Home About Vibra Healthcare Our Services Patient Resources Locations Careers DEI Partnerships Contact Us Corporate Compliance & Privacy Practices Corporate Compliance Plan Summary. Adopted by The Managers: 10.2013 Introduction Vibra Healthcare, LLC’s (“Vibra”) Corporate Compliance Plan has been developed in accordance with applicable law and policies issued by state and federal authorities. Through the Plan, Vibra will promote full compliance with all legal duties applicable to it and its employees, foster and assure ethical conduct, and provide guidance to each employee and agent of Vibra for their conduct. The procedures and standards of conduct contained in the Plan are intended to generally define the scope of conduct which the Plan is intended to cover and are not to be considered all-inclusive. The important provisions of Vibra’s Corporate Compliance Plan are summarized in this brochure. If you have any questions regarding these provisions, or wish to view a full copy of the Plan, please contact your Facility Compliance Coordinator or the Vibra Corporate Compliance Officer. Corporate Code of Conduct Vibra has a reputation for conducting its activities in accordance with the highest level of business and community ethics, and in compliance with applicable governing laws. The maintenance of extremely high standards of honesty, integrity, impartiality, and conduct is essential to assure the retention of the patients’ and the public’s trust in Vibra. The preservation of that trust and of Vibra’s reputation requires close observance of these standards on the part of its Managers, Officers, employees and agents. Vibra is committed to ensuring that it operates under the highest ethical and moral standards, and that its activities comply with the applicable legal requirements in this Plan. Vibra has developed a Code of Conduct to provide standards by which all Vibra employees will conduct themselves in order to protect and promote organization-wide integrity, and to enhance Vibra’s ability to achieve its mission. Compliance with the Code of Conduct will be the responsibility of every manager, officer, employee, agent or representative of Vibra. Vibra’s Code of Conduct provides the guiding standards for our decisions and actions as members of the Vibra community. The Code cannot cover every situation in the daily conduct of our many varied activities nor substitute for common sense, individual judgment or personal integrity. Listed below are the guiding principles of Vibra’s Code of Conduct. Principle 1: Integrity Principle 2: Legal Compliance Principle 3: Business Ethics Principle 4: Confidentiality Principle 5: Conflict of Interest Principle 6: Business Relationships Principle 7: Protection of Assets Principle 8: Reporting Misconduct Principle 9: Relationships with Patients Vibra will strive to ensure integrity in all activities conducted by or on behalf of the organization, and promote honesty in all levels of interaction within the organization. Corporate Compliance Officer and Committee Vibra’s Corporate Compliance Plan will be implemented under the guidance and supervision of the Corporate Compliance Officer and a Committee consisting of the upper-level Managers of the organization. In addition, each Vibra facility will have its own Facility Compliance Coordinator to help put the Plan’s provisions into practice. These individuals will be responsible for developing policies and practices designed to ensure that each Vibra facility meets the compliance standards set forth in the Plan. The Facility Compliance Coordinators and the Corporate Compliance Officer will be accessible to all Vibra employees. Training and Education The key to maintaining compliance with applicable law is to ensure that Vibra personnel receive training and education to enable them to identify potential fraud and abuse issues, and conform their conduct to the applicable requirements of law. The Plan requires Vibra to provide employees with the training necessary to ensure compliance with applicable federal and state laws and regulations. Accordingly, Vibra will schedule periodic and annual training for employees on the requirements of the Plan itself, as well as other substantive areas relating to their job functions. Policies, Procedures, and Protocols Vibra and its Facilities have already adopted numerous policies and procedures to provide the best care possible to our patients and to ensure that operations are conducted in accordance with law. Those policies will continue to remain in place under the Plan. The Corporate Compliance Officer and the local Facility Compliance Coordinators will also coordinate the development of specific policies designed to address recordkeeping, contracting, billing, reimbursement and clinical issues as well. Vibra’s policies and procedures will be regularly reviewed to assess their effectiveness. When appropriate or required, the Corporate Compliance Officer will direct revisions to these policies and procedures to correct errors, to make operations more efficient, or to improve the quality of care provided to our patients. Compliance Reporting Obligations and Investigations As reflected in the Code of Conduct, each and every employee of Vibra is required to report all instances of suspected misconduct or potential violations of law to the Corporate Compliance Officer. This can be done anonymously through the Hotline established by Vibra. The Hotline number is 888-238-7185. Employees may also report potential compliance issues to their supervisors or the Facility Compliance Coordinator. Vibra’s Corporate Compliance Officer will review all reports received by the company, and will conduct an appropriate investigation into all instances of claimed misconduct or noncompliance. Vibra employees are required, when requested, to assist the Corporate Compliance Officer in these investigations. At the conclusion of an investigation, the Corporate Compliance Officer, in conjunction with Vibra’s legal counsel, will implement corrective action initiatives and, where required, make the appropriate disclosures to governmental agencies. It is important to emphasize that Vibra will not tolerate retaliation against employees or agents who report suspected abuse in good faith, nor will Vibra allow abuse of its reporting processes. Self-Monitoring and Auditing Vibra recognizes the need to monitor and audit its operations to determine the effectiveness of this Plan’s implementation and the company’s overall compliance with applicable law. The Corporate Compliance Officer will supervise all auditing systems, conducting periodic and annual audits of Vibra’s facilities and its employees. Audit procedures will be implemented which are designed to determine accuracy and validity of coding and billing submitted to Medicare and other federal health programs, to ensure compliance with Medicare Conditions of Participation, and to detect other instances of potential noncompliance by Vibra employees and agents as quickly as possible. Auditing techniques will include on-site visits, mock surveys, sampling reviews of claim submissions, and interviews of key personnel. Each audit will generate a Compliance Report, which shall be forwarded to the Corporate Compliance Committee and the Vibra Managers for review and action. Employee, Officer, and Manager Duties Under the Plan Promotion of and adherence to the Plan shall be an element of each Vibra employee’s performance standards. Each employee’s compliance performance will be taken into account in connection with performance evaluations. Managers and supervisors have the additional responsibility to ensure that persons under their supervision are advised of their responsibilities under the Plan and under applicable laws and regulations. Conduct in violation of this Plan is outside of the scope of an employee’s job responsibilities and authority and may subject the employee to disciplinary action, including suspension, imposition of monetary penalties or termination. Appropriate disciplinary measures shall be imposed on a case-by-case basis, and shall be consistent with the disciplinary scales contained in the Employee Handbook. Most Important Concepts under Vibra’s Corporate Compliance Plan Be honest, tell the truth and act in accordance with the provisions of Vibra’s Code of Conduct. There are consequences for failing to do so. Be aware of the laws and regulations that govern your job responsibilities and follow them. Ask questions if unsure of the applicable legal requirements before taking action. Report suspected misconduct or potential compliance issues to your supervisor, the Facility Compliance Coordinator, or the Corporate Compliance Officer through the Hotline at 888-238-7185. Assist in the development of policies and procedures designed to enhance Vibra’s operations and fully cooperate in all self-auditing and monitoring activities. Participate in Vibra’s educational training sessions on compliance. Make compliance a part of your day-to-day job performance. 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