Compliance at Caron

Caron Treatment Centers (“Caron”) is committed to operating with integrity and in full compliance with laws, regulations and policies. Caron sets expectations for ethical conduct with a longstanding reputation for being a leading behavioral health and addiction treatment center. Caron’s Compliance Program is based on the Office of Inspector General of the U.S. Health and Human Services’ Compliance Program Guidance and U.S. Federal Sentencing Guidelines for effective compliance programs which includes the following:

1. Compliance Policies and Procedures.
2. Corporate Compliance Officer and Audit, Compliance and Risk Management Committee.
3. Training and Education.
4. Open Lines of Communication.
5. Monitoring and Auditing.
6. Enforcement.
7. Response to Deficiencies and Corrective Actions.

Caron’s Compliance Program assists, educates and advises all Caron employees, officers, board members, and contracted persons on how to prevent, detect and correct violations of federal, state, or local laws or violations to Caron’s policies and procedures. The Compliance Program is designed to:

• Support Caron’s commitment to following policies, ethics and standards of conduct.
• Ensure Caron complies with applicable federal, state and local laws and regulations.
• Educate and train personnel to conduct their job activities in compliance with state and federal law and according to the policies and procedures of the Compliance Program.
• Educate and train personnel and contracted persons on Caron Statement of Organizational Ethics and Code of Conduct.
• Implement auditing and monitoring initiatives to measure the effectiveness of the Compliance Program and to address problems in an efficient and timely manner.
• Promote open lines of communication for the reporting of compliance and ethical concerns.

Caron’s Statement of Organizational Ethics and Conduct of Conduct
All Caron Representatives, regardless of employment status (e.g., full-time, part-time, or per diem) and any person under a contract or other arrangement (for example, a consultant) who provides services at any Caron location or otherwise for or on behalf of Caron, are held to professional standards of ethical behavior, Caron’s Statement of Organizational Ethics & Code of Conduct, Caron’s Conflict of Interest policy, and any other guidance issued by Caron regarding ethical behavior.

Any Caron Representative or person providing services to Caron will not harm or endanger the health and well-being of a patient, a patient’s family, colleague, or a student in any way. It is the policy of Caron to deliver kind and humane treatment to all patients, their family members, and students. Any person receiving care, treatment or is employed at Caron shall retain all civil rights and liberties except as provided by law. No patient may be deprived of a civil right solely by reason of treatment. Caron will not engage in or tolerate any unlawful discrimination (including any form of unlawful harassment) on account of a person’s sex, age, race, color, religion, creed, sexual preference or orientation, marital status, national origin, ancestry, citizenship, language you speak (including proficiency in English), military status, veteran status, handicap, or disability (physical or mental), medical condition including HIV diagnosis/ perception of HIV infection or any other protected group or status. Caron Representatives should not place themselves in a position where their actions, activities or interests of others with whom they may have a financial, business, professional, family or social relationship may be in conflict with the interests of Caron.

Any Caron Representative who recognizes or discovers a violation of Caron’s Organizational Ethics & Code of Conduct, Conflict of Interest or other guidance issued by Caron’s Compliance Department is obligated to report the violation to the Corporate Compliance Officer. Failure to comply with Caron’s policies will be subject to appropriate performance management pursuant to all applicable policies and procedures, up to and including termination, and may subject the Caron Representative to criminal or civil action.

Fraud, Waste & Abuse, False Claims Act & Whistleblower Protections
Caron takes health care fraud, waste and abuse very seriously. Caron is committed to ensuring all applicable laws and regulations that address health care fraud, waste, abuse is followed at all times. This includes the Federal False Claims Act, state laws related to false claims as well as protections available for those who report violations of these laws. All Caron employees, contractors or agents are educated in the definitions and descriptions of fraud, waste and abuse. All Caron employees, contractors and agents are responsible for preventing, detecting and reporting any activities that constitute fraud, waste and abuse at any Caron location. Caron shall not discharge, threaten, discriminate or otherwise retaliate against an employee or other Caron Representative for making a good faith report to Caron or appropriate authority of wrongdoing or waste.

Reporting a Compliance Concern
A toll-free Compliance Hotline is available for reporting any compliance concerns. This hotline serves as a channel for callers to seek guidance or report possible compliance issues in the following areas:

• Violations of state or federal regulations or laws including Federal HIPAA privacy regulations.
• Violations of any of Caron’s Program requirements.
• Violations of Operating policies and procedures.
• Concerns about Caron’s billing, accounting, internal control or auditing related matters and/or practices.
• Ethical concerns or issues.

All reports to the Compliance Hotline are investigated and handled in a confidential manner by trained individuals. Callers may remain anonymous or leave their contact information if they so choose. Caron relies on these reports to confirm or improve upon its processes and practices, and does not tolerate retaliation against individuals who report concerns in good faith.

For the Compliance Hotline, call 1-855-356-8890.