthcareEthicsLine.com.

I know about a violation of one of our policies, but am afraid to report it. What if I make a report? How will I be protected?

We take measures with each report to help protect the reporting person. These measures include:

  • We remind those involved of our non-retaliation policy;
  • We continue to monitor the issue; and
  • We take corrective actions if retaliation occurs.

You should always report anything that seems like retaliation so the Company can take corrective actions.

What happens when I contact the EthicsLine?

Calls to the Change Healthcare EthicsLine are answered by an independent third party with expertise in handling ethics line calls. A specialist will ask you questions and send a report to our Office of Compliance and Ethics for a confidential review. The report will be assigned to Legal and/or HR as necessary for review and appropriate follow-up.

Do I have to identify myself if I use the Change Healthcare EthicsLine?

It is essential that you feel secure when raising questions or reporting potential violations of our Code, our policies or legal requirements. Confidentiality is a priority and every effort will be made to protect your identity if known. However, in some instances, our need to perform a thorough investigation or because of legal requirements, it may not be possible to maintain your confidentiality. While we encourage you to provide as much detail as possible when using the Change Healthcare EthicsLine, where allowed by local law, you may choose to remain anonymous and not to identify yourself when reporting a concern, including a concern regarding questionable accounting or auditing matters.

What does it mean to make a report in good faith?

Acting in “good faith” means a genuine effort to provide honest, complete, and accurate information about a situation that you believe may violate our Code, our policies or legal requirements. Even if you only suspect that misconduct has occurred, you should speak up. You will still be protected from retaliation even if it turns out that you were mistaken so long as the report was made honestly and in good faith. An example of a report that is “not made in good faith” is if you make untrue statements to cause trouble for someone you do not like. Anyone who knowingly makes a false report of misconduct will be subject to disciplinary action.

I am a contractor working at Change Healthcare and I have a concern to report. Can I use the Change Healthcare EthicsLine?

Yes, the Change Healthcare EthicsLine can be used by all team members, including contractors and consultants. The Ethics Line is also available to all Change Healthcare agents, business partners, suppliers and vendors.

We Respect All

What if a team member made offensive jokes at an offsite dinner with a customer? Does our Code apply?

Yes. Our Code applies to our work wherever we are. That includes what we do on Change Healthcare property and at off-site meetings, business travel, and business-related social activities.

I overheard a team member threaten another, who is afraid to report the incident. What should I do?

Immediately report the incident to your manager, Human Resources, Employee Relations or any other Speak Up resource identified in our Code. We all have a responsibility to act if we see or suspect a threat of violence in our workplace.

My manager often makes inappropriate comments about a colleague’s disability. She then covers it up by saying, “I’m only kidding.” Is that ok?

No. These actions are not acceptable. Your manager needs to understand her comments are not appropriate. If you are comfortable doing so, say something directly to your manager. Whether you talk to your manager or not, you should report the situation to Human Resources, Employee Relations or any of the other Speak Up resources identified in our Code.

I noticed something in my facility that could be a safety problem, but it really isn’t my area. Should I report it?

Yes, report it. We all are responsible for maintaining a safe work environment. You should notify your manager, Human Resources or Employee Relations immediately.

In a recent meeting, a supplier began reading jokes from his cell-phone that degraded a certain religious group. I found the jokes offensive, but everyone else was laughing. Am I being too sensitive?

No, you are not being too sensitive. The Company does not tolerate this kind of disrespectful conduct from Change Healthcare team members or any Change Healthcare business partner, including our suppliers. You should report the incident using one of the Speak Up resources identified in our Code.

A co-worker makes seemingly innocent and complementary comments about the appearance of another team member. Is this appropriate?

Frequent comments may rise to the level of creating a hostile work environment. An occasional general comment such as “I like your new haircut” is probably acceptable. It depends on the specific nature of the comments, their frequency and the overall environment. If in doubt about the appropriateness of a comment, do not make it. Inappropriate comments should be reported to your manager, Human Resources, Employee Relations or through the Change Healthcare EthicsLine.

