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Care Compass is dedicated to the protection of information pertaining to its Staff, Business Associates, and the patients and clients served by its participating organizations and Members. For more information on the policies, click on the links below.

Compliance Policies

Addressing Instances of Non-Compliance Through Appropriate Disciplinary Actions Policy
The Care Compass Entities are committed to ensuring that regulatory requirements and their Compliance Program policies and procedures are adhered to by Affected Individuals. To demonstrate such commitment, it is the policy of the Care Compass Entities to publicize and consistently enforce these policies and procedures by imposing appropriate disciplinary action.
Addressing Instances of Non-Compliance Through Appropriate Disciplinary Actions Policy

Antitrust Compliance Policy
The Care Compass Entities are committed to complying with Antitrust Law and prohibit anti-competitive conduct, including the improper exchange of competitively sensitive information, collusion to limit competition, and actions to discourage its Participants from contracting with payors outside the context of the Care Compass Entities’ arrangements with such payors.
Antitrust Compliance Policy

Beneficiary Inducements Policy
The Care Compass Entities will comply with federal and state prohibitions on remuneration provided to Federal healthcare programs, including Medicare or Medicaid, as improper inducements in relation to care, services and supplies payable under Medicare or Medicaid.
Beneficiary Inducements Policy

Code of Conduct for Network Operations
This Network Code of Conduct has been designed to inform Care Compass Affected Individuals and the community we service of our standards and provide guidance on ethical and compliance issues for the Care Compass Networks (Networks).
Care Compass Code of Conduct

Compliance Program Training and Education Policy
It is the policy of the Care Compass Entities to develop and offer on-going educational and training programs so that Affected Individuals are familiar with the Care Compass Entities’ Compliance Programs and understand the fraud and abuse, antitrust, and other applicable laws and regulations that pertain to the activities of the Care Compass Entities.
Compliance Program Training and Education Policy

Conducting Compliance Audits Policy
As part of its efforts to implement an effective Compliance Program, the Care Compass Entities will periodically conduct proactive monitoring and auditing functions designed to test and confirm compliance with the Care Compass Entities’ payment systems, compliance standards, and policies and procedures, as well as federal, state, and local laws and regulations, and areas of high-risk identified in Compliance Department Risk Assessments.
Conducting Compliance Audits Policy

Deficit Reduction and False Claims Prevention Policy
The Care Compass Entities are committed to ensuring regulatory compliance and the communication of expectations regarding the prevention of fraud, waste, and abuse pertaining to the operations of the Care Compass Entities.
Deficit Reduction and False Claims Prevention Policy

Detection and Prevention of Fraud, Waste, and Abuse Policy
It is the policy of the Care Compass Entities to comply with laws and regulations fully and consistently and to implement reasonable precautions and take appropriate actions to prevent, detect, and address potential or actual cases of fraud, waste, and abuse.
Detection and Prevention of Fraud, Waste, and Abuse Policy

Director of Compliance Authority and Obligations Policy
It is the policy of the Care Compass Entities to have a Director of Compliance, serving as the Compliance and Privacy Officer to oversee the development and implementation of the Care Compass Entities’ Compliance and Privacy Programs and to ensure appropriate handling of instances of suspected or known illegal or unethical conduct and the protection of Personally Identifiable Information (PII) and Protected Health Information (PHI).
Director of Compliance’s Authority and Obligations Policy

Duty to Report Non-Compliance Policy
The Care Compass Entities are committed to conducting its business in a manner that complies fully with applicable laws, regulations, guidance, program requirements, and the Care Compass Entities’ Codes of Conduct. Affected Individuals must report suspected unethical or illegal conduct, in order to support this commitment and to protect the Care Compass Entities’ reputations.
Duty to Report Non-Compliance Policy

Functions of the Compliance Committee Policy
To assist the Board of Directors in fulfilling the Board’s oversight responsibility and support the Director of Compliance in meeting their responsibilities, the Care Compass Entities will establish and maintain Compliance Committee(s).
Functions of the Compliance Committee Policy

Member Complaints and Reportable Incidents Policy
It is the Policy of CCC to recognize the rights of each Member to report concerns about the quality of care or service received and provide a process for prompt review and, when possible, resolution. CCC allows Members to voice Complaints freely and without being subject to coercion, discrimination, reprisal, or unreasonable interruption of care.
Member Complaints and Reportable Incidents Policy

Reimbursement and Self-Disclosure Policy
The Care Compass Entities are dedicated to the protection of the patients and clients of its Affected Individuals and Participants, and to the mission of serving the healthcare and social determinants of health needs of the community. In order to ensure proper payment in meeting this mission, the Care Compass Entities will proactively review issues which may give rise to the refund of payments received by the Care Compass Entities which were found to be unauthorized or in violation of appropriate laws and standards pertaining to Medicaid and/or Third-Party Liability programs.
Reimbursement and Self Disclosure Policy

