Corporate Compliance

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Maintaining the highest standards of corporate compliance

SCP Health (SCP) is firmly committed to the highest standards of ethics, integrity, professionalism, and compliance. Our Corporate Compliance Program includes auditing and monitoring, enhanced lines of communication between the Chief Compliance Officer and team members, consistency in the standards we set for ethics and compliance, and increased awareness of these standards through a vigorous corporate compliance training and education program. In everything we do, our actions and decisions are aligned with our mission and core values. We are committed to doing the right thing every time—with integrity.

Code of Conduct

Our company Code of Conduct provides guidance to team members on carrying out daily activities within appropriate ethical and legal standards.

Code of Conduct was developed to help ensure we meet our ethical standards and comply with applicable laws, rules, and regulations. It is a critical component of our overall Corporate Compliance Program and is an important resource for our team members.

The Code of Conduct includes potential consequences affecting both the company and our team members for failure to comply with all statutes, regulations, and guidelines applicable to federal and state healthcare programs. The standards set forth in the Code are mandatory and should be applied in all decision-making. The business practices that are addressed in the code include, but are not limited to:

• Accuracy of records and document retention
• Anti-Kickback Statute
• Coding and billing
• Confidential business information
• Conflict of interest
• Corporate opportunities
• Emergency Medical Treatment and Active Labor Act (EMTALA)
• False Claims Act and Deficit Reduction Act (whistleblower provisions)
• Financial accounting systems
• Gifts and business courtesies
• Harassment/discrimination prevention
• Health Insurance Portability and Accountability Act (HIPAA)
• Information technology and resources
• Political and charitable activities
• Privacy of patient information
• Professional licensing
• Requests for information pursuant to an investigation or legal proceeding
• Stark Law
• Team member screening
• Use of resources and assets
• Workplace health
• Workplace safety
• Workplace violence

All company team members are encouraged to conduct themselves in a way that supports the highest standards of ethics and integrity and to follow the standards set forth in our Code of Conduct and our policies and procedures.

Training and Education

Team members must have Corporate Compliance training upon hire or contracting and annually thereafter. Each employee, including contractors, must receive, acknowledge, and attest to the Code of Conduct. We also require annual training on the Code of Conduct, policies and procedures as well as pertinent laws, regulations, payor rules and high-risk areas impacting our business.

Additional specialized training is assigned in areas such as HIPAA Privacy and Security, EMTALA, fraud and abuse, and harassment and discrimination prevention. Corporate and clinical compliance training is delivered through webcasts, online courses, and instructor-led sessions. Training is tracked in the company’s learning management system.

We have a full suite of corporate compliance policies and procedures. We perform a routine review and revision of our policies and procedures to stay abreast of both internal and external developments. Team members receive and review updated policies and procedures, specifically those that are directly related to job function and accessible through company portals.

Auditing and Monitoring

Our company has developed extensive auditing and monitoring of all service lines to assess internal controls and processes for compliance with all applicable laws, rules, and regulations. The Office of the Inspector General has published areas of concern, and our compliance department has developed an annual work plan along with audit tools for each area of concern to assist in evaluating our company’s risk for each of these areas. SCP compliance professionals work in conjunction with other departments to accomplish the necessary goals and objectives of our Compliance Program.

Privacy and Security

Our company is committed to maintaining the confidentiality, privacy, and security of its patients’ Protected Health Information (PHI). Consistent with the Health Insurance Portability and Accountability Act (HIPAA), we only access, use, or disclose PHI, including patient financial information, for purposes of treatment, payment, operations, with appropriate patient authorization or when required by law. .

We are committed to being conscientious and accountable when handling confidential company information. In addition, because of its confidential nature, business, health, and financial information must be protected by an effective internal control environment, including policies and procedures to secure the company’s assets, and made available outside the company only with appropriate authorization and after consideration of the interests of the company as a whole.

Protecting the company’s information assets is everyone’s responsibility. Examples of confidential information include:

• Company financial information, including financial statements, payroll records, accounts payable summaries, vendor listings, and price/cost information
• Customer lists and agreements, market share data, and strategic plans
• Due diligence information about potential acquisitions
• Patient’s protected health information
• Policies, procedures, and processes
• Trade secrets
• Written and verbal agreements between team members, agents, strategic partners, vendors, and/or other third parties

Confidential Compliance Hotline

Our company’s Compliance Hotline provides a confidential and anonymous line of communication for anyone, including team members, to report complaints or concerns. Individuals may contact the Compliance Hotline 24 hours a day, seven days a week, at 1-800-934-4069 or via www.SCPHealthHotline.com. The toll-free telephone number is hosted by an independent third-party vendor.

Our company makes every effort to maintain, within the limits of the law and within the bounds of an appropriate investigation, the confidentiality of the identity of any individual who uses the Compliance Hotline. There will be no retaliation or retribution for anyone who reports a possible violation in good faith.

Compliance Oversight

The success of our corporate healthcare Compliance Program relies on high-level oversight from our Board of Directors as well as buy-in, support, and accountability from team members. Listed below are the committees and individuals who support our Compliance Program.

• The Audit Committee and the Quality and Compliance Committees of our Board of Directors provide regular guidance regarding the direction of the company’s Compliance Program. In addition, the committees receive regular reports on the status of the Compliance Program. Our Chief Compliance Officer has a direct reporting line to the committees.
• The Corporate Compliance Committee monitors the Compliance Program. It is composed of a cross-section of SCP team members across varying levels and key departments.
• Our Chief Compliance Officer oversees the Compliance Program and evaluates compliance issues/concerns within the organization. The Chief Compliance Officer helps ensure that the Board of Directors, management, and team members are in compliance with the rules and regulations of regulatory agencies, that company policies and procedures are being followed, and that behavior in the organization meets the company’s Code of Conduct.
• Each team member has a shared responsibility and commitment to our mission of healthcare service to our patients. Compliance is the responsibility of every team member, as is to always conduct job responsibilities with integrity and to make all clinical decisions based solely on the needs of the patient.

Emergency Medical Treatment and Active Labor Act

EMTALA (Emergency Medical Treatment and Active Labor Act) compliance involves the understanding and interpretation of multifaceted concepts involving the issue of when and how a patient may be refused treatment or transferred from one hospital to another when he or she is in an unstable medical condition. The intent of EMTALA was to ensure patient access to emergency medical care and to prevent the practice of patient dumping, in which uninsured patients were transferred because they could not pay for services provided and were transferred from private to public hospitals without consideration of their medical stability.  It is company policy that all individuals presenting to the emergency department receive an appropriate medical screening examination upon presentation and/or request for treatment. All patients are stabilized within the capability and capacity of the facility and, as needed, appropriately transferred. All employees and providers complete EMTALA training upon hire or contract commencement and annually thereafter. We work with our hospital clients to ensure that our providers are in compliance with the requirements of EMTALA.

Additional Compliance Policies and Statements

• SCP Health complies with applicable Federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, or sex. View the Nondiscrimination Statementfor information on services available to our patients.
• Notice of Privacy Practice