Mennonite Home Communities of Ohio

Mennonite Memorial Home • Maple Crest • Willow Ridge
Mennonite Home Health & Senior Services • Hilty Home

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SCOPE

Our Compliance Program Plan covers the compliance issues, laws and regulations and guidelines that are relevant to a provider of senior services including senior living communities that may provide a wide range of healthcare services. This includes but is not limited to Medicare and Medicaid regulatory issues, guidelines from the Office of Inspector General, Internal Revenue Service and the Office of Civil Rights of the Department of Health and Human Services, Occupational Safety and Health Administration as well as other regulatory and business issues.

The term "PARTNER" defines the various individuals who are partnered with Mennonite Home Communities of Ohio (MHCO). All individuals, including employees, vendors, contractors, volunteers, donors, directors and officers are members of our team in providing care and services to our residents.

The term "RESIDENT" as used in this Code of Ethics refers to both residents who live within the walls of MHCO, as well as clients who are served in their own private homes by Mennonite Home Health and Senior Services.

The scope of the program includes:

Policies and procedures that guide our organization in appropriate business practice and promote compliance with laws and governmental regulations;

Recommendations and resources for training programs that are mandatory for Partners to ensure understanding of the Code of Ethics;

Distribution of a copy of the Code of Ethics to all Partners and with a written acknowledgment of its receipt by the Partner;

Structures that include appropriate monitoring and review of potential fraud and abuse issues conducted to identify need for corrective action as well as additional training;

Mechanisms established to provide Partners with a means to report potential noncompliance issues or other areas of concern without fear of retribution;

A process for corrective action that includes appropriate corrective measures, to address any issues of noncompliance;

Guidelines that have been developed for prevention of response to identified compliance issues. This includes an annual review of the Compliance Program and modifications to the Program as appropriate;

Designation of a Compliance Officer and other appropriate bodies such as a Compliance Committee charged with the responsibility for developing, operating and monitoring the Compliance Program within the organization.

Any questions regarding the policies in this Code of Ethics or references should be directed to your immediate supervisor, the Compliance Liaisons, a member of the Compliance Committee or the Compliance Officer (see Appendix A for a list of names).

We are a retirement community that provides a continuum of care including in-home services, independent duplexes and apartments, assisted living and skilled nursing environments. In addition, we provide services to children through the Hilty Home's child care center. This Code of Ethics applies to every person at every level of the organization. This includes employees, board of directors, volunteers, independent contractors, subcontractors and vendors who may provide or are involved with healthcare or billing. The term Resident refers to individuals who receive the various types of healthcare, and other services that we provide.

Mennonite Home Communities of Ohio includes retirement communities that offer services that are licensed by the Ohio Department of Health, the Ohio Department of Job and Family Services, and the Centers for Medicaid and Medicare. All policies in MHCO's Corporate Compliance program pertain to all MHCO entities, including Mennonite Memorial Home, Maple Crest, Mennonite Home Health and Senior Services, Willow Ridge and Hilty Home.

Lines of service provided by Mennonite Home Communities of Ohio

Intermediate and skilled nursing care
Residential care (i.e. assisted care)
Independent apartments and duplexes
In-home clinical and non-clinical services
Services to children, including day care, preschool, and after school programs

The CODE OF ETHICS is supported by the policies and procedures of MHCO. For more specific guidelines, see the appropriate policy or procedure.

STRUCTURE AND ORGANIZATION

Friends Services for the Aging (FSA), along with Brethren, Mennonite and Quaker organizations involved in providing services to the elderly, have established a collaborative Compliance Program known as the Peace Church Compliance Program (PCCP).

The Board of Directors of MHCO, the Board of Directors of Hilty Home and Friends Services for the Aging have jointly established the following structure, reporting relationships and responsibilities to oversee the administration of the PCCP and to ensure that all potential issues or violations identified by any Partner are investigated and addressed.

COMPLIANCE & PRIVACY OFFICER (Compliance Officer)

The FSA Senior Director of Compliance serves as our Compliance & Privacy Officer. She has the responsibility to assist the Compliance Liaisons, the CEO and the Board of Directors in designing, establishing and overseeing efforts in establishing, maintaining and monitoring compliance within the organization.

