Our Mission and Values
Nivano Physicians is committed to providing exceptional healthcare services while maintaining the highest standards of ethical conduct and legal compliance. Our Code of Conduct serves as the foundation for all decisions and actions taken by our organization, employees, physicians, contractors, and business partners.
Core Healthcare Values
Our code is built upon these fundamental healthcare values:
Quality Patient Care
- Patient-Centered Focus: Every decision prioritizes patient safety, dignity, and well-being
- Clinical Excellence: Commitment to evidence-based medicine and continuous quality improvement
- Cultural Competency: Respectful care for patients of all backgrounds, cultures, and identities
- Privacy and Confidentiality: Strict protection of patient health information and personal privacy
Cost Efficiency and Value
- Responsible Resource Management: Efficient use of healthcare resources without compromising quality
- Medical Necessity: Services provided must be medically necessary and appropriate
- Transparency: Clear communication about costs, benefits, and treatment options
- Stewardship: Responsible management of public and private healthcare funds
Organizational Integrity
- Ethical Decision-Making: “Do the right thing, always” guides all our actions
- Honest Communication: Truthful, accurate, and timely information sharing
- Accountability: Taking responsibility for our actions and their consequences
- Continuous Improvement: Learning from mistakes and implementing better practices
Commitment to Legal Compliance
All personnel must comply with applicable federal, state, and local laws, including:
Federal Healthcare Laws
- False Claims Act: No submission of false or fraudulent claims
- Anti-Kickback Statute: Prohibition on improper inducements and remuneration
- Physician Self-Referral Law (Stark Law): Compliance with referral restrictions
- HIPAA Privacy and Security Rules: Protection of patient health information
- Emergency Medical Treatment and Labor Act (EMTALA): Appropriate emergency care
Medicare and Medicaid Compliance
- CMS Conditions of Participation: Meeting all Medicare/Medicaid requirements
- Quality Reporting: Accurate and timely submission of quality data
- Audit Cooperation: Full cooperation with government audits and investigations
- Fraud Prevention: Active measures to prevent, detect, and report fraud
Civil Rights and Non-Discrimination
- Section 1557: Non-discrimination in healthcare programs and activities
- Americans with Disabilities Act: Accessibility and reasonable accommodations
- Title VII: Equal employment opportunity and workplace respect
- California Civil Rights Laws: Enhanced protections under state law
Standards for All Personnel
Employees
All Nivano Physicians employees must:
- Follow all policies and procedures as outlined in the employee handbook
- Complete required training including compliance, privacy, and safety programs
- Report violations through appropriate channels without fear of retaliation
- Maintain confidentiality of patient information and business operations
- Provide respectful service to all patients, families, and colleagues
Physicians
All affiliated physicians must:
- Practice evidence-based medicine in accordance with professional standards
- Maintain proper licensure and meet all credentialing requirements
- Follow clinical protocols and quality assurance procedures
- Participate in peer review and quality improvement activities
- Comply with medical staff bylaws and hospital policies
Contractors and Vendors
All business partners must:
- Execute appropriate agreements including Business Associate Agreements where required
- Meet security requirements for handling patient information and organizational data
- Follow compliance standards equivalent to our internal requirements
- Report potential violations and cooperate with investigations
- Maintain professional standards consistent with our organizational values
Behavioral Expectations
Professional Conduct
We expect all personnel to:
- Treat everyone with dignity and respect regardless of position, background, or circumstances
- Communicate professionally in all interactions, both internal and external
- Maintain appropriate boundaries in professional relationships
- Avoid conflicts of interest that could compromise judgment or create unfair advantage
- Protect confidential information belonging to patients, employees, and the organization
Ethical Decision-Making Framework
When facing ethical dilemmas, consider:
- Is it legal? Does the action comply with all applicable laws and regulations?
- Is it ethical? Does it align with our values and professional standards?
- Is it in the patient’s best interest? Does it prioritize patient welfare and safety?
- Would I be comfortable if this became public? Can I defend this decision transparently?
- Does it pass the “right thing” test? Is this what I would want for my own family?
Reporting Mechanisms
Compliance Hotline
Report violations or concerns through our confidential hotline:
- Phone: (916) 407-2000
- Email: compliance@nivanophysicians.com
- Mail: Nivano Physicians Compliance Officer, 2554 Millcreek Dr, Suite 100, Sacramento, CA 95833
Open Door Policy
We maintain an open-door policy encouraging:
- Direct supervisor discussions about compliance concerns
- Management consultation on ethical questions
- Compliance officer access for sensitive matters
- Anonymous reporting options when preferred
Protection Against Retaliation
Nivano Physicians strictly prohibits retaliation against anyone who:
- Reports suspected violations in good faith
- Participates in investigations or compliance activities
- Refuses to participate in potentially illegal activities
- Advocates for proper compliance and ethical conduct
Consequences of Violations
Disciplinary Actions
Violations of this Code of Conduct may result in:
- Corrective counseling and additional training
- Written warnings with performance improvement plans
- Suspension without pay pending investigation
- Termination of employment or contract relationships
- Legal action including criminal and civil penalties
Factors Considered
Disciplinary decisions consider:
- Severity of the violation and potential impact
- Intent and knowledge of the individual involved
- Previous compliance history and training completion
- Cooperation with investigations and corrective measures
- Legal and regulatory requirements for specific violations
Personal Responsibility
Every individual associated with Nivano Physicians has a personal responsibility to:
Stay Informed
- Read and understand this Code of Conduct and related policies
- Complete required training and stay current with updates
- Ask questions when uncertain about proper conduct
- Stay informed about changes in laws and regulations
Take Action
- Report suspected violations promptly and honestly
- Cooperate fully with investigations and corrective actions
- Implement improvements based on compliance guidance
- Model ethical behavior for colleagues and subordinates
Continuous Commitment
- Acknowledge receipt of this Code of Conduct annually
- Participate actively in compliance and quality improvement activities
- Suggest improvements to policies and procedures
- Maintain professional development relevant to your role
Distribution and Acknowledgment
Required Distribution
This Code of Conduct must be distributed to:
- All new employees during orientation
- All physicians upon initial appointment and reappointment
- All contractors and vendors handling patient information or providing services
- All board members and organizational leadership
Annual Acknowledgment
All personnel must:
- Review the Code annually and acknowledge understanding
- Complete attestation forms confirming compliance commitment
- Attend update training when significant changes occur
- Maintain current contact information for compliance communications
Contact Information
For questions about this Code of Conduct:
Chief Compliance Officer
- Email: compliance@nivanophysicians.com
- Phone: (916) 407-2000
- Office: 2554 Millcreek Dr, Suite 100, Sacramento, CA 95833
Human Resources Department
- Email: customerservice@nivanophysicians.com
- Phone: (916) 407-2000
This Code of Conduct reflects our unwavering commitment to ethical healthcare delivery and legal compliance. It is reviewed annually and updated as needed to reflect changes in laws, regulations, and best practices.
Document Version: 1.0
Effective Date: August 7, 2025
Board Approval Date: August 7, 2025
Next Review Date: August 7, 2026