1. INTEGRATED CARE ALLIANCE, LLC CORPORATE COMPLIANCE TRAINING DEBRA SCHUCHERT, COMPLIANCE OFFICER

2. INTEGRATED CARE ALLIANCE, LLC CORPORATE COMPLIANCE PROGRAM It is the policy of Integrated Care Alliance to comply with all laws governing its operations and conduct business in keeping with legal and ethical standards. It is also the policy of Integrated Care Alliance to deal with employees and customers using the highest clinical and business ethics. Integrated Care Alliance strives to maintain a corporate culture which promotes the prevention, detection, and resolution of possible violations of laws and unethical conduct. Integrated Care Alliance 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. Integrated Care Alliance 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 PROGRAM ELEMENTS  Integrated Care Alliance maintains written standards, a Code of Conduct, a Risk Management Plan and Compliance policies and procedures.  Integrated Care Alliance 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.  Integrated Care Alliance 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.  Integrated Care Alliance may use audits or other evaluation techniques to monitor compliance with identified risk area.

4. CORPORATE COMPLIANCE PROGRAM ELEMENTS  Integrated Care Alliance 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.  Integrated Care Alliance 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.  Integrated Care Alliance 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 - Integrated Care Alliance Partners Corporate Compliance Department Ensure important aspects of Compliance are monitored  CC-002 - Confidentiality Maintain confidentiality of Integrated Care Alliance information & integrity of compliance program  CC-003 - Integrated Care Alliance Internal Corporate Compliance Investigation Respond to and investigate possible violations of applicable federal, state or local law and non-compliance with Integrated Care Alliance’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 Integrated Care Alliance 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. WHAT MAKES A CLAIM “FALSE” ?  Factually False Claims : A factually false claim means that the services on the bill did not actually happen. This type of false claim can take the form of billing for services not provided,billing for more expensive services than those actually rendered (called up coding), double-billing for services, or billing for services that were medically unnecessary, even if they were actually performed.  Legally False Claims: A legally false claim occurs when the circumstances of the services on the claim or the claim itself create or reflect a violation of an underlying law or regulation. For example, claims for physician services rendered pursuant to an arrangement that violate the Stark Law (prohibiting self-referrals) or the Anti-Kickback Statute are legally prohibited and are thus ‘false’, if made knowingly. The submission of the claim itself is evidence of the provider’s implied certification that the claim is valid, such that even if the provider (or biller) has not affirmatively represented that the claims are legally compliant, submitting legally invalid claims is generally viewed as knowing misrepresentation under the False Claims Act (FCA).  Reverse False Claims: A reverse false claim is failure to return overpayments (made by the Federal Government) within the 60 day time frame imposed in 2010 by the Affordable Care Act (ACA). The ACA added a requirement that all overpayments be returned to the government within sixty days of when the claim is “identified”, and if not reported creates a False Claims Act liability for failing to do so. The Centers of Medicare and Medicaid Services (CMS) has issued proposed rules on the subject.  Payment for a False Claim is a felony, punishable by imprisonment for not more than 10 years, or by a fine of not more than $50,000, or both.  False Claims Training form should be signed by the MCPN staff and contracted Providers.

8. 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.

9. CORPORATE COMPLIANCE FACTS Compliance programs and claims may be audited by Recovery Audit Contractors hired by the Federal Government and State of Michigan Contractors. 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. The Affordable Care Act requires the return of any Federal Health-Care program overpayment no later than 60 days after the overpayment is identified. 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.

10. CORPORATE COMPLIANCE FACTS  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

11. 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 -2015. 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 - Integrated Care Alliance 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 – Integrated Care Alliance 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 - Integrated Care Alliance 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.

12. 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 - Integrated Care Alliance 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 – Integrated Care Alliance 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 - Integrated Care Alliance 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, their documentation must be present upon request.