1. Eliada Homes Inc. Corporate Compliance

2. Prevent fraud, abuse and improper activity. Detect any misconduct early. Respond swiftly through appropriate corrective actions. Create culture of compliance.

3. Operate within strict compliance with laws and regulations. High ethical and professional standards.

4. Code of Conduct Compliance Officer (VP) and Committee oversight Compliance training for staff Mechanisms for reporting compliance problems System of internal compliance audits and reviews Procedures for corrective action and/or disciplinary measures

5. Code of Conduct Proper Billing that ensures Eliada does NOT Bill for students not served Bill twice for same service Bill at excess rates Bill for service we know was billed by another provider Bill Medicaid as primary when we know student has PHI

6. Providing Access to Necessary Services Cannot restrict access in bundled services Submitting Complete and Accurate Reports Accurate and complete cost finding reports

7. Avoiding Kickbacks and Referral Fees Illegal to pay for referrals Includes services from vendors Avoiding Conflicts of Interests Staff and Board Cannot use our positions for personal benefit

8. Using Eliada Resources for Eliada Business Only Cannot use facilities/equipment for personal benefit Or to promote business, charity, or political cause Using Eliada Resources Exclusively for Charitable Purposes Cannot use our resources to engage in business outside Eliada’s purposes

9. Ensuring Equal Opportunity for all Clients, Employees, and Contractors Cannot discriminate based on race, nationality/ethnic background, religion, gender, disability Cannot discriminate in hiring or treatment of staff No tolerance for sexual harassment of clients or staff

10. Maintaining the Confidentiality of Client Records HIPAA Limits the use and disclosure of protected health information Conduct Business with Honesty and Integrity Act in a manner that promotes Eliada’s reputation as an agency that exceeds requirements of the law and operates with highest ethical standards

11. Compliance Officer (VP/Performance Improvement) Review and update Code of Conduct Oversight of Compliance Hotline Receive and investigate compliance complaints Ensure reporting of violations Training of staff Evaluate effectiveness of Compliance Program Develop compliance policies/procedures

12. Compliance Committee Eliada Homes Board of Trustees Ultimate authority for governance of Eliada including compliance with applicable laws.

13. Staff Responsibility Follow all Compliance Code of Conduct Report compliance problems: Supervisor. Compliance Officer. Compliance Hotline. Fraud, abuse, and improper activities Participate in and cooperate with internal audits and reviews Cooperate with any investigations

14. Corrective Actions Quality Improvement: training, revise procedures, seek interpretation of laws/regulations. Self disclosure/reporting Return overpayments or other funds Employees who engage in fraud, abuse, or other misconduct are subject to disciplinary actions.

15. COMPLIANCE Integrity Excellence Teamwork Faith, Hope & Love