Business Ethics & Compliance Policy

✓ Amada Senior Care of South Jersey (ASCOSJ commits to maintaining highest ethics, compliance with laws, regulations, and service standards in relation to business operations and practices and direct service to customers.

✓ All policies and leadership conduct shall ensure compliance with applicable laws, regulations, and accreditation standards to ensure operations in an ethical manner.

Policy Guidelines:

1. It is the determined policy of ASCOSJ and its employees to adhere to sound and lawful business practices and comply with all program requirements, regulations, and guidelines.

2. The Agency shall cooperate with all reasonable and lawful demands made by governmental investigations or law enforcement agents. Written, copied or electronic documentation is not to be altered or destroyed in anticipation of a request or as a result of a request for those documents by any authorized, lawful investigation.

3 The Governing Authority has final judgment on all business ethics and compliance decisions.

4 The Governing Authority will review the BEC plan and its findings annually through the reports made by the appropriate Committee.

5 The Governing Authority shall appoint an independent Compliance Officers and charge the Professional Advisory Committee with advising the Governing Authority on compliance and ethical issues and overseeing the ASCOSJ compliance program. The independent compliance officer name shall be made public for Clients and employees.

6 The Governing Authority shall annually review all reported violations or incidents of misconduct and compliance, the findings of all internal audits to include admissions, reimbursement, accounts receivable, delinquent accounts, and staff expenses. The Governing Authority shall have final judgment on all business ethics and compliance decisions.

7 Annual reports to the Governing Authority on incidents of misconduct or violations are prepared and evaluated.

8 ASCOSJ has adopted a Code of Ethics that clearly outlines expected conduct and is displayed in office.

9 BEC compliance plan shall include the elements involved in plan oversight, monitoring and evaluation, distribution of the plan to employees and clients, reporting procedures, and establish the approach to outside investigations as well as the provision for enforcement of the plan.

10. It is the determined policy of ASCOSJ and its employees to adhere to sound and lawful business practices and comply with all laws, regulations, accreditation standards and guidelines. Therefore, a Business Ethics and Compliance Plan (BEC) has been established for employee conduct and delineates the consequences for failure to adhere to the accepted ethics and compliance practices within ASCOSJ

11. This policy statement will be distributed to the public and referral sources annually and to all clients at admission.

12. A Code of Ethics is provided each employee, which includes the assignment to the appropriate level of care, excluding unauthorized employees from performing personal care.

13. New employees will be informed of the BEC Plan during orientation. Documentation will be placed in their personnel record.

14. All reports of misconduct or violations of law are to be considered serious and are to receive immediate attention with a full investigation. Reports of any misconduct, unethical business

practice or violation of laws and accreditation standards and guidelines can be made by anyone.

15. Each occurrence must be reported in writing to the Chief Executive or Compliance Officer and include the name of the accused person(s), act(s), and date(s) of the suspected violation. The Chief Executive will meet with the staff member(s) making a report of misconduct or violation of the law as the first step in the investigation process. All reported incidents are investigated within five (5) days of the report, including those reported by the Compliance Officer.

16. Reports of misconduct, safety concerns or violation can be made by anyone within the prescribed procedure, including licensing and/or regulatory agencies, the Compliance Officer and are held in confidence.

17. Employees shall be protected under the Conscientious Employee Protection Act (CEPA Law) which prohibits taking any retaliatory action against any employee because the employee in good faith ASCOSJ discloses or threatens to disclose violations of law, unethical, or fraudulent acts.

18. ASCOSJ will cooperate with all reasonable and lawful demands made by government investigators or law enforcement agents and no documents will be altered or destroyed in anticipation of a request by a lawful investigation.

19. All employees are to conduct themselves in a principled manner and in compliance with laws, regulations, and accreditation standards, this includes providing proof of certification or licensure. Failure to do so may result in disciplinary action.

20. Failure by any employee to report unethical or unlawful practices or actions is misconduct warranting disciplinary action. However, any employee who raises a complaint under this policy in bad faith, or for the purpose of harassing another employee, or who repeatedly raises meritless complaints hereunder, will be subject to disciplinary action, and such disciplinary action will not be deemed retaliation under this policy.

21. The Agency will on an annual basis conduct internal audits on admissions, payments and reimbursement, accounts receivable, delinquent accounts, and staff expenses to ensure adherence to all laws, regulations, program requirements and guidelines and policies. The results of these audits are to be reported at least annually to the Compliance Committee for their review and recommendations to the Board of Trustees.

22. It is the policy of ASCOSJ to prohibit kickbacks from being paid or received. The administrative staff and the members of the governing body will sign a No Kickback Policy statement annually.

23. It is the policy of ASCOSJ to comply with all Federal HIPAA and State HINT regulations regarding confidentiality of patient information. All Agency staff and volunteers shall sign a Confidentiality Agreement in this regard. Each patient will receive a privacy statement that will be explained to them and that they will acknowledge on the Informed Consent form.

Amada Senior Care of South Jersey Management