Valley Health Plan Code of Conduct

Compliance consist of regulations mandated by the federal and state government to assure that organizations such as Valley Health Plan (VHP) follow all applicable laws in coordinating and paying for healthcare services. VHP being under the umbrella of Santa Clara County Health and Hospital Systems adheres to the same philosophy and Code of Conduct.

  • VHP affirms that the public has placed its trust in each employee, and honoring that trust means that each employee is obligated to perform his or her duties in a manner that maintains the trust and confidence of Santa Clara County residents and others; 
  • VHP’s mission is to provide leadership in developing and promoting a healthy community through a planned, integrated healthcare delivery system which offers prevention, education and treatment programs to its enrollees; 
  • In support of its mission, VHP personnel shall treat all enrollees with respect, dignity and professionalism without regard to race, age, gender, religion, national origin or sexual orientation; 
  • VHP personnel will follow the Code of Conduct, and in doing so will not lie, cheat or participate in illegal activities while carrying out their job responsibilities; and 
  • VHP personnel will follow all federal, state, county and local laws and regulations in the performance of their duties, and when uncertain about the laws and regulations, they will take the steps necessary to ensure that they are performing their duties as accurately as possible.

Protected Health Information

VHP is very serious about your Protected Health Information (PHI) that staff has access to. Information is shared on a need-to-know basis only and discussions regarding PHI are not held in common areas. Staff are trained upon hire about protecting PHI and all the safeguards around oral, written, and electronic access. All written documents that contain PHI are kept locked when not in immediate use. When no longer needed, written PHI is placed in locked shred bins. All electronic PHI is safeguarded with passwords particular to employees who need access to perform job functions, and these passwords must be periodically changed. VHP has firewalls and monitors access to the system to prevent inadvertent loss of PHI. Inappropriate access or use of PHI by employees may result in immediate dismissal from VHP.

Affirmative Statement About Financial Incentives

Valley Health Plan affirms that:

  1. Utilization Management (UM) decision making is based only on appropriateness of care and service and existence of coverage.
  2. The Plan does not specifically reward practitioners or other individuals for issuing denials of coverage.
  3. Financial incentives for UM decision makers do not encourage decisions that result in underutilization.

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