Nivano Physicians, Inc.
Effective Date: August 7, 2025
Last Updated: March 12, 2026
Version: 2.0
Purpose
This Code of Conduct establishes the ethical and legal standards that govern all decisions and actions taken by Nivano Physicians employees, affiliated physicians, contractors, vendors, and board members. Our code reflects our foundational commitment: deliver exceptional healthcare with integrity, transparency, and respect for every person we serve.
Core Values
Nivano Physicians’ conduct standards are built on three pillars:
Quality Patient Care — Every decision prioritizes patient safety, dignity, and well-being. We are committed to evidence-based medicine, continuous quality improvement, cultural competency, and the strict protection of patient health information.
Responsible Stewardship — We use healthcare resources efficiently and appropriately, provide only medically necessary services, communicate transparently about costs and options, and manage public and private healthcare funds with integrity.
Organizational Integrity — We do the right thing, always. Honest communication, accountability for our actions, and continuous improvement are not aspirational — they are operational requirements.
Legal Compliance
All Nivano Physicians personnel must comply with applicable federal, state, and local laws. Key legal obligations include:
| Legal Framework | Requirement |
|---|---|
| Federal False Claims Act (31 U.S.C. §§ 3729–3733) | No submission of false or fraudulent claims |
| Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)) | No improper inducements or remuneration |
| Stark Law (42 U.S.C. § 1395nn) | Compliance with physician self-referral restrictions |
| HIPAA Privacy and Security Rules | Protection of all protected health information |
| EMTALA | Appropriate provision of emergency care |
| CMS Conditions of Participation | Full compliance with Medicare/Medicaid requirements |
| ACA Section 1557 | Non-discrimination in healthcare programs and activities |
| Americans with Disabilities Act | Accessibility and reasonable accommodations |
| Title VII / California Civil Rights Laws | Equal employment opportunity and workplace respect |
Standards by Role
Employees
All Nivano Physicians employees are expected to follow all organizational policies and procedures, complete required compliance and privacy training on schedule, report suspected violations through appropriate channels without fear of retaliation, maintain the confidentiality of patient information and business operations, and treat all patients, families, and colleagues with respect.
Affiliated Physicians
All affiliated physicians are expected to practice evidence-based medicine consistent 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, and comply with applicable medical staff bylaws.
Contractors and Vendors
All business partners are expected to execute appropriate agreements — including Business Associate Agreements where required — meet security standards for handling patient information, follow compliance standards equivalent to our internal requirements, report potential violations and cooperate with investigations, and maintain professional conduct consistent with our organizational values.
Ethical Decision-Making
When facing an uncertain situation, apply this test before acting:
- Is it legal? Does it 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?
- Would I be comfortable if this decision became public?
- Is this what I would want for my own family?
If any answer is no, stop and consult your supervisor or the Compliance Department before proceeding.
Reporting Violations
Nivano Physicians maintains multiple channels for reporting compliance concerns. All reports made in good faith are protected from retaliation.
Compliance Department
Phone: (916) 407-2000
Email: compliance@nivanophysicians.com
Mail: Nivano Physicians Compliance Officer, 2554 Millcreek Dr., Suite 100, Sacramento, CA 95833
Reports may also be made directly to a supervisor, through management, or anonymously where preferred. Anonymous reporting options are available through the compliance office.
Retaliation against any individual who reports a suspected violation in good faith, participates in a compliance investigation, or refuses to participate in potentially illegal activity is strictly prohibited and is itself a violation of this Code.
Consequences of Violations
Violations of this Code of Conduct are taken seriously. Depending on the nature, severity, and circumstances of the violation, consequences may include corrective counseling, written warnings, performance improvement plans, suspension, termination of employment or contract, referral to licensing boards, or civil or criminal legal action.
Factors considered in any disciplinary decision include the severity and impact of the violation, the individual’s intent and prior compliance history, cooperation with investigation and remediation, and applicable legal or regulatory requirements.
Personal Responsibility
Every individual affiliated with Nivano Physicians has a personal responsibility to read and understand this Code, complete all required training on time, ask questions when uncertain about appropriate conduct, report suspected violations promptly, cooperate fully with investigations, and model ethical behavior for colleagues.
All personnel must acknowledge receipt of this Code annually and complete attestation confirming their compliance commitment.
Distribution
This Code of Conduct is distributed to all new employees during orientation, all physicians upon initial appointment and reappointment, all contractors and vendors handling patient information or providing services, and all board members and organizational leadership.
Contact Information
Compliance Department
Phone: (916) 407-2000
Email: compliance@nivanophysicians.com
Address: 2554 Millcreek Dr., Suite 100, Sacramento, CA 95833
Member/Patient Services
Phone: (916) 407-2000
Email: customerservice@nivanophysicians.com
Policy Review
This Code of Conduct is reviewed annually and updated to reflect changes in laws, regulations, CMS guidance, and organizational best practices. The next scheduled review is August 7, 2026.
This document was last updated on March 12, 2026 by the Compliance Department.