Responding to Detected Offenses and Developing Appropriate Corrective Action Plans Policy
It is the policy of the Care Compass Entities to ensure that it responds to information that an Affected Individual is engaging in activity that may be contrary to applicable Federal or State law or the requirements of the Care Compass Entities’ Compliance Programs.
Responding to Detected Offenses and Developing Appropriate Corrective Action Plans Policy

Sanctions Policy
It is the policy of the Care Compass Entities to fairly and consistently apply Sanctions to Affected Individuals who fail to abide by Federal and State laws and regulations; the Code of Conduct; compliance, privacy and security policies and procedures, and other applicable policies and procedures; or who engage in behavior that may result in a compliance or privacy violation.
Sanctions Policy

Whistleblower Policy
It is the policy of the Care Compass Entities to support and promote activities to identify and report suspected fraudulent activity and unethical behavior while maintaining a work environment that encourages Affected Individuals to take an active part in the investigative process without fear of retaliation or negative impact.
Whistleblower Policy

Privacy and Security Policies

Acceptable Use Policy
This policy defines information technology (IT) requirements, actions, prohibitions, and acceptable use of the Care Compass Entities’ information technology devices, systems, and resources, which Staff must follow within technical controls and implemented security configurations. Inappropriate use exposes the Care Compass Entities to risks including virus attacks, compromise of network systems and services, and legal issues.
Acceptable Use Policy

Access Controls Policy
This policy serves to establish the requirements for the Care Compass Entities’ Access Control Program – the Physical, Technical and Security techniques that regulate who or what can view or use resources in a computing environment.
Access Controls Policy

Amendments to Protected Health Information Policy
It is the policy of the Care Compass Entities to comply with all federal and state regulation regarding an individual’s right to request amendments to their PHI contained within the designated record set.
Amendments to PHI Policy

Authorization for Release of Protected Health Information Policy
It is the policy of the Care Compass Entities to comply with all federal and state regulation regarding the Use and Disclosure of PHI and to allow Disclosure of PHI without an individual’s authorization only for the purposes of Treatment, Payment and Healthcare Operations or as otherwise allowed by HIPAA or under other state and federal law.
Authorization for Release of PHI Policy

Breach Notification Policy
It is the policy of the Care Compass Entities to maintain privacy and security measures to protect the confidentiality of PHI by preventing impermissible acquisition, access, use or disclosure of such PHI.  This Policy describes the process by which the Care Compass Entities identify, verify, notify, and address any such Breach of PHI.
Breach Notification Policy

Data Governance Policy
This Policy addresses data governance and data sharing among the Care Compass Entities and their Participants, the uninsured population, and Individuals covered by public and private payors. This Policy pertains to all Staff, vendors, community health teams, Participants, and any other persons who have access to the Care Compass Entities’ information systems and will describe how the Care Compass Entities establish data partnerships and how data shall be received, stored, used, and shared. This Policy also specifically addresses the Care Compass Entities’ inclusion, use, and treatment of Sensitive Data or other Sensitive Information.
Data Governance Policy

Information Security Program Management Policy
This policy serves to establish the information security program management requirements for the Care Compass Entities. This policy pertains to Staff, vendors, community health teams, participating organizations and any other person who has access to the Care Compass Entities’ information systems or to PHI, PII, or to Sensitive Information.
Information Security Program Management Policy

IT Security Requirements Guide
This policy provides an operational guide on Care Compass Network’s IT Security requirements.
IT Security Requirements Guide

Notice of Privacy Practices Policy
This policy serves to establish the requirements for Care Compass Collaborative (“CCC”), in its role as a Covered Entity, and Care Compass Network (“CCN”) and Care Compass Supporting IPA (“IPA”), when functioning as CCC’s Business Associates, to maintain compliance with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) requirements to publish, distribute, and maintain a Notice of Privacy Practices.
Notice of Privacy Practices Policy

Privacy Program Policy
It is the policy of the Care Compass Entities to implement measures and controls to protect the privacy and confidentiality of PHI, PII, and Sensitive Information. The Care Compass Entities are dedicated to the protection of information pertaining to its Affected Individuals and the patients and clients served by its Affected Individuals.
Privacy Program Policy

Restrictions on Use and Disclosure of Protected Health Information Policy
It is the policy of the Care Compass Entities to comply with all federal and state regulation regarding an individual’s right to request restrictions on the Use or Disclosure of their PHI.
Restrictions on Use and Disclosure of PHI Policy

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