Advisory Board: Contra Costa Health Plan Joint Conference Committee
Subject: Code of Conduct
To: Joint Conference Committee (JCC) Members
From: Sunny T. Cooper, Senior Director of Compliance and Regulatory Affairs (Interim)
Compliance Department
Date: December 19, 2025
Subject: Code of Conduct
Approval of Code of Conduct November 2025 Release
CCHP has updated its Code of Conduct to remove reference to specific processes and focus more on ethical conduct and behavioral standards. Below is a detailed summary of changes.
*NEW* - disclaimer that the Code of Conduct shall not be construed as a contract of employment and who it applies to.
*NEW* - Table of Contents
*NEW* Section Introduction and Purpose - Definition of Ethics and what it is, Questions to ask yourself when faced with a challenging situation
*NEW* Section on Business Practices - expanded Conflicts of Interest, gifts and Tips, FWA, description of applicable laws (false claims act, stark law, anti-kickback law, etc)
*NEW* Section on Privacy, Security, and Protection of Assets - Information Security and Data Protection, Responsible use of AI
*NEW* Section on Public Engagement - Media and Speaking Engagements, Reference to Social Media Policy, Political Activity
*NEW* Section on Workplace Environment - Drug and smoke-free workplace, emergency plan, no discrimination, bullying, harassment, or violence, no solicitation
Section in Current Code
Current
Mission and Principles
RETAINED as written
Commitment to members, payors and regulators, Patient/client/member care and rights
MOVE AND UPDATED section to "professional interactions" - Streamlined language to highlight that everyone should be treated with respect and dignity
Confidentiality of patient information, HIPAA
REMOVED section of payments for referrals and the process for contracting physicians
Contract Physicians
REMOVED section of payments for referrals and the process for contracting physicians
Agreements with oth...
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