AHSA CODE OF CONDUCT
The American HealthCare Services Association (AHSA), its officers, and all of its employees
are committed to upholding only the highest caliber business
ethics and are strictly dedicated to the fair treatment
of all of its business associates. In order to demonstrate
our conviction to operating under only the most legal and
ethical circumstances, AHSA has established the following
guidelines that will formally serve as its Code of Conduct
(COC). It is the responsibility of every AHSA officer, employee
and business associate to uphold the standards set forth
in the COC in order to ensure that each individual’s conduct
does not violate these important principles. In addition
to the standards set forth in the COC, AHSA supports the
Code of Conduct of the Health Industry Group Purchasing
Association (HIGPA).
AHSA’s board members, officers, management and employees
will ensure an ongoing competitive environment by avoiding
any activities or circumstances that could create any perception
of conflict of interest. These policies are designed to
prevent any actual or perceived conflicts of interest. Actions
that may involve a conflict of interest must be avoided
both in business and personal relationships and activities.
Every representative of the AHSA organization is required
to disclose any conflict of interest which he or she may
have regarding any dealings involving any relationship with
any vendor or member and agrees to exclude himself or herself
from all matters involving said vendor or member.
AHSA policy prohibits AHSA equity in any contracted vendor
or member and does not permit any fees (other than member
annual dues) to be taken in advance. AHSA management and
exempt employees may not hold an individual equity interest
(own stock) in any company with which AHSA contracts. AHSA’s
COC requires all management and exempt employees to immediately
disclose specific personal investments which are in conflict
with these guidelines. No officer or employee (or their
immediate family) involved in or in a position to influence
the contracting process, may own any equity interest in
any health care stock. These stipulations expressly exclude
mutual fund holdings. Any such individual with any interest
has ninety (90) days from time of notification to sell such
stock to meet this requirement. If a loss is projected,
AHSA reserves the right to consider accepting a notarized
sell order in place of any actual sell transaction documentation.
In no instance may AHSA employees use or share inside information,
which is not otherwise available to the general public,
for any manner of personal gain or for the benefit of anyone
else, as might be realized through the stock trading of
any member or vendor.
Board members, management and employees are expressly forbidden
from providing or accepting gifts, other than of nominal
value (< $50 per instance), designed to influence the individual
in the performance of their duties. Gifts are defined as
business meals, entertainment and/or promotional items.
No AHSA officer or employee (or immediate family) may serve
on the board of directors (or comparable body) of any company
doing business or seeking to do business with AHSA.
AHSA will carefully maintain, respect and protect the confidentiality
of all proprietary information it obtains from its vendors
and members. The security and protection of proprietary
and confidential information is an expected component of
every AHSA employee's duties. Confidential information may
not be discussed with or released to any unauthorized individuals
and any violation may serve as grounds for immediate dismissal.
Practices that are prohibited under any state and/or federal
antitrust laws (which exist to prevent anti-competitive
actions) will not be tolerated. No verbal or written agreement
may be made with any competitor to control pricing, to limit
services, or to exclude vendors, members, or markets. AHSA
officers and employees are prohibited from taking any actions
to illegally monopolize or attempt to monopolize any applicable
business segments or activity within the health care and/or
group purchasing industry.
AHSA offers a comprehensive program which assists its members
in procuring health care services more efficiently and cost
effectively. In addition, the AHSA group staffing services
program supports it members with value-added services such
as credentialing, consolidated invoicing, utilization reporting
and more. While AHSA is continuously striving to create
value for it members and vendors, either party is able to
leave the program with thirty (30) days written notice.
Furthermore, AHSA members have the option to procure the
same or similar services from other vendors outside the
AHSA program since the member contract is non-exclusive
in design. We ask, in good faith, that members first attempt
to procure applicable services through AHSA in the interest
of allowing each member to maximize the benefits available
via their affiliation with AHSA.
In the interest of acting with the highest ethical standards,
all AHSA dealings must be forthright, honest, and in line
with AHSA policy as well as applicable laws and regulations.
As such, the AHSA RFI/contracting process is designed to
fairly evaluate vendors in the areas of cost competitiveness,
quality and service capacity. Paramount to this process
is the promotion of competition. AHSA has not and will not
dictate rates/prices to its vendors but will rather allow
natural competition and each submitting company to determine
its own level of pricing. We constantly strive to avoid
any appearance of preferential treatment or favoritism among
competing vendors. We will not accept fees from vendors
which are excessive or which do not relate directly to the
services procured by our members. From time to time, vendors
may be asked to sponsor or share in the costs of events
held to promote membership in AHSA. Any contributions received
are voluntary and have no bearing on any contracting decisions.
All AHSA contracts for staffing services will be for a term
of one (1) year and may be cancelled at any time with thirty
(30) days written notice. Vendor administrative fees will
be fairly and equitably assessed across the AHSA vendor
network and will not exceed 3 percent.
In the interest of continually striving to ensure only the
highest caliber business practices are carried out at AHSA,
vendor input is welcome at any time. In fact, AHSA more
formally requests feedback from its vendors on an annual
basis via its web-based vendor survey process. Vendor base
diversity is important to AHSA and, as such, we will work
to support and promote the efforts of minority and women-owned
businesses. AHSA strictly adheres to all appropriate regulations
relative to the disclosure of administrative fees to its
vendors. As such, a description of all group staffing services
program fees is included in the official AHSA Standard Agency
Staffing Agreement, which is executed by all AHSA vendors.
Furthermore, each AHSA member is provided with a copy of
this same agreement as well, allowing them to review such
administrative fees. The selection of staffing services
shall always be a result of the ultimate decision of each
applicable AHSA member. AHSA will impose no conditions on
its members that would impede their independent review and
selection decision.
Our commitment to these principles and practices is critically
important and any violation will not be tolerated. If you
have a concern regarding any unethical or unfair business
practice at AHSA, please contact us at 1-800-784-1975. The
AHSA leadership team commits to documenting and reviewing
any and all concerns in an effort to enforce the intent
of the AHSA COC. |
