The Center for Health Care Services Corporate Compliance Program

1. The Center for Health Care ServicesCorporate Compliance Program • What is Corporate Compliance? • It is the policy and practice of The Center for Health Care Services (Center) to fully comply with federal, state, and local regulations and applicable laws and to adhere to sound ethical and moral standards in its business activities. The Center demonstrates its commitment through the establishment of a comprehensive compliance program. At its core, this means adhering to fair billing practices, and minimizing fraud, waste, and abuse. • Assists staff in adhering to policies and procedures. • The current CHCS Corporate Compliance policy is available on the Center’s Intranet • Corporate Compliance Is NOT. . . • A replacement for Client Rights • A process to circumvent Human Resources

2. The Center for Health Care ServicesCorporate Compliance Program The CHCS Compliance Officer • Is charged with the responsibility of assembling the compliance efforts of the Center and ensuring its success. • Investigates allegations and reports findings to the President/CEO and the Board of Trustees. • Paul Sisler, Director, Information Services; Corporate Compliance Officer; CHCS Privacy Officer; CHCS Information Security Officer • Corporate Compliance Line - 210-731-1300 ext. 390 CHCS Corporate Compliance Committee • Advises and assists the Corporate Compliance Officer • Reviews all investigations and plans of correction • Attempt to protect the Center from criminal liability and reduce the exposure of its employees to prosecution for white collar criminal offenses.

3. Fair Billing Practices • CHCS will invoice consumers or third parties only for authorized services actually provided to consumers and will provide assistance to consumers seeking to understand the cost of their care. Federal False Claims Act • Under the False Claims Act, 31 U.S.C. §§ 3729-3733, those who knowingly submit, or cause another person or entity to submit, false claims for payment of government funds are liable for three times the government’s damages plus civil penalties of $5,500 to $11,000 per false claim. (www.taf.org)

4. The Center for Health Care ServicesCorporate Compliance Program Texas False Claims Act • Substantially similar to the Federal False Claims act. The actions that trigger civil and criminal penalties under the Texas Act generally mirror those of the Federal False Claims Act. • However, a person may also be liable if he presents a claim for payment under the Medicaid program for a product or service that was rendered by an unlicensed provider or that has not been approved by a healthcare practitioner. • The Civil penalty is greater for unlawful acts that result in injury to an elderly person, a disabled person, or someone younger than eighteen. • For more specific details, the full Act can be found at http://www.taf.org/texasfca.htm Types of Fraud Prosecuted Under the FCA include: • Billing for goods and services that were never delivered or rendered. • Submitting false service records or samples in order to show better-than-actual performance. • Billing for work or tests not performed. • Forging signatures when such signatures are required for reimbursement from Medicare or Medicaid. • Poor, erroneous, incomplete, or absent documentation supporting the claim.

5. All Center work force members(includes all employees, agents, contractors, temp. staff, and affiliates) shall adhere to the policies and procedures set forth by the Center. Those policies and procedures include the Mission Statement, Quality Statement, Vision & Values service policies contained in the Center’s Policies & Procedures, and information contained in the employee handbook . Your Responsibilities as a CHCS employee: • Fully understand the Federal and Texas False Claims Acts • Fully comply with federal, state, and local regulations and applicable laws • Comply with all policies, and relevant laws and regulations, which pertain to their performance of duties. Staff is expected to participate in periodic training and to demonstrate familiarity with Center policies, laws and regulations relevant to their duties. • Adhere to sound ethical and moral standards in all your business/clinical activities.

6. Adhere to sound ethical and moral standards in all your business/clinical activities: • All consumers, employees, contractors, and visitors deserve to be treated with dignity, respect, and courtesy. • We will fairly and accurately represent our capabilities and ourselves. • We will provide services to meet the identified needs of our consumers and will constantly seek to avoid the provision of those services which are unnecessary. • We will follow applicable industry practices throughout the organization. • Know what the policies and procedures are. • Comply with Center and government requirements regarding record keeping. All records must be prepared accurately and retained. • Report information truthfully - all Center business related statements, verbal or written, must be accurate, timely, and reported in good faith. • Report any activity they reasonably believe is in violation of any law, regulation, policy, or ethical standard. • Failure to do so in a timely manner could result in disciplinary action.

7. Where do you Report Possible Violations? • Supervisor 2. CHCS Corporate Compliance Officer– Paul Sisler E-mail: compliance@chcsbc.org Mail or in person: The Center for Health Care Services ATTN: COMPLIANCE OFFICER 3031 IH10 West, San Antonio TX 78201 Phone: (210) 731-1300 ext. 390 3.The Department of Health & Human Services: Mail to: Office of Inspector General Department of Health and Human Services ATTN: HOTLINE 330 Independence Ave., SW, Washington DC, 20201 Phone 1-800-HHS-TIPS (800-447-8477) E-Mail: HHSTips@oig.hhs.gov References • Texas Health & Safety Code §§ 534.001 et. seq. • Texas Local Government Code §§ 171.001 et. seq. • Federal Sentencing Guidelines • Department of Health and Human Services Office of the Inspector General (OIG) Compliance Guidelines • Performance Contract with the Texas Department of State Health Services

9. The Center for Health Care Services Corporate Compliance Acknowledgement / Ethics Statement WHEREAS, The Center For Health Care Services provides and bills services under programs and agencies, such as but not limited to, Medicare, Medicaid, CHAMPUS, Texas Dept. of State Health Services (DSHS), Texas Commission on Offenders with Medical or Mental Impairments (TCOOMMI), Early Childhood Intervention (ECI); and WHEREAS, there is a need to prevent and detect violations of the rules, laws and regulations that govern these funding sources; and WHEREAS, The Center receives State and Federal funding for provision of services to children and adults who are challenged with substance abuse, mental retardation/developmental disabilities, and mental illness issues; NOW THEREFORE BE IT RESOLVED THAT I SHALL: • obey the law, adhering to all laws and regulatory requirements that apply to The Center For Health Care Services; • prepare accurate records and maintain them according to requirements; • report information truthfully; • employ fair billing practices; and • disclose the appearance of or any potential conflicts of interest. BE IT FURTHER RESOLVED, THAT I SHALL: • treat all consumers, employees, contractors, and visitors with dignity, respect and courtesy, • fairly and accurately represent our capabilities and ourselves; • provide services to meet the identified needs of our consumers, and will constantly seek to avoid the provision of those services, which are unnecessary. • follow applicable industry practices; and • when in a supervisory position, be responsible to see that the employees I supervise understand the importance of and follow this compliance program. _____________________________ ___________ Printed Name Employee ID# _________________________ ___________ Signature Date (Please read, sign, and return to Human Resources & Development)