Code of Conduct

At RxAdvance, we are committed to conducting business in an ethical and honest manner and within the bounds of the law. This Code of Conduct is intended to provide employees with guidelines for conducting business in a manner which fulfills that commitment. The Code of Conduct is supplementary to the mission, vision, and governs the conduct of all employees, members of the Board of Directors (when acting on behalf of the Company), first tier, downstream, and related entities (FDRs), contractors, and all agents of the Company.

 

The standards contained in this Code of Conduct are important, and therefore any violation will be handled in accordance with the Performance Management, or other applicable policies and procedures of RxAdvance, and may include termination of employment. In addition, referral of certain matters will be made to government and regulatory agencies as required by law. The offender may also be responsible in a civil suit for losses or other damages caused by his or her inappropriate conduct.

 

The Corporate Compliance Program

The Corporate Compliance Program has been established to prevent the occurrence of illegal or unethical behavior, to stop any such behavior as soon as reasonably possible after it has been discovered, to discipline the individuals involved (including those who know of violations but fail to report them), and to recommend and implement changes in policy and procedure necessary to avoid a recurrence of any prior violation.

 

Questions and How to Report Violations of the Standards

It is important to RxAdvance that employees have an effective way to get an answer to any question they may have about how to conduct their job. It is also important for employees and other agents to report any instance of a known or suspected violation of this Code of Conduct.

 

In the event that an employee has a question or concern or believes that someone is conducting their business in an illegal, unethical, or otherwise questionable manner, or violating RxAdvance’s policies, it is preferred that the employee first contact his or her supervisor to discuss the matter.

 

RxAdvance’s Commitment to Compliance

RxAdvance strives to…

 

1. Comply with the Law.

RxAdvance is subject to numerous local, state, and federal laws and regulations pertaining to all aspects of its operation. All employees are required to understand and abide by those laws and regulations which are applicable to them in the performance of their jobs.

 

2. Provide Excellent Member Care.

RxAdvance employees shall strive to treat all members with a spirit of kindness, patience and understanding. Each member is an individual and should be treated as such. RxAdvance will provide services in a manner that does not discriminate against any person because of age, race, religion, gender, sexual orientation, disability, national origin, or for any other reason prohibited by applicable state and Federal law. At all times, competent and qualified individuals will provide appropriate care, while considering the safety and well-being of the patients.

 

3. Protect Confidential Information.

RxAdvance is committed to maintaining the confidentiality of patient, personnel, and other proprietary information in accordance with applicable legal and ethical standards.

 

4. Drug and Alcohol Use

All employees and contractors working at RxAdvance must consent to drug and alcohol screening upon reasonable suspicion of the use of drugs or alcohol (i) during work hours or (ii) outside of work hours if it impairs employee’s or contractor’s ability to perform the duties of his or her position during work hours.

5. Adhere to Anti-Referral and Health Care Fraud and Abuse Legislation.

All employees of RxAdvance are required to comply with laws which prohibit health care fraud and abuse. Activities that are prohibited include, but are not limited to:

  • Intentionally or knowingly making false or fraudulent claims for payment or approval;
  • Offering or receiving remuneration (such as a kickback, bribe, or rebate) as an inducement to make a referral for the furnishing (or arranging for the furnishing) of any item or service;
  • Submitting false information for the purpose of gaining or retaining the right to participate in a plan or obtain reimbursement for services.

 

6. Not Accept Inappropriate Gifts or Gratuities.

The following standards apply to the giving or receiving of gifts and gratuities.

 

Receiving Gifts:

Employees are prohibited from soliciting tips, personal gratuities or gifts from members, prescribers, clients, pharmacy providers, and vendors. Employees may, however, accept non-monetary gratuities or gifts of a nominal value, such as cookies, flowers, or candy if the gift would not influence, or reasonably appear to others to be capable of influencing, the employee’s business judgment.

 

If the value of the gift is substantial or there is a question regarding whether the gift meets this standard of reasonableness, the employee must seek prior approval from the Corporate Compliance Officer (who will take the request to the Compliance Committee for review) or refuse the gift and promptly return the gift.

 

Giving Gifts:

Employees shall not offer or give money, services, or other things of value with the expectation of influencing the judgment or decision-making process of any purchaser, vendor, client, member, prescriber, pharmacy provider, governmental official or any other person.

 

An employee who is in doubt about whether a situation involving the giving or receiving of something of value is acceptable, should ask his or her supervisor, or the Human Resources Department.