We Respect Private, Sensitive and Confidential Information

I work in HR and was recently contacted by a marketing company requesting the home addresses of all of our team members so they can send out some valuable information about a new medical clinic. What if our team members really would benefit from this information? May I provide the addresses to the marketing company?

No, our team members’ home addresses are private information and should only be disclosed for legitimate business and employment reasons, or if required by legal requirements. In this case, marketing a service to employees is not an acceptable reason for revealing this private information.

A colleague asked me to share customer information from my former employer. Should I?

No. You must not disclose the information. The customer information of your former employer is your former employer’s confidential information and you have an obligation to protect the information, even after leaving that company. If you were to share the information, you would be violating our Code of Conduct, as well as obligations to your former employer. Remember, you will have an obligation to protect Change Healthcare’s proprietary and confidential information, too, should you leave the Company.

I emailed the wrong report to a customer. The report contained another customer’s confidential information. I asked the customer to delete the email, should I do anything else?

Yes, you should seek guidance from your manager and Business Unit Compliance Lead and submit a report through the ChangeHealthcareEthicsLine.com.

One of our vendors that handles personal information on our behalf mentioned they had a security problem with one of their data systems that store and process personal information. What should I do?

You should report this to the Change Healthcare EthicsLine immediately. The Company will assess whether there may have been a security breach involving personal information and determine an appropriate response based on this assessment. When engaging a vendor to manage private, sensitive or confidential information on behalf of the Company, you must ensure the vendor signs an appropriate contract and has sufficient privacy, data security, and other relevant policies and procedures in place to protect the information.

We Avoid Conflicts of Interest

What if one of my relatives or a close personal friend works for a Change Healthcare customer? Do I need to notify someone about this relationship?

Even if you do not work directly with your family member or friend, any situation which creates even the appearance of a conflict of interest should be disclosed. If your job responsibilities have the potential of intersecting with a relative’s or friend’s job, you should disclose this relationship by sending an email to the Change Healthcare Office of Compliance and Ethics.

What if I want to work on evenings or weekends as a consultant for another company? Is this permitted?

Possibly. It would be a conflict if you work for a competitor or if you use Change Healthcare-related information or assets in your work for the other company. It can also be a conflict if your outside business activity negatively impacts your job performance. You should disclose the outside business activity by sending an email to the Change Healthcare Office of Compliance and Ethics.

What if I own stock in a publicly traded company that provides products to Change Healthcare? Is this investment a conflict of interest?

If the investment is small, it should not be a problem. Generally, an investment in a publicly traded company that is a Change Healthcare customer, business partner, contractor, consultant, supplier, vendor or competitor should not exceed 5% of your net worth or 5% of the ownership of the other company, unless the holding is through a mutual fund or other investment vehicle you do not direct or influence. If you have an interest in a customer, business partner, contractor, consultant, supplier, vendor or competitor that you interact with as part of your Change Healthcare duties, or an interest that exceeds the thresholds noted above, you should disclose the situation by sending an email to the Change Healthcare Office of Compliance and Ethics.

What happens after I disclose a potential conflict of interest?

The Office of Compliance and Ethics will review the potential conflict. When necessary, it will request additional information to determine whether a conflict exists. In some instances, you and your manager may need to sign a letter that outlines how you and Change Healthcare will manage the conflict.

For any other information or concerns, contact your manager, Business Unit Compliance Lead or Office of Compliance and Ethics for assistance.

How do I know if an offer of entertainment from a supplier is appropriate? I did not solicit the invitation, which I know is not acceptable.

You may accept infrequent and occasional meals and entertainment if the supplier attends and the costs are modest. Ordinary business meals and attendance at local sporting events are generally acceptable. An invitation to an out of town or a premium event is not acceptable. Even a modest meal or entertainment event could create an appearance of a conflict of interest if there is a pending bid process or procurement decision. You should review the Criteria for Appropriate Business Courtesies in the the Change Healthcare Gifts and Entertainment Policy and consult with your manager or Business Unit Compliance Lead before making a final decision. It is always preferable to pay the fair market value of a meal or a ticket to an event to avoid any potential appearance of a conflict of interest.

