NAATP Code of Ethics - A common sense approach to "mission vs. margin" in the fast-changing...

NAATP Annual Conference – May 18, 2014Bob Ferguson, Ethics Committee Chairman

NAATP Code of Ethics

A common sense approach to balancing “mission vs. margin” in the ever-evolving landscape of addiction treatment.

Addiction Treatment at the Ethical Crossroads…

Who is policing what is being promised on the Internet, as well as by the call centers interwoven into the marketing strategies of treatment providers? Who comes between the desperate family and the treatment provider, to guarantee that treatment is valid and likely to produce a good outcome?

• Paying bounties for referrals.• Large gifts to interventionists with whom a

program works.• Insurance “bait and switch” when reimbursements

are very low.• Call centers sharing patient info among treatment

centers.• Kickbacks to and from toxicology labs and

treatment facilities.• Billing the patient for proprietary nutrient

supplements.• Promising a cure.


Environmental challenges facing today’s leaders

• Shifting payer mix – managed care, out of network, private pay

• Consolidation via mergers & acquisition

• Industry growth via start-ups, increased competition

• Uncertainty around ACA and Parity Act and inclusion of residential as an “essential service.”

• Impact of social media – emergence of the visible and vocal consumer

• Emergence of online/direct to consumer marketing: “Caveat Emptor”


Source: American Marketing Association https://archive.ama.org/Archive/AboutAMA/Pages/Statement%20of%20Ethics.aspx

Ethical Values American Marketing Association

Respect – to acknowledge the basic human dignity of all stakeholders.

Transparency – to create a spirit of openness in marketing operations. Honesty – to be forthright in dealings with customers and stakeholders.

Responsibility – to accept the consequences of our marketing decisions and strategies. Fairness – to balance justly the needs of the buyer with the interests of the seller.

https://archive.ama.org/Archive/AboutAMA/Pages/Statement%20of%20Ethics.aspx

Guiding Principals for NAATP Code of Ethics

• A “common sense” document that is evolving and dynamic

• The ethics conversation as a process, not an event.

• Create a forum for discussion and debate – i.e. leadership versus enforcement?

• Membership organization versus an accrediting agency


“What is moral is what you feel good after; what is immoral is what you feel bad after.”

- Ernest Hemingway

Benchmark Study – May, 2013

• Educational Consultants – IECA http://www.iecaonline.com

• Therapeutic Schools & Programs – NATSAP www.natsap.org

• Professional Chaplains – ACP http://www.professionalchaplains.org

• Chiropractors – ACA http://www.acatoday.org

• Doctors of Acupuncture – AAOM http://www.aaaomonline.org

• Midwives – NACPM http://www.nacpm.org

Examine, compare and identify: 1. Mission, Vision and Values2. Criteria for Membership3. Code of Ethics 4. Enforcement of Standards of Practice5. Handling of Complaints


http://www.iecaonline.com/

http://www.natsap.org/

http://www.professionalchaplains.org/

http://www.professionalchaplains.org/

http://www.acatoday.org/



http://www.aaaomonline.org/



http://www.nacpm.org/

http://www.nacpm.org/

…Just as personal responsibility and accountability are underscored in treatment for the recovery process, NAATP treatment providers shall assume such responsibility and accountability in their provision of treatment services, in their management practices, in their staff relationships, in their relationships with other publics, and in their marketing.


Treatment

• Specific admission and referral criteria are developed and adhered to for every level of service provided.

• Quality treatment services are provided that appropriately meet the physical, emotional, social and spiritual needs of the patient and family.

• Treatment programs enhance the dignity and protect the human and legal rights of the patient and family.

• Continuing care (or “aftercare”) services are considered essential to the continuum of care.


Management

• Governing authority clearly states organizational goals and objectives

• Staff members who subscribe to the professional standards of their respective fields provide interdisciplinary team treatment.

• Treatment facilities develop relationship with other health care providers to assure they are an integral part of a community’s health care services system.

