The BHealthy Compliance Program is applicable to all BHFL service providers, including contractors and consultants. BHealthy is dedicated to providing quality and efficient patient care, upholding high standards of ethical, professional, and business conduct, and ensuring full compliance with all relevant federal and state laws governing healthcare delivery and payment, including those that prohibit fraud, waste, or abuse of healthcare resources.

Fraud, waste, and abuse are defined as follows:

• Fraud: Intentional deception or misrepresentation, knowingly making a false claim, or other willful deception to receive unauthorized benefits. No specific intent to defraud is required.

• Waste: Extravagant, careless, or unnecessary utilization or payment for healthcare services.

• Abuse: Activities or practices by a member, practitioner, employee, or contractor that are inconsistent with sound fiscal, business, or care practices, resulting in unnecessary costs, unnecessary services, or failure to meet professional healthcare standards.

BHFL aims to ensure quality and efficient patient care, high standards of ethical conduct, and adherence to applicable laws and healthcare program requirements.

The Compliance Program for contractors and consultants includes:

1. Written standards promoting compliance with laws and regulations.

2. A designated Compliance Officer and Compliance Committee responsible for implementing and monitoring the program.

3. Appropriate educational programs.

4. A reporting process for potential compliance violations, with protections for anonymity and against retaliation.

5. Procedures for responding to improper activities by contractors and consultants.

6. Periodic audits or other monitoring methods to identify and resolve issues.

7. A process for investigating and resolving identified problems.

Contractors and consultants are expected to comply with all relevant federal and state laws and assist BHFL in its compliance efforts. They must adhere to the terms of their agreements and cooperate in the implementation, maintenance, and monitoring of the Compliance Program. BHFL may also require participation in educational programming on compliance issues.

If a contractor or consultant fails to perform services ethically and in compliance with these principles, their engagement with BHFL may be terminated.

To ensure the highest standards of ethical conduct and compliance with all applicable laws, BHFL encourages open communication between contractors, consultants, and the Compliance Team to successfully implement the Compliance Program and reduce the potential for fraud, abuse, and waste.

Contractors and consultants should keep the following in mind when providing services:

1. Reporting Suspected Violations: Report suspected violations of the Compliance Program or any law, regulation, or third-party payor requirement as soon as possible.

   • How to Report: Reports can be made anonymously to the Compliance Team via email at info@bhealthyforlife.com.

2. Receipt of Report: Complaints should be forwarded to the Compliance Team, and contractors and consultants are expected to cooperate in investigations.

3. Handling by BHFL: The Compliance Team will promptly investigate and address compliance complaints.

4. Preserving Confidentiality: BHFL will strive to keep the identity of reporters confidential where possible.

5. Non-retaliation: BHFL prohibits retaliation or intimidation against individuals reporting suspected fraud, waste, or abuse. Contractors or consultants who retaliate may have their engagement terminated.

6. Documentation: Records of complaints and investigations will be maintained for seven years and destroyed thereafter unless required for ongoing or future investigations.

BHFL is committed to high ethical standards and compliance in all business aspects. Contractors and consultants are expected to comply with all relevant laws and third-party payor requirements, including:

• Upholding high ethical standards and treating patients and others with honesty, fairness, dignity, and respect.

• Complying with anti-discrimination, anti-harassment, and anti-retaliation laws.

• Not offering or receiving items of value to induce referrals.

• Avoiding conflicts of interest.

• Ensuring truthful and accurate billing practices.

• Maintaining the confidentiality of patients' protected health information.

• Complying with intellectual property laws.

• Following security and asset protocols.

• Reporting suspected violations immediately to the Compliance Team.

Contractors and consultants must acknowledge and adhere to these principles throughout their engagement with BHFL. Failure to comply may result in termination of their engagement.