HNE is committed to compliance with such laws and regulations and intends to assure that HNE’s activities and operations, as carried out by the employees and other agents of HNE, are conducted in compliance with such laws and regulations. In recognition of this commitment, HNE has developed a Corporate Compliance Program that has been adopted and endorsed by the HNE Board of Directors.

Governing Principles

• The HNE Compliance Program is based upon the following basic principles:
• Compliance with law is the policy of the company and is the best business practice.
• HNE should maintain policies and internal structures that encourage compliance.
• Compliance efforts should be designed to be as simple and effective as possible, and to avoid measures that will be confusing, ineffective or without substance.

Goals
The goals of the HNE Compliance Program are to:

• provide a structure for compliance oversight and direction by management and the Board of Directors;
• define, demonstrate, and communicate the organization-wide commitment to sustaining an ethical corporate culture;
• provide for the prevention and detection of illegal or unethical conduct by HNE employees and agents;
• provide a retaliation-free system for reporting and investigation of compliance violations or concerns; and,
• educate employees of HNE on pertinent federal and state laws and regulations.

Scope
The scope of the HNE Compliance Program covers all employees, temporary employees, volunteers, and agents of HNE and its subsidiaries, promoting compliance with applicable federal and state law and regulations while adhering to the highest ethical standards. The HNE Compliance Program also includes the HNE Privacy and Security Program, promoting the confidentiality, privacy and security of member protected health information, as well as the HNE Fraud, Waste, and Abuse Prevention Program.

Code of Conduct
Part of HNE’s mission is to be a leading corporate citizen. This means that HNE, and all HNE associates and agents, should follow these three rules when conducting business on behalf of HNE:

• Act ethically and responsibly.
• Obey the law.
• If you learn that someone connected with HNE is breaking either of the first two rules, do your best to put things right, or to find someone who can.

All employees and agents of HNE are advised as follows:

• No employee or agent of HNE has any authority to act contrary to the provisions of the Program, or to authorize, direct or condone violations by any other employee or agent of HNE.
• Any employee or agent of HNE who has knowledge of facts or incidents that he or she believes may violate this Policy has an obligation to promptly report the matter.
• Any employee or agent who violates the Program, or who orders or who knowingly permits a subordinate to violate the Program, shall be subject to appropriate disciplinary action which may include discharge or termination of his/her relationship with HNE.
• HNE will make full, fair, timely, and understandable disclosures in the periodic reports required by law.

Reporting Concerns
Please tell us if you have a compliance concern. You can call our toll-free compliance hotline, email, or send us a letter via fax or mail.

• Compliance Hotline: (800) 453-3959 (available 24/7; reports can be made anonymously)
• Email: compliance@hne.com (please use secure messaging at https://hne-mail.com)
• Fax: (413) 233-2806
• HNE mailing address:
  Health New England, Inc.
  Attn: Compliance Officer
  One Monarch Place
  Springfield, MA 01144-1500

When making a report, please provide as much detail as possible. Names, dates, and a description of the issues in question are helpful. For example, you may wish to describe why you think an activity is a cause for concern. If possible, please include your name and telephone number. That way, we can contact you if we have any questions during our investigation. If you wish to use email to report a concern, please use secure messaging to protect your confidentiality. For example, you may send and receive secure messages by logging in to the HNE Secure Mail Message Center. Go to https://hne-mail.com, create a login, and compose a message. You will be able to log in later to receive our response.

Prompt response and corrective action:
All reports will be taken seriously and, if warranted, investigated by the Compliance Officer. The identity of those reporting will remain confidential to the extent possible. However, confidentiality can not be guaranteed, and will not be possible in some circumstances. Compliance issues will only be discussed with persons with an absolute “need to know.” HNE will not tolerate retaliation against any employee or agent of HNE who reports a suspected violation in good faith.

Privacy and Security Program:
HNE has established a comprehensive Privacy and Security policy to protect HNE members from inappropriate use or disclosure of their protected health information (PHI). Under this policy, HNE has implemented appropriate administrative, physical, and technical safeguards to ensure the security of electronic PHI. For more information, review the HNE Notice of Privacy Practices.

Fraud, Waste, and Abuse Prevention Program:
HNE has established a comprehensive Fraud, Waste, and Abuse Prevention policy prevent, detect, and correct fraud, waste, and abuse by employees, members, employers, brokers, providers, and Contractors of Health New England (HNE). Under this program, HNE works to promote a sense of integrity and vigilance by means of comprehensive anti-fraud education for such individuals and entities. For more information, review the HNE Fraud, Waste, and Prevention Program page.

How to File a Health Information Privacy Complaint with the US Deprtment of Health and Human Services Office of Civil Rights.