ADOPTION OF PROVIDER COMPLIANCE PROGRAM

KIDZ THERAPY SERVICES, PLLC
PART 521 TITLE 18
CODES, RULES AND REGULATIONS OF THE STATE OF NEW YORK
DATE OF ADOPTION: SEPTEMBER 29, 2009

Kidz Therapy Services PLLC has established a Provider Compliance Program which includes a Compliance Committee and a designated Compliance Coordinator. Kidz Therapy Services requires that all employees comply with all Rules and Regulations as stated in this manual, as well as, all applicable federal, state, and local laws, rules, regulations and professional guidelines.

• All employees are expected to use professional judgment and honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.
  
• Failure to comply with all Rules and Regulations as stated in Kidz Therapy's procedure manual, as well as, all applicable federal, state, and local laws, rules, regulations and professional guidelines may result in corrective action up to and including termination of employment and referral to legal authorities. Any actions found to be encouraging, directing, facilitating or permitting non-compliant behavior, may result in corrective action up to and including termination of employment and referral to legal authorities. Any act by a person to coerce or influence an accountant during the performance of an audit is unlawful and will be reported to the appropriate legal authorities.
  
• Employees and those acting on behalf of Kidz Therapy are required to disclose any actual or potential conflicts of interest and seek guidance on how to handle such situations.
  
• A conflict of interest is any situation in which financial or other personal considerations may compromise or appear to compromise: (1) the business judgment of any employee or other party engaged by us; (2) the delivery of service; or, (3) the ability of an employee to do his or her job. An actual or potential conflict of interest occurs when an individual is in a position to influence a decision that may result in a personal gain for that person at the expense of the best interest of Kidz Therapy Services, PLLC and/or the children and families we service.
  
• Business dealings with outside entities (families, schools, school districts, etc.) should not result in unusual gain for those entities, Kidz Therapy or an employee. “Unusual gain” refers to bribes, product bonuses, special fringe benefits, unusual price breaks, and other windfalls designed to ultimately benefit the employer, the employee, or both. Certain nominal benefits are allowed in accordance with other policies.
  
• Kidz Therapy materials, products, designs, plans, ideas, and data are the property of Kidz Therapy and should never be given to an outside firm or individual except through normal established standard protocols with appropriate prior authorization. Any improper transfer of material or disclosure of information, even though it may not be apparent that an employee has personally gained by such action, is prohibited.
  
• All employees, including supervisors and managers, are responsible for reporting misconduct, including actual or potential violations of law, regulation, policies and procedures, problems and concerns regarding questionable accounting, internal accounting controls, or auditing matters. Failure to report a known violation may result in appropriate disciplinary action up to and including termination.
• Anyone with knowledge of a potential violation of law, regulation, policies or procedures including questionable accounting, internal accounting controls and/or auditing matters, has an affirmative duty to report that information. Failure to report a potential violation may result in appropriate disciplinary action up to and including termination.
• A telephone hotline, (516) 394-9803, has been set up so that employees can report problems, violations and concerns or seek clarification of compliance related issues without having to go through the management chain of authority.
• Reporting can be done by calling the compliance hotline (516) 394-9803 24 hours a day, 365 days a year. You may call or approach the Compliance Coordinator, Anna Stellman, at any time or any other member of the Compliance Committee; Judy Mahoney, Donna Menna or Linda Roeder.
• Callers may remain anonymous. If they identify themselves, callers will have their confidentiality protected to the full extent of the law. No attempt will be made to identify a caller who requests anonymity. Any violation of this policy may result in sanctions and penalties. Determinations as to the limit of confidentiality under the law will be made in consultation with legal counsel.
• Employees cannot exempt themselves from the consequences of their own misconduct by reporting the issue, although self-reporting may be taken into account in determining the appropriate course of action.
• Knowledge of actual or potential wrong-doing, misconduct, or violations must be immediately reported to management, the compliance office, or the hotline.
• No supervisor, manager or employee is permitted to engage in retaliation, retribution or any form of harassment against an employee for reporting a compliance related concern. Any supervisor, manager or employee who conducts or condones retribution, retaliation or harassment in any way will be subject to discipline, up to and including termination.
• Kidz Therapy Services prohibits the firing, threatening or otherwise harming of any person on the basis of the employee’s reporting a problem or his or her participation in an investigation of violations. People who bring organizational problems or criminal conduct to their supervisors, administrators, or the compliance coordinator are entitled to protections and remedies.