The purpose of HBR's CCP is to provide a means for HBR executive management to ensure its clients, employees, patients and providers ("Stakeholders") that the Company is in material and substantial compliance with all laws and regulations that govern medical billing. The purpose of the CCP is also to provide a means for employees to report suspected wrongdoing or to ask ethical questions in a work environment free of fear and retaliation. While no Compliance Program will be able to eliminate 100% of the errors and misinterpretations of billing rules, regulations, and laws, HBR's Compliance Program provides the company with a formal set of policies and procedures not only to help prevent, but also to detect violations once they occur and then to work at resolving those issues internally and, when necessary, through voluntary disclosure to the proper government agencies.

HBR's Corporate Compliance Program is more than the Company's statement to achieve technical compliance with laws and regulations – it is also the Company's statement of good corporate citizenship that we pledge to do business in an ethical manner. Each employee is empowered with the ownership, as well as the responsibility of this ideal. HBR expects employees to act as the "front line" in advancing the Compliance Program and the Code of Ethics. The following is the summary of the Code of Ethics:

• HBR employees should use the “HIP Principles”:  honesty, integrity and professionalism.
• Good Decisions and Common Sense – use of good judgement while utilizing appropriate resources to make sound decisions in business matters.
• Trustworthy Conduct – be dependable, loyal and honest.
• Respectful Behavior – treat all others with courtesy and acceptance.
• Accountability- take personal responsibility for one’s actions.
• Good citizenship – make a personal effort to keep HBR a productive environment.
• Avoid the appearance of impropriety – employees should always conduct themselves in such a way that there would be no reason to question the ethics or appropriateness of their actions or conduct.  HBR has a unique Wallet card that each employee is provided outlining questions to ask and where to go when help is needed to answer these questions, including the HBR HELPLINE number, to report issues or compliance concerns.
• Corporate Compliance is the by-product of good business practices.

At HBR, the way business is conducted is a representation not only of the individual employee but the Company as a whole. Providers, e.g. hospitals and physicians, place their trust in HBR's employees performing coding and billing lawfully and in compliance with appropriate standards. Therefore, the following policies and procedures are provided and employees are expected to abide by them to the best of their ability:

• At a minimum, HBR will comply with all applicable laws and regulations.  If in doubt of policy, the employee should consult the Company’s management staff or the Compliance Department.
• Conflicts of interest are to be avoided.  Employees must remain loyal to the Company’s duties and responsibilities.
• Confidentiality and privacy of all patient, client and personnel information is to be protected.  Therefore, each employee has a responsibility to the Company and clients to protect sensitive, confidential and privileged information.
• HBR utilizes non-discriminatory management practices to ensure equality in the workplace.  Employee discrimination or harassment will not be tolerated.

This list is not intended to be exclusively used as a resource for good business conduct. It obviously does not address all situations or conditions which could arise. HBR employees are urged to discuss any potential issue with a supervisor, manager or the Compliance Department if there are any questions.

Written policies and procedures – HBR's Corporate Compliance Program sets forth a code or standard of conduct addressing major areas in the coding and billing industry including but not limited to the following:

• Internal coding practices and policies
• Internal coding quality assurance and training
• “Assumption coding”
• Upcoding
• Unbundling
• Insurance-Only billing
• Refund processing
• HIPAA Privacy, Transaction Code Sets standards and Security

Designation of a compliance officer – HBR's has had a Compliance Officer since the program's inception. The current CCO has served in this capacity for over ten (10) years and also acted as counsel for the previous CCO in 1994.

Effective Training and Education – Coder trainees at HBR receive initial, specific and intensive coding training prior to performing coding for any HBR clients and regular in-service education once they become full-fledged coders. Employee Compliance training began in early 1995 and has been continued with an annual refresher training for all employees and management staff each year since 1995. As part of the Compliance Program's commitment to training, all new employees attend initial Compliance training soon after employment to provide specific education of HBR's Compliance Program and employee obligations. All compliance training sessions provide employees with updated compliance issues in our industry as well as continued guidance as it relates to specific coding and billing procedures and HIPAA related issues.

Auditing and Monitoring - HBR performs auditing and monitoring on an on-going basis. For example, the Coding Department is subject to regular coding quality assurance review through a dedicated Coding Quality Assurance Department. This is done to assure that coding and billing processes are preformed according to the Medicare Documentation Guidelines and guidelines established by CPT-4 and ICD-9. Coders who do not maintain an acceptable accuracy rate will be placed into a focused review where each chart is reviewed with the coding QA manager contemporaneously and prior to claim submission.

Effective lines of communication – All HBR employees have direct access to the Compliance Officer and his staff through the company HELPLINE. This toll-free telephone line is dedicated solely for the employees to have access to report potential compliance issues, request information on compliance issues or receive an explanation of current Company policies or procedures. The HELPLINE is available 24 hours a day 7 days a week. Calls cannot be traced or recorded allowing any employee the ability to receive or report information without disclosing their identity and without the fear of retaliation. All calls are answered by a member of the Compliance Department in a timely manner and all issues are logged, investigated and documented until resolved.

HBR's policy on non-retribution is at the heart of HBR's Compliance Program. The non-retribution policy states that neither HBR nor any of its employees or management will retaliate or engage in retribution against any employee who raises a compliance issue in person or through the Employee HELPLINE.

Enforcing standards through well publicized disciplinary guidelines – All disciplinary actions and standards are documented in HBR's Human Resources Policies and Procedures Manual and outlined in HBR's Compliance and Privacy Guide, Second Edition ("the Guide"). As mentioned previously, HBR has policies and procedures to guide employees in both ethical and legal business activities. Any violations of these standards may result in disciplinary actions, up to and including termination of employment if warranted.

Response, detection and prevention – HBR believes that our coding QA process is truly an "early warning" system to prevent and detect potential compliance issues. In addition to coding, there are other formalized methods of HBR responding, detecting and/or preventing coding and/or billing errors. HBR's standing compliance, IT and management committees regularly review and analyze compliance-related issues, including claim feedback from Medicare Carriers, payor refunds and tracking billing industry experience and recommended practices. HBR believes that the extra effort and processes in place measuring above and beyond the governmental mandates is an indication of HBR's genuine efforts to conduct business in an ethical and law-abiding manner and exemplifies HBR's compliance philosophy making us a leader in both compliance and value-added service in the healthcare billing industry.

HBR's Compliance Program is not only a plan to prevent and detect medical billing problems, but it also serves the broader purpose of encouraging management and employees to ask questions and report issues about the company's policies and practices in an environment free of fear and retaliation. HBR in turn makes every effort to answer their questions and to address and resolve the issues that they report. Today compliance has become an integral part of HBR's everyday business practices and provides our Stakeholders with assurance of the Company's voluntary and long-standing commitment to truly effective Compliance.