We Give and Receive Appropriately

What should I do if I receive a gift that is not allowed under our Gifts and Entertainment Policy?

If you receive a gift that exceeds Change Healthcare policy, the best course of action is simply not to accept the gift or return it with a note of appreciation and an explanation of our policy. If for some reason the gift cannot be returned, turn it in to your manager or Human Resources for donation.

I was invited to a conference sponsored by a supplier. The supplier offered to pay for my travel expenses, including airfare, meals, and accommodations. Can I accept this offer?

The Change Healthcare Gifts and Entertainment Policy does not allow you to accept the supplier’s offer to pay your travel expenses. If your attendance at the conference is approved by management, the Company will pay your travel expenses. You may, however, accept the costs of any registration fee and any meals provided by the conference sponsor. Team members invited to be a guest speaker or presenter at a sponsored conference or trade show may accept travel, lodging and meal expenses from the sponsor provided advance manager approval is obtained.

I received a gift from a customer, but I am unsure of its value. How do I know if I can accept the gift?

The Change Healthcare Gifts and Entertainment Policy contains Criteria for Acceptable Business Courtesies (“Criteria”). Team members can offer or accept business courtesies only when the Criteria are met and there is no sense of obligation or appearance of impropriety. The Criteria require the value of a business courtesy to be nominal, it cannot be excessive or lavish. You should use your best judgment to determine whether the value of the gift is nominal, and whether the gift complies with the other Criteria requirements as well. If you have any questions, please consult with your manager, your Business Unit Compliance Lead, the Office of Compliance and Ethics or Legal for further guidance.

We Use our Assets Wisely

I am running for the local school board. I want to use the office copier to make copies of my campaign flyer. Is thisOK?

No, the use of company assets for such personal purposes is not allowed.

I talk about my life and my work on my Facebook page. Should I be concerned about what I say about my job?

Yes. You are personally responsible for the content you publish online, and your posts are not private. Protect information about Change Healthcare and the people and companies with which we conduct business. You should not post information or make any comment(s) that would reflect poorly on a team member, the Company, its customers, business partners, contractors, consultants, suppliers, or vendors.

I often see incorrect information about Change Healthcare or our products or services on social media platforms. Can I respond by posting information that corrects these inaccuracies?

No. Even if you have good intentions, do not post corrections. Only authorized Change Healthcare team members can post or correct information about the Company on social media. Please notify your manager that you observed the incorrect information.

My family and friends email me at work. These are personal messages. Can I expect them to remain private on my company computer?

Although you may use your company-issued computer for incidental private use, remember Change Healthcare owns the computer and all information stored on it. You should not have any expectation of privacy with respect to any information stored on your computer or any other company-owned information systems. To the extent permitted by law, Change Healthcare may review anything stored on your company computer at any time.

We Maintain Accurate Business Records

I want to join a professional organization, but my manager told me the Company won’t pay the dues. I really think the professional organization will help me in my job, so what if I pay the membership dues myself and submit an expense report for something else to recover my money? Is that OK?

Submitting a false expense report is never acceptable. You should try and explain the benefits of joining this professional organization to your manager. If the answer is still no, you will need to evaluate if the personal benefits of joining the professional organization warrant your paying the dues yourself without reimbursement from the Company.

I have been assigned to review some paper and electronic records from my Business Unit. I think most of these can be disposed of because they date back several years and concern a product we no longer offer. Can I just put the records in the secure shredding container in the print room?

No. The Company has retention requirements for most types of records. In particular, there may be ongoing legal proceedings or contracts that require the records to be retained beyond the normal timeframes. You should check with the Office of Compliance and Ethics or Legal to see if the documents can be destroyed.

I have had a great year and have already made my sales number. One of my customers just called and inquired about adding a large addendum to its existing service order. Our new fiscal year starts in two weeks. Can I start the paperwork, but leave the date blank so that I can date it for the first of next month?

No. Inserting a date on a service order that mischaracterizes the true timing of the transaction is contrary to our responsibility to create and maintain accurate books and records. Service orders are important company financial documents. Knowingly creating a false or inaccurate document is prohibited.

