STANDARDS OF CONDUCT
Ethical Obligations for Compliance
Lake Nona Diagnostics is a business of high ethics and morals. Each of Lake Nona Diagnostics’ employees and agents is required to act in conformity with such viewpoints. In furtherance of this position, each employee or agent shall timely report to the Compliance Officer any and all activities that such person knows or reasonably suspects are not in conformance with this Compliance Plan.
Obligations to Act in the Best Interest of Lake Nona Diagnostics
Each person or entity who is an employee or agent of Lake Nona Diagnostics shall conduct him/her/itself in furtherance of the goals of Lake Nona Diagnostics. Intentional or reckless disregard of this Compliance Plan or any applicable Federal or State law may subject a person to discipline from the Executive Team, including (as appropriate) termination of employment or other affiliation with Lake Nona Diagnostics.
Prohibition on Ownership by Certain Persons
Physicians who are in a position to refer specimens to Lake Nona Diagnostics for testing are prohibited from possessing an ownership interest in Lake Nona Diagnostics.
Prohibition on Processing Certain Specimens
Lake Nona Diagnostics shall not perform laboratory services for any person who has primary or secondary coverage under a Federal or State health care program (i.e., Medicare, Medicaid, CHAMPUS or TriCare). Moreover, Lake Nona Diagnostics shall not submit any claims to any Federal or State health care program or bill any individual, third party payor, or other entity for services inadvertently furnished on behalf of any such person.
No Inducement for Referrals
Lake Nona Diagnostics shall not provide any inducement to any person or entity (e.g., ordering providers, staff of Treatment Facilities) in order to gain referrals for specimens. Lake Nona Diagnostics shall not charge a price below fair market value for any laboratory tests.
No Requirement for Treatment Facilities to Refer
At no time shall Lake Nona Diagnostics require any provider or Treatment Facility to refer specimens to Lake Nona Diagnostics for analysis or to compensate in any way any person or entity for doing so.
Each time new Standards of Conduct are issued, Lake Nona Diagnostics’ employees and agents shall be asked to sign a statement certifying that they have received, read and understand such Standards of Conduct.
