Synergy Partners, LLC Corporate Compliance Training

1. Synergy Partners, LLCCorporate Compliance Training July 10, 2014 Debra Schuchert, Compliance Officer

2. Synergy Partners, LLCCorporate Compliance Program It is the policy of Synergy to comply with all laws governing its operations and conduct business in keeping with legal and ethical standards. It is also the policy of Synergy to deal with employees and customers using the highest clinical and business ethics. Synergy strives to maintain a corporate culture which promotes the prevention, detection, and resolution of possible violations of laws and unethical conduct. Synergy supports the government in its goal to decrease financial loss from false claims and has as its own goal, the reduction of potential exposure to criminal penalties, civil damages, and administrative actions. Synergy believes that a compliance program guides the Management Board, President/CEO, managers, employees, and health professionals in the efficient management and operation of the company and in improving the quality of its services.

3. Corporate Compliance ProgramElements • Synergy maintains written standards, a Code of Conduct, a Risk Management Plan and Compliance policies and procedures. • Synergy has a Compliance Department consisting of staff responsible for compliance efforts, Corporate Compliance Committee, and affiliate Compliance officials. The Corporate Compliance Committee conducts quarterly meetings. • Synergy conducts education and training programs for employees and maintains an Ethics Hotline (866) 724-7544 (24 hours a day, seven days a week) DWMHA Compliance Hot Line (313) 833-3502 (24 hours a day, seven days a week) to foster an open atmosphere for employees to report issues and concerns free from retaliation. • Synergy may use audits or other evaluation techniques to monitor compliance with identified risk area.

4. Corporate Compliance ProgramElements • Synergy maintains a system and procedures to respond to allegations and detected offenses. If it is determined that there is a current deficiency or area of non-compliance, the development of a corrective action plan is completed to resolve the issue. • Synergy educates and trains its employees on the requirements for the Compliance Program, and the disciplinary policy for employees who violate the compliance policies and applicable laws. Disciplinary action may include oral warnings, suspensions, and termination of employment depending on the circumstances and severity of the violation. • Synergy believes that compliance with the law means not only following the law, but also conducting business so the Company deserves and receives recognition as good and law-abiding corporate citizens. The goal is to inspire confidence from clients, consumers, employees, the community, and our government.

5. Corporate Compliance Policies • CC-001 - Synergy Partners Corporate Compliance Department • Ensure important aspects of Compliance are monitored • CC-002 - Confidentiality Maintain confidentiality of Synergy information & integrity of compliance program • CC-003 - Synergy Internal Corporate Compliance Investigation Respond to and investigate possible violations of applicable federal, state or local law and non-compliance with Synergy’s Code of Conduct • CC-004 - Responding to a Governmental Inquiry or Investigation Guidelines for responding to both federal and state government investigations • CC-005 – False Claims Compliant with federal / state law and regulations related to the billing & payment of claims involving federal, state or private programs • CC-006 – Omnibus rules as related to Anti-Kickback, Self Referral, and Stark Laws Guidelines for Synergy to comply with federal and state anti-referral and anti-kickback laws and regulations • CC-007 – Compliance Record Storage Retention Guidelines for the retention of documents related to the Compliance program

6. Corporate Compliance Facts • Possible penalties for NON-Compliance include the following: Imprisonment , Fines, & Termination of Employment • Compliance is the responsibility of: • Compliance Officer , Federal Government, and Employee • The following constitutes the filing of a false claim – knowingly and willfully submit: • Up-coding the level of service provided • Improper documentation practices • Double billing resulting in duplicate payment • Failure to properly use coding modifiers • Billing for items or services not rendered or not provided as billed • Submit false information • Failure to refund credit balances

7. Corporate Compliance Facts • Who is liable under the False Claims Act? Any person or entity connected with the submission of a false claim can be liable, including; Providers Beneficiaries Health plans that do business with the Federal government Billing companies Contractors • If a concern or question about compliance arises, you should: • Ask the Compliance Officer, Manager, or notify Compliance Officer anonymously • Anti-Kickback – Federal Penalties: Criminal Penalties: - Criminal Statue-felony charges (5yrs and /or $25k Fine) - Potential financial liability under False Claim Act Civil Money Penalties: - Loss of Medicare & Medicaid provider status - Civil Monetary penalties of $ 50K per act, plus damages equal to 3x remuneration involved.

8. Corporate ComplianceFacts • Compliance programs and claims may be audited by : • Recovery Audit Contractors (RACs) hired by the Federal government and State of Michigan contractors. Medicaid Recovery Audit Contractor Programs (RAC’s) A directive of the Affordable Care Act (ACA) is a provision that requires states to expand their Recovery Audit Contractor Programs (RACs) to prevent provider fraud, waste, abuse and improper payments, and to take administrative action to recoup overpayments as may be necessary. Medicare has been successfully conducting audits and is now increasing the spread of these recovery audits to Medicaid. It is believed that the Affordable Care Act requires the States to up their examinations of Medicaid accounting , which could result in recovering a total of nine to ten billion dollars for the government.

9. Corporate ComplianceFacts • Things that should be reported: Violations of law Inappropriate gifts, entertainment or gratuities Improper use of Authority property Violations of patient confidentiality Discrimination or harassment Stealing/Misuse of assets Embezzlement of funds Obstruction of Criminal or Internal Investigations

10. Office of Inspector General (OIG) Audits • The OIG distributes an annual work plan that lays out the areas that will be targeted during an audit. In addition, to our annual onsite audits, the following audits will be conducted according to the OIG work plan -2014. • Audits: • OIG “monthly” Employee Exclusion Search • Unallowable Room & Board Charges • Community Supports while consumer is in the hospital • Skill Building • Adult Foster Care Employee Training • Adult Foster Care Reimbursement for Community Living Support Services & Personal Care • Supported Independent Living Providers • Direct Care Wages • Ability to Pay • Claims & Billing • HIPAA Security • Annual Compliance Training for Employees and VCE Online Training course • Respite • Audit Forms: • Compliance Statement - Synergy requires each provider to sign the Compliance Statement as proof that the provider is maintaining Compliance standards and trainings within their organization. • Compliance & Breach Notification on Protected Health Information and Personal Record Information Statement – Synergy requires each provider to sign the statement as proof that the provider is maintaining policies and procedures to safeguard Protected Health Information (PHI) and Personal Record Information (PRI). • Documentation Statements - Synergy requires providers to have documentation complete, accurate, and available upon request for a provider or consumer audit. If an onsite audit is conducted there is a 24 hour time frame to produce documentation if not already available. A sampling of provider services audit requires a 48 hour time frame to produce documentation if not already available.

11. Office of Inspector General (OIG) Audits • Audit Forms: • OIG Employee Exclusion Search - The employee exclusion search must be performed on a monthly basis. • Compliance Statement - Synergy requires each provider to sign the Compliance Statement as proof that the provider is maintaining Compliance standards and trainings within their organization. • Compliance & Breach Notification on Protected Health Information and Personal Record Information Statement – Synergy requires each provider to sign the statement as proof that the provider is maintaining policies and procedures to safeguard Protected Health Information (PHI) and Personal Record Information (PRI). • Documentation Statements - Synergy requires providers to have documentation complete, accurate, and available upon request for a provider or consumer audit. If an onsite audit is conducted there is a 24 hour time frame to produce documentation if not already available. A sampling of provider services audit requires a 48 hour time frame to produce documentation if not already available. This does not apply to providers that have started a new program. Documentation must be present upon request.