CAMcare Health Corporation Corporate Compliance Program

1. CAMcare Health CorporationCorporate Compliance Program

2. Corporate Compliance • Purpose: • To establish a system of internal controls designed to ensure that we regularly evaluate and monitor our own adherence to applicable statues, regulations and program requirements

3. High Risk Areas for Health Centers • Billing and Coding • Grants Management • Internal Controls • Information Management • Tax Issues • Cost Reporting and Regulatory Filings

4. Elements of Effective CCP • Designate Corporate Compliance Officer and Committee • Develop and Implementation of Compliance & Practice Standards • Conduct Training & Education • Establish open lines of communication • Conduct Internal Monitoring and Auditing • Establish Process for Responding to Potential Offenses • Establish Disciplinary Standards

5. Corporate Compliance Committee • Corporate Compliance Officer • Medical Director • Nursing Director • Billing Director • Finance Director • MIS Director

6. Implementation of Compliance & Practice Standards • Establishment of policy to promote compliance • Develop written policies and procedures that establish guiding principles or courses of action for staff • Policies and procedures must be consistent with the requirements and standards established by health center’s BOT and all regulatory and accrediting organizations

7. Training and Education • Develop and provide ongoing education and training for BOT and Staff regarding the Compliance Program • All BOT and Staff will receive a General Compliance training • Specialized training for staff (ie. Staff with direct responsibility for coding and billing) • Focused training for areas identified in an audit to be potentially problematic

8. Open Lines of Communication • Establish a toll free hotline for reporting issues and concerns relating to compliance • Ensure that the telephone number is publicized in a common staff work area (ie. Break room, lunchroom)

9. Internal Auditing and Monitoring • Conduct periodic self audits to assure • Written standards and policies are in compliance with the law • Operating in compliance with written policies and procedures • Coding and billing are accurate with services provided • Documentation is accurate and complete • Furnished services are reasonable and necessary

10. Response to Detected Offenses • Upon receiving a report of suspected non-compliance, the Compliance Officer will initiate steps to investigate the conduct in question • Interviews of persons with knowledge of the matter • Review of relevant documents and applicable laws • Engage legal counsel, external auditors, or health care experts to assist in the investigation if necessary

11. Establish Disciplinary Standards • Establish and publish procedures for enforcing and disciplining individuals who violate the law • Disciplinary guidelines should be well publicized • Trainings • Policy and Procedure • Employee job descriptions • Employee handbook • Standards of Conduct

12. Why Corporate Compliance? • Mandatory • Establishes a program to identify and respond to organizational risks • Identifies and addresses gaps in existing practices,policies and procedures • Program will deter potential fraudulent activity