I accidentally entered the wrong amount on an expense report. What should I do?

We all make mistakes. Be proactive, advise your manager of the error and take the necessary steps, as directed, to ensure the Company’s books and records are accurate.

We Follow the Law

What should I do if there is a conflict between company policy and the law in the country where I work?

Our goal is to comply with all local laws and to adhere to the highest standards of business conduct wherever we do business. If the local laws of a particular country or state within the U.S. are less restrictive, you still must adhere to policy. On the other hand, if the Change Healthcare policy is less restrictive than the local laws of another country, or state within the U.S. are less restrictive than company policy, you must comply with the local law. Please contact Change Healthcare Legal if you have any questions about applicable laws.

Fraud, Waste, and Abuse Laws

I know that the U.S. federal government has implemented several laws and regulations addressing fraud, waste and abuse(FWA) in federal healthcare benefit programs. How can I recognize FWA?

Many of our customers have business relationships with the Centers for Medicare and Medicaid Services (CMS) or other agencies that involve offering and/or providing healthcare services to federal healthcare benefit program enrollees. CMS requires many of these customers to maintain compliance programs and attest to compliance with FWA training requirements. Change Healthcare contracts with these customers, and is, therefore, also obligated to have appropriate FWA training, which we offer on an annual basis.

FWA comes in many different forms, and recognizing the various forms is important. We all are obligated to become familiar with the definitions of FWA and learn to recognize the different kinds of FWA.

  • Fraud is intentionally or knowingly using false statements or fraudulent schemes (such as kickbacks) to obtain payment, or cause another to obtain payment, from any healthcare benefit program.
  • Waste is the overuse or inefficient use of medical benefits and services that leads to unnecessary costs.
  • Abuse is actions that are inconsistent with accepted, sound medical, business and fiscal practices that directly or indirectly result in unnecessary healthcare costs.

Examples of FWA include false claims, bait and switch pricing, kickbacks, marketing schemes, incorrect coding, upcoding, duplicate billing, unnecessary services or treatments, billing for services not provided, identity theft, and failure to offer negotiated prices.

Please contact the Office of Compliance and Ethics if you would like more information on FWA and the Company’s training obligations.

Antitrust and Competition Laws

At a trade association meeting, several of our competitors began discussing their marketing and pricing strategies. What should I do?

Although trade associations have legitimate purposes, they create risks of anti-competitive discussions. A group of competitors discussing issues of mutual concern could cross a line into an anti-competitive topic. If you find yourself in a situation where a topic seems inappropriate, leave the discussion immediately and make it clear to those present that you are leaving because of the nature of the conversation. You should also report the issue to Legal as soon as possible.

Anti-Corrupution Laws

I believe one of our contractors may be making improper payments to government officials on behalf of Change Healthcare. Should I be concerned?

Yes. The actions of parties performing services on our behalf may expose Change Healthcare to significant liability under anti-corruption laws. If you have reason to believe a party performing services on Change Healthcare’s behalf is making improper payments, immediately contact your manager and Legal, or raise the issue through the direct link to Change Healthcare’s EthicsLine on the bottom of this page.

Doing Business with the Government

I am scheduled to be traveling to the airport at the same time as a United States Federal Contracting Officer after our meeting. What if I offer the Contracting Officer a ride to the airport and save her the taxi ride? Is that ok?

No. Providing transportation to a United States Government Federal Contracting Officer is generally prohibited unless the individual pays the market value of the transportation.

Is it ok for a Change Healthcare team member to obtain information on the prices a competitor plans to bid or has bid on a government procurement?

No, it is not permissible for Change Healthcare to obtain any information that another party considers proprietary or confidential regarding competitive procurement, including information about pricing.

Political Contributions and Activities

A friend of mine is running for local office and I would like to help him with his campaign. Is this allowed?

Yes. Your personal political activities are your own – not Change Healthcare‘s. Just make sure not to use Company resources, including Company time, email or the Company’s name to advance your friend‘s campaign.