Change Healthcare FAQs
ABOUT THE ETHICSLINE
The Change Healthcare EthicsLine is a confidential reporting tool you may use at any time to ask questions or report suspected violations of Change Healthcare’s Code of Conduct, company policies or legal requirements. It is a resource for team members with questions regarding the right thing to do, as well as a tool through which we can speak up when we suspect others may not be doing the right thing.
At Change Healthcare, we believe that our team members are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity. Additionally, publicly-traded companies are required by law to have an anonymous reporting vehicle to address accounting and auditing fraud, violations of our Code of Conduct and any other ethical concerns.
Change Healthcare’s EthicsLine offers a secure mechanism – web and phone – for you to raise your concerns 24 hours a day, 7 days a week, 365 days a year.
REPORTING – GENERAL
Change Healthcare’s success is in part based on the trust it has established with its customers, team members, and other stakeholders. Ethical lapses can damage this trust and, as a result, impact Change Healthcare’s business. To protect that trust and help ensure our continued success, team members not only have a responsibility to act ethically but also to speak up when they are concerned that others may not be acting appropriately.
No, the EthicsLine is operated by NAVEX, an independent third-party organization that provides hotline reporting solutions for organizations worldwide.
We expect you to speak up and voice your concerns whenever you observe behavior that you believe may violate our Code of Conduct, company policies or legal requirements. Ideally, you should bring concerns forward to your manager, Employee Relations, Business Unit Compliance, or other member of your management team. We recognize, however, that there may be circumstances when you may not want to speak directly with management regarding your concerns. With the EthicsLine, you can ask questions or raise concerns confidentially.
Yes, if anonymous reporting is allowed by local laws. We do, however, encourage you to identify yourself. We may be able to do a better job of investigating your concern if you let us know who you are and how we can reach you.
Yes, the EthicsLine provides a process through which you can remain anonymous (if allowed by local law) and at the same time communicate with the individual assigned to investigate your report.
If you provide your name or other identifying information, your identity will be treated as confidential. However, it is not possible to guarantee absolute confidentiality. Disclosure to others may be required by law or someone may guess your identity from the circumstances in your report. You should not let these possibilities discourage you from reporting a concern. Change Healthcare encourages you to speak up and will not tolerate retaliation against anyone who raises a good faith concern.
The Change Healthcare EthicsLine is designed for raising concerns or asking questions involving potential violations of our Code of Conduct, company policies or legal requirements. Such potential violations could include, but are not limited to:
• Discrimination or harassment
• Retaliation or intimidation
• Workplace violence, threats or bullying
• Substance abuse
• Conflicts of interest
• Falsification of documents or other fraudulent activity
• Inappropriate gifts or entertainment
• Inappropriate political activities and contributions
• Breaches of a customer’s or Change Healthcare’s confidentiality
• Inappropriate personal use of Change Healthcare’s resources
• Theft, bribery or kickbacks
• Potential Privacy Incidents
• Accounting or other financial concerns
• Other potential violations of our Code, company policies or legal requirements.
Change Healthcare’s EthicsLine is administered by a third-party organization who provides representatives to answer your call. When you call the EthicsLine, the Call Center agent will ask you some questions to gather as much information as possible. You should be prepared, if you are willing, to provide the names of witnesses and impacted individuals of any alleged unethical conduct. Such information will assist in our investigation into your complaint.
When you submit the report, you will be issued an access code and password. Please write it down and keep it in a safe place. Use this access code and password to return to the EthicsLine website or telephone helpline within 5 business days to review any follow-up questions or to submit more information about your report. Please continue to follow up in the system so that we can continue communicating with you as necessary.
Your report will be investigated promptly, thoroughly and discreetly. All investigations will be objective, fact-based and free from personal opinion, bias or prejudice. When making a report, please provide as much information as possible, including the name of your business unit or department, the name of the people involved, details of the concern, any supporting evidence, and any other relevant information. It is important to ensure we have enough detail to review and take appropriate action. If more information is required and you have provided your personal information, you may be contacted to provide further details.
Change Healthcare does not tolerate any form of retaliation for raising concerns in good faith, asking questions, or participating in an investigation. Change Healthcare encourages all Team Members to share their concerns and presumes all concerns are being raised in Good Faith. Raising a concern in good faith means making a genuine effort to provide honest, complete and accurate information.