 

7. Avoid Conflicts of Interest.

It is the policy of RxAdvance to prohibit its employees and other associates from engaging in any activity, practice, or act which conflicts with, or appears to conflict with, the interests of RxAdvance, its members, its clients, or its vendors. Therefore, Employees, Contractors, Board Members, and other individuals must disclose to their supervisor or the Compliance Officer any potential conflict of interest they or their immediate family have in any firm which does business with RxAdvance or which competes with RxAdvance. S

 

8. Follow All Antitrust Regulations.

A number of activities engaged in by RxAdvance are subject to state and federal antitrust laws. Generally, these laws prohibit agreements or actions that may illegally restrain trade or reduce competition. Examples of activities that violate these laws include, but are not limited to, agreements among competitors to fix or stabilize prices, inappropriate exclusive dealings, and boycotts of specified suppliers or customers.

 

9. Keep Accurate and Complete Records.

It is essential that RxAdvance report accurate information to governmental entities and other third parties. In order to meet this obligation, it is equally essential that every employee accurately and clearly report the relevant facts or the true nature of a transaction. No employee should knowingly or with reckless disregard for the truth make any false or misleading statement on any form or to any other officer, employee, or auditor for RxAdvance. Employee travel and entertainment related expenses must be accurately documented and supported when seeking reimbursement from RxAdvance.

 

10. Provide a Safe Workplace.

It is the policy of RxAdvance to comply with all applicable state and federal laws designed to improve workplace safety. RxAdvance is committed to training employees to carry out their work in manner that is safe for them, their coworkers, and the members they serve.

RxAdvance prohibits any disruptive, abusive, offensive, or impaired behavior. Prohibited conduct includes, but is not limited to:

  • Inappropriate verbal communications, including profane, intimidating, or disrespectful language.
  • Demeaning or condescending behavior or actions.
  • Inappropriate physical contact or physical threats.
  • Verbal abuse, verbal outbursts, or name-calling.
  • Please see 8001 Employee Handbook for more information

 

11. Not Tolerate Harassment or Discrimination.

It is RxAdvance’s policy not to discriminate on the basis of race, color, religion, national origin, age, disability, sexual orientation, or gender in providing services to patients or the public, nor in relation to employment practices. Furthermore, RxAdvance prohibits harassment of its employees in any form by supervisors, coworkers, clients, members, or vendors.

 

12. Appropriately Use its Assets.

All employees are charged with protecting and preserving RxAdvance’s assets and resources by following procedures to prevent their loss, theft, or unauthorized use. No part of the net earnings of RxAdvance shall inure to the benefit of, or be distributed to, its trustees, Executive Staff, employees or other private persons having directly or indirectly any personal or private interest in the activities of RxAdvance, except to the extent that such payments constitute reasonable compensation for services rendered in the necessary course of RxAdvance’s business.

 

13. Protect Access to Information Systems.

RxAdvance is committed to protecting all aspects of its information systems. All employees and other associates with access to RxAdvance’s computerized information system must abide by RxAdvance’s Security and Infrastructure Policies. Some Security and Infrastructure Policies include information concerning the protection of confidential information, passwords and access information. .

 

14. Adhere to Intellectual Property Laws.

RxAdvance is committed to adhering to all applicable intellectual property laws. All software used in connection with RxAdvance’s business must be properly licensed and used in accordance with that license. Additionally, RxAdvance will respect the intellectual property and copyright laws regarding books, trade journals, magazines, and other applicable resources.

 

15. Reporting Suspected Fraud.

RxAdvance is committed to adhering to all laws and regulations applicable to reporting suspected fraud or fraudulent activities.  RxAdvance employees should immediately notify their supervisor, or if circumstances warrant, the Compliance Officer of the company, should they suspect any fraudulent activity.

 

16. Non-Retaliation.

RxAdvance prohibits retaliating against anyone for raising a legal or ethical concern or cooperating with an investigation. Retaliation can also be against the law, leading to potential civil liability and criminal penalties. No one may seek revenge against, or try to “get even” with, any colleague who makes a good faith report, regardless of who is implicated. Retaliation is taken very seriously by the Company, and if it occurs it will result in discipline up to, and including, termination of employment.

 

Attestation

By signing the RxAdvance Policy and Procedure Attestation, employees, temporary staff, and contractors are acknowledging that they have read and understood the RxAdvance Code of Conduct policy and will abide by it.

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RxAdvance is now nirvanaHealth.

Since 2013, the RxAdvance team has been dedicated to disrupting the healthcare industry, specifically in pharmacy benefit management. After 3 years of development, we went live with our first client in 2016 and delivered groundbreaking pharmacy benefit management services. Now that we have proven success year-after-year, we have decided to expand our impact beyond just the PBM industry—onto the payer industry. These two industries alone control the majority of the healthcare spend in the United States, including the $900+ billion of waste generated annually. With our expansion into a new portion of the industry, we have outgrown the RxAdvance name, since it does not accurately capture the scope of our healthcare reach and mission. We are excited to announce our new name and brand—nirvanaHealth. The RxAdvance name has served us well for many years and will continue to do so under nirvanaHealth.