Acutis Workforce shall comply with the following policies and standards:

Ethical and Professional Standards

• Acutis workforce shall comply with and perform their services consistent with high ethical and professional standards. They shall treat patients, co-workers, and others in a professional manner with honesty, fairness, dignity, and respect.
   

Acutis Policies and Procedures​​

• Acutis workforce shall comply with all applicable Acutis policies and procedures, including but not limited to those policies and procedures relevant to the Acutis Compliance Program.
  
  

Laws, Regulations, and Program Requirements​

• Acutis workforce shall comply with all applicable federal and state laws, regulations, and third-party payor program requirements.
   

• Acutis screens all Workforce members, vendors, contractors, and clients to ensure that they are not included in: a) the United States Department of Health and Human Services Office of Inspector General’s List of Excluded Individuals/Entities; (b) the General Services Administration’s System for Award Management (“SAM”); (c) applicable state Medicaid excluded provider or other debarment listings; or (d) any other similar or successor list(s) of excluded or debarred individuals or entities.
   

HIPAA Privacy and Security

• Acutis believes in strict confidentiality policies and requires all employees to sign a confidentiality agreement at the time of hire and annually thereafter. Confidentiality means that communications with or about patients involving patient health information will be private and limited to those who need the information in order to provide treatment, payment, and health care operations.
   

Quality of Care

• All professional staff employed or engaged by Acutis shall be properly licensed (and/or certified) and registered per applicable law.
   

Non-discrimination

• Acutis workforce shall not discriminate against other Acutis workforce, patients, or others on the basis of race, color, sex, religion, age, national origin, ancestry, disability, or sexual orientation.
   

Offering or Receiving Items of Value to Induce Referrals

• Federal and state laws prohibit paying, offering, or receiving anything of value to induce referrals for healthcare business unless certain conditions are met. Acutis workforce shall not offer, ask for, pay, or accept anything of value in exchange for healthcare referrals. This applies to offering or receiving any money, gifts, free or discounted items or services, professional courtesies, or other arrangements with the intent to induce referrals. This applies to any such transactions involving potential referral sources, including transactions with other healthcare providers, vendors, or patients. Violations may subject Acutis and its workforce to criminal and administrative penalties.
   

Financial Relationships with Physicians and Other Referral Sources

• Federal and state laws affect contracts, agreements, and other financial relationships with physicians, practitioners, vendors, and other referral sources.
   

  • a. Acutis workforce shall not enter any contract or other financial arrangement with or give or receive anything of value to or from, an outside physician, a physician’s family member, or other referral sources without the prior approval of the Compliance Officer.
     

  • b. If Acutis has a contract or other financial relationship with an outside physician or a member of the physician’s family, Acutis workforce shall not bill Medicare for any items or services referred by that physician without the prior approval of the Compliance Officer.
     

  • c. Acutis workforce must strictly comply with the terms of any approved contract or other financial arrangements with outside physicians, their family members, or referral sources. Failure to perform or improper modifications of such contracts or arrangements may violate applicable laws.

​

Conflicts of Interests

• It is Acutis's workforce's responsibility to act in the best interest of Acutis at all times. When performing job duties on behalf of Acutis, workforce members shall avoid any relationship, influence, or activity that might impair, or even appear to impair the ability to make objective and fair decisions.
   

• Acutis workforce members must disclose any potential conflict of interests at the time of hire, and annually thereafter, or if the situation changes causing a conflict.
   

Improper Inducements to Medicare or Medicaid Beneficiaries

• Inducements to Medicare, Medicaid, or other government beneficiaries may violate applicable law. Acutis workforce shall not waive or discount government beneficiary co-pays unless such discount complies with Acutis’ policy.
   

• Acutis workforce shall not offer any other discount, gift, free items or service, or other inducements to clients (government beneficiaries) without first obtaining approval from the Compliance Officer.
   