• Fee structures are made available to the public.

• Treatment facilities do not discriminate against any person for any services provided on the basis of race, creed, sex or national origin.

• Treatment facilities recognize that ongoing internal evaluation of care is essential.


Facilities

• All applicable local, sate and federal life safety, occupational safety, health and fire codes are met.

• When a facility serves the handicapped, they are assured accessibility and maneuverability.

• The treatment facility’s environment enhances the human dignity and rights of patients.

• Positive community relationships are developed and nurtured.

• There is cultivation of good relationships and communications with related public and private agencies, associations, and institutions.


MarketingFinancial rewards for patient referrals:

No financial rewards or substantive gifts are offered for patient referrals.

Treatment providers may refer families or individuals to a variety of treatment or recovery support professionals, including interventionists; continuing care providers; monitoring agencies; and/or referral sources that offer services to patients prior to or after outpatient or residential treatment.

However, in no case should treatment providers make payment or compensation to these individuals or organizations in exchange for patient referrals – neither in the form of direct payment, consulting contracts, large gifts, nor other forms of remuneration or compensation.


MarketingDeceptive advertising or marketing practices:

Treatment providers will not engage in deceptive or misleading advertising or marketing practices.

NAATP members and member organizations will provide information in their advertising; on their websites; and in their collateral marketing materials about the general location of their facility or facilities; the credentials of their staff; and the length of stay in their programs.

In addition NAATP members and member organizations will not utilize any form of false or misleading advertising; will not engage in “patient brokering;” will not exploit patients and or families, particularly for the purpose of promoting their programs; and will not engage in competitive practices that are unduly predatory and/or destructive to a collaborative marketplace.


MarketingExposing Clients’ Identities for Marketing Purposes

Treatment providers will not exploit their clients’ rights to privacy for the purpose of promoting or marketing their programs.

NAATP members and member organizations hold sacred the shared value of our patients’ rights to privacy. Clients’ identities may not be revealed by a treatment provider – neither in the form of photographic images, video images, media coverage, nor in marketing testimonials – at any time during the client’s engagement in treatment.


“…is filled with disturbing accounts of seriously addicted people getting very limited care at exhaustive costs and with uncertain results - but in my experience, they are accurate accounts.”

A. Thomas McLellan, PhD - Introduction to

Inside Rehab


Complaints Policy and Procedure – Draft Language

Complaints charging members of NAATP with unethical behavior or practices shall be investigated, processed, and resolved in accordance with procedures…

1. Seek informal resolution between parties first2. Formal written complaint to NAATP Ethics Committee

Chair3. NAATP will notify respondent within 10 days4. Ethics Committee must determine if there is “probable

cause” to investigate5. All parties notified, investigation conducted by Ethics

Committee6. Ethics Committee submits findings to Board of Directors7. Respondent may request appearance at next Board of

Directors meeting8. Board of Directors makes final decision and notifies all

parties.


Complaints, Enforcement, Accountability

• Ethical complaints: • Forwarded to member organization CEO• Complainant referred to State Licensing +/or

Accrediting Agency

• Member Accountability: • Proof of valid and current state licensure; new members

& renewals• Member sign off on Code of Ethics; new members &

renewals


Looking ahead…

1. Revise, adopt, and disseminated an update Code of Ethics

2. Communicate with NAATP members and consumers• Prominent placement on NAATP website• Information session at NAATP annual conference• Email blast to NAATP members• Media release to consumer and trade media

3. Education and leadership for NAATP members• Provide ethics panels at future conferences (i.e. NCAD

and NAATP) • Ethics column in quarterly newsletter• Bring gray areas into sharper focus through debate and

discussion


NAATP Annual Conference – May 18, 2014Bob Ferguson, Ethics Committee Chairman


A common sense approach to balancing “mission vs. margin” in the ever-evolving landscape of addiction treatment.

NAATP Code of Ethics - A common sense approach to "mission vs. margin" in the fast-changing...

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