The Compliance Officer works with the CEO and the Compliance Liaisons and has periodic reporting responsibility to the Board of Directors. The Compliance Officer is also accountable to the Executive Director of Friends Services for the Aging. The Compliance Officer is responsible for the oversight of the PCCP including continued coordination with the Compliance Liaisons for the development, implementation, training, monitoring and enforcement activities within the organization. The Compliance Officer is assisted by Compliance Specialists in providing services to your organization on a quarterly basis.

MANAGEMENT

The Chief Executive Officer carries the overall responsibility for creating a culture that values and emphasizes compliance and integrity and ensures privacy. As a central part of this role, he/she serves on the Compliance Oversight Council and participates in the selection of the Compliance Oversight Committee that guides the PCCP.

At MHCO-Bluffton, the Healthcare Administrator and the Assisted Living Supervisor have been appointed as the Compliance Liaisons. At MHCO-Hilty, the Healthcare Administrator and the Secretary/Receptionist have been appointed as the Compliance Liaisons. They are responsible for coordinating compliance activities in conjunction with the Compliance Officer. These activities include quarterly audits, responses to hotline calls and overseeing the organization's Compliance Committee. As a function of this role, the Compliance Liaisons also function as the internal Privacy Officers.

The Organization's Compliance Committee is comprised of members of the management team. The Compliance Liaisons share the responsibility of chairing this committee. The committee meets no less than quarterly.

See APPENDIX A in full Code of Ethics PDF for list of team members.

HISTORICAL COMMITMENT TO CHRISTIAN SERVICE AND ETHICAL BUSINESS PRACTICES

The Board of Directors established a list of six CORE VALUES, and MISSION and VISION Statements which guide the day-to-day management of all communities of MHCO.

CORE VALUES

  1. Relationship through Community
    We are dedicated to nurturing the sense of family that flourishes among our staff, residents, clients and volunteers. We value the support of our churches and community. These foundational relationships are a sacred trust and we are devoted to preserving that trust in everything we do.
  2. Compassionate Care
    We seek to honor God as we demonstrate a Christ-like love and compassion to all touched by our ministry of continuing care. Each individual member of our family is unique, worthy of respect and gentle consideration.
  3. Life Enrichment
    We believe that true quality of life includes opportunities for life enrichment through meaningful activity, friendships, fun and personal decision-making. We affirm each person's unique gifts and talents, and we endeavor to create an atmosphere where each has opportunity to maximize his or her potential.
  4. Integrity
    As a not-for-profit, mission driven organization, we are devoted to responsible management of the financial, human, and natural resources entrusted to us with transparency, benevolence and honesty. We are committed to being trustworthy and honorable in our actions.
  5. Excellence
    We are dedicated to continuing our long tradition of progressive care and services designed to meet the spiritual, emotional and physical needs of each generation. Through our ministry, we desire to offer superior and distinctive services and environments which exceed expectations and glorify God.

MISSION STATEMENT

We are dedicated to being a Christ-centered community that promotes personal decision-making and purposeful living for each older adult served.

VISION STATEMENT

To be the community's source of innovative care, excellent services and comprehensive resources for older adults.

In addition, The Board of Directors of Hilty Home adopted the following Mission Statement for the Hilty Home Community.

MISSION STATEMENT – HILTY HOME

~Loving Care in a Christian Environment~

  • Excellent Physical Care in a Christian Atmosphere (Matthew 25: 31-40)
  • Supportive Spiritual Care with Opportunities for Christian Growth (Colossians 2:6-7)
  • Compassionate Care with a Servant Attitude (Matthew 20: 25-27, John 13: 12-17)

FROM THE CEO'S DESK

Dear Mennonite Home Communities of Ohio Partner,

Quality care of our resident and client population has always been our
commitment at Mennonite Home Communities of Ohio (MHCO). In an effort to maintain and improve the quality of the services we provide, we have implemented the Compliance and Privacy Program. This Code of Ethics serves as the foundation for how we operate. Our high standards are expanded further through our organizational policies and procedures.

This handbook will explain the Compliance and Privacy Program to you so that you can apply the guidelines in your daily duties at MHCO. If you have any questions, comments or concerns regarding these guidelines you should contact your immediate supervisor. You may also contact the Compliance Officer/Senior Director of Compliance at 215-646-0720 or use the confidential Peace Church Compliance Hotline at 1-800-211-2713.

Thank you for continuing to work in a manner that achieves the goals of
our organization.

Sincerely,

The Board of Directors of MHCO and
Laura Voth, CEO

Download the full Code of Ethics PDF » – 335kb

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