Brethren Retirement Community, Brethren Home Care, Brethren Management Services (and any other subsidiaries) is committed to ethical, honest billing practices and expects every team member (including employees, independent contractors, sub-contractors and vendors) to be vigilant in maintaining these standards at all times. It is important that our contractors understand the provisions of a number of laws, your obligation to act under these laws and your right to report if you suspect a violation as well as protections available for those who report violations of these laws. Please ensure your staff are familiar with the laws and regulations listed below:

Compliance Program:

Brethren Retirement Community is required to have a Compliance Program. The core document of any compliance program is the Code of Conduct which covers compliance issues, laws and regulations and the guidelines that are relevant to providers of senior services. This code of conduct is relevant to all individuals including employees, contractors, volunteers, directors and officers.

Below you will find a summary of our code of conduct. Please assure that you review your obligations to abide by the compliance program as a requirement of doing business with Brethren Retirement Community.

Excluded Provider Policy:

Brethren Retirement Community cannot do business with any individuals or entities sanctioned by the Federal and/or State government. It is your duty to inform us immediately if your organization or anyone under your employment is currently or becomes excluded in the future.

Elder Justice Act:

Under this regulation it is the obligation of anyone who works for, or contracts with a long term community to report to local law enforcement, and to the Secretary of Health and Human Services, their reasonable suspicion of crimes against nursing home residents. This reporting must happen in a timely manner.

If the event that causes suspicion –

- Results in serious bodily injury, the individual shall report the suspicion immediately, but not later than 2 hours after forming the suspicion;

- Does not result in serious bodily injury, the individual shall report the suspicion not later than 24 hours after forming the suspicion.

Please be sure to inform all of your employees who, in the course of business, are present in any our community’s campuses, are aware of these obligations:

-Federal False Claims Act (31 U.S.C. (3729-3733)

- Federal Civil and Criminal Penalties and Administrative Remedies:

-False Claims and Civil Penalties (31 U. S. C § 3729)

-Program Fraud and Civil Remedies Act of 1986 (“PFCRA”) (31 U.S.C. §3801-3812)

-Civil Monetary Penalties Law (“CMPL”) 42 U.S.C § 1320a-7a)

-Criminal Penalties (42 U.S. C. § 1320a – 7b)

-Exclusion from Participation in federal Health Care Programs (42 U.S.C. 1320a – 7)

-State False Claims Laws

-Federal “Qui Tam” or “Whistleblower” Protect (31 U.S.C. § 3730)

You are encouraged to communicate any compliance concerns to our Compliance Officer or Compliance Official or use the Compliance Hotline.

Effective: March 1, 2021