Although it is generally easier to conduct an effective investigation if you identify yourself, where local laws permit, you may choose to remain anonymous. If you do report your concern anonymously, there is no way for Change Healthcare to trace your call. The third party that manages the EthicsLine system does not use caller ID and does not record the calls. Reports from your computer would come through a secure internet portal which does not trace or show user screen names. Your internet IP address is removed to ensure that anonymity in the EthicsLine system is maintained. You will be given a password and an access code after you file the report or ask a question that will allow you to go back into the system anonymously to respond to questions we may have or to see the answer to your question.
Information is entered directly on the EthicsLine secure server to prevent any possible breach in security. The information you provide is only available to specific individuals within the company who are charged with reviewing the information you have provided. The individuals may vary but will typically include a member of the Office of Compliance and Ethics, Legal and Compliance, or Employee Relations teams.
Whether your report is anonymous or not, we cannot guarantee confidentiality or anonymity as the nature of the issue and/or related case details may reveal the identities of those involved. However, the EthicsLine and company investigation practices are designed to ensure that only those individuals with a need to know will have access to information about the matter. In addition, every effort will be made to maintain a high level of discretion in responding to inquiries and investigating reports submitted through the EthicsLine. Change Healthcare encourages all Team Members to share their concerns and presumes all concerns are being raised in Good Faith. Further, Change Healthcare’s Speak Up and Non-Retaliation Policy applies even if an allegation that was made in Good Faith ultimately turns out to be unsubstantiated. Please also note that Change Healthcare has zero tolerance for retaliation where a concern has been raised in good faith. Anyone who engaged in retaliation will be subject to disciplinary action up to and including termination.
To protect the privacy of all concerned, Change Healthcare generally cannot discuss the specifics of investigations except with certain members of management, Employee Relations, and any employee directly impacted by disciplinary or remedial actions. However, if you make a report to the Change Healthcare EthicsLine - even anonymously - you will be provided a unique access code and password. We urge you to contact the EthicsLine either by phone or online to receive updates or provide additional information that may be necessary for proper investigation of your concern.
To preserve the security of your data, access to your report and any further communication is carefully controlled. Therefore, if you lose your report key or password, you must file a new report to obtain updates or provide additional information in connection with the initial report. In the new report, you should mention that the matter relates to a prior report.
Translation resources are available whether an inquiry or report is submitted to the Change Healthcare EthicsLine via online or by telephone. If communicating over the telephone, the reporter must be able to speak the name of their preferred language in English to the Change Healthcare EthicsLine operator. The operator will conference in a translator who will then assist with documenting the inquiry or report.
REPORTING - OTHER
A Potential Privacy Incident is a situation where an individual or entity may have received, viewed, or had access to any Restricted, Confidential or Internal Use Only information not belonging to them. This includes unauthorized access or disclosure of Protected Health Information (PHI) and Personal Information (any information about an individual).
Any Potential Privacy Incident should be reported immediately via Change Healthcare’s EthicsLine by going to www.changehealthcareethicsline.com, clicking on the “Potential Privacy Incident” button, and providing as much information as known at the time of the report. It is important not to delay reporting any Potential (known or suspected) Privacy Incident.
Change Healthcare Team Members are encouraged to visit the Enterprise Privacy Team’s My Community Page by going to Ping One, selecting My Community and selecting Privacy from the dropdown menu of Quicklinks on the top.
A suspected l Information Security Incident is the attempted or successful unauthorized access, use, disclosure, modification, or destruction of information or interference with system operations in an information system. If you suspect or become aware of any Information Security Incident (lost laptop, phishing or other system security issues), you can file a report about that Information Security Incident by email at securityincident@changehealthcare.com.
VOLUNTARY DISCLOSURES
At Change Healthcare, acting with integrity means placing Change Healthcare’s best interests before our own. We do not let personal interests affect the business decisions we make on behalf the company. Change Healthcare’s Code of Conduct requires all team members to disclose any activity, relationship, or situation that can create an actual or potential conflict of interest, or the appearance of one. The EthicsLine provides a tool through which team members should disclose any situation or activity that may compromise our ability to act in the best interests of Change Healthcare.
The Office of Compliance and Ethics will review the potential conflict of interest and determine. If necessary, it will request additional information to determine whether a conflict exists. In some instances, you may need to sign a letter that outlines how you and Change Healthcare will manage the conflict.