• All contracts, leases, and other financial relationships with clients will be based on the fair market value of the services or items being supplied or exchanged, and not on the basis of the volume or value of referrals or other business between the parties.
  ​

Professional Courtesies

• Acutis workforce shall not offer or receive any free or discounted items or services to or from other health care providers, their family members, or their office staff, unless such offer is consistent with Acutis’ Policy, or the offer, has been approved by the Compliance Officer.

​

Improper Billing Activities

• Acutis workforce shall not engage in false, fraudulent, improper, or questionable billing. Such improper activities include, but are not limited to:
   

  • a. Billing for items or services that were not actually given.
     

  • b. Billing for or giving items or services that were not medically necessary.
     

  • c. Submitting a claim for physician services when the services were actually rendered by a non-physician, or where a physician failed to provide the level of supervision required by applicable laws or regulations.
     

  • d. Submitting a claim for payment without adequate documentation to support the claim.
     

  • e. Signing a form for a physician.
     

  • f. Improperly altering medical records.
     

  • g. Using a billing code that supplies a higher payment rate than the correct billing code (i.e., “upcoding”).
     

  • h. Submitting bills in a fragmented fashion to maximize reimbursement even though third-party payors require the procedures to be billed together (i.e., “unbundling”).
     

  • i. Submitting more than one claim for the same service (i.e., “duplicate billing”).
     

​If an Acutis workforce member has a question about the proper standard or procedure for documenting or submitting a claim, they should contact the Compliance Manager as described below.

Documentation and Record Retention

• Acutis shall maintain accurate records and accounts to ensure legal and ethical business practices and to prevent fraudulent activities.
   

• Patient care must be necessary, appropriate, and well-documented. Records and accounts must be complete and not misleading. Accounting records and the reports produced from those records must be retained per applicable laws and relevant accounting standards.
   

Unfair Competition and Deceptive Trade

• Federal and state antitrust laws prevent certain anti-competitive conduct, including collusive agreements among competitors to set prices; divide patient care or services; boycott other entities; etc. Acutis workforce should not engage in collusive discussions with competitors over such things as prices, employee wages, services to be given or eliminated, or division of patients or patient services without the Compliance Departments' prior approval. Similarly, the Acutis workforce should not discuss exclusive arrangements with third-party payors, vendors, and providers without first discussing the matter with the Compliance Department. Finally, Acutis's workforce should not engage in any deceptive acts or practices relating to Acutis.
  
  

Marketing Activities​

• All marketing activities and advertising by Acutis workforce must be truthful and not misleading, must be supported by evidence to substantiate any claims made, and must otherwise be per applicable law. In this regard, our best “advertisement” is the quality of our services.
   

• All marketing activities and advertising by the Acutis workforce must be based on the merits of the services provided by Acutis and not on any promise, express or implied, of payment for any referrals.
   

Report Suspected Violations​

• Acutis has an obligation to promptly repay money identified as overpayments that are received from third-party payers within 60 days. Acutis has a duty to ensure such overpayments are promptly reported, explained, and returned in accordance with applicable law and contractual requirements. It is essential that Acutis workforce:
   

  • a. Comply with applicable laws, regulations, and policies; and
     

  • b. Immediately report suspected violations or compliance concerns to their supervisor, department leader, or the Compliance Department, Anonymous reports may be made by calling the compliance hotline (631-606-4192). You may also contact the compliance department through email at complianceinquiries@acutis.com, as well as contact the Compliance Department team members directly:
    

    • Chief Compliance Officer, David Goldberg        ddgoldberg@acutis.com

    • Compliance Manager, Sara Anderson                sanderson@acutis.com
      

  • c. Failure to report a suspected violation may subject Acutis workforce to appropriate discipline.
    
    
    

Non-retaliation

• No adverse action will be taken against an Acutis workforce member who in good faith and without reckless intent has come forth with information or evidence of a suspected violation of any law, regulation, program requirement or Acutis policy relevant to the Acutis Compliance Program.