WHEN KIDS PLAY  

• POLICIES AND PROCEDURES 

Thank you for choosing WHEN KIDS PLAY as your home health therapy provider. You and your child's medical needs, treatment, safety, and well being are of paramount importance to us. We are committed to working as a team with you, your family, and other healthcare providers to support community-based care that is well coordinated to meet the patient's needs in the home setting. Our goal is to lessen the stressful impact of a patient's condition while providing quality medical care for the patient. Our staff members expect and welcome the parent/caregiver involvement in development, planning, and implementation of care for the patient. Your questions about care are welcome. We will do our best to answer or seek answers to your questions regarding the care and treatment provided to the patient. We are committed to uphold the rights of our clients as healthcare patients and recognize our responsibilities in providing services. 
STARTING CARE / ADMISSION: 
The first step in the admission process is for us to get to know you, the patient (child), and your family and to help identify needed services. We will determine which services required could be provided directly by WHEN KIDS PLAY, and which may be provided through coordination with other organizations. Admission to the agency must be accompanied by the direction of a physician including a physician referral for services. We will need information regarding the patient's medical condition and history, medications and current treatments, family medical history, and medical records review when applicable. 
HOURS OF OPERATION AND AFTER HOURS COVERAGE
Our office is open Monday through Friday from 8:00am to 5:00pm, except during company holidays. You may contact us by calling 817-475-3358 or emailing lbrown@whenkidsplay.com. After hours and weekends/holidays you may leave a voice message, text, or email at the contacts above. In the case of an emergency, go to the nearest emergency room or call 911. 
WEATHER / EMERGENCY ARRANGEMENTS:
During extreme weather conditions we will make every effort to provide for the safety of patients and family who are in the process of receiving care from our staff. Safety of all staff, patients, and families will be considered first in the provision / rescheduling decisions for care. Care provided during emergency conditions will be scheduled on a prioritized basis. We will attempt to contact you, the family, in the event we must reschedule or cancel a home care visit. In the event of extreme weather and /or utilities failures, please attend to emergency broadcast methods for your area. 
SCHEDULING
Scheduling is arranged between the family and the direct care provider.  In the event that a staff member cancels, we will make every attempt to meet plan of care (number of visits recommended) including rescheduling missed visits or offering other staff to make up missed visits when possible. (Therapy visits may not be provided on official holidays). If you wish to cancel a visit, please give us as much advanced notice as possible so that we may reschedule or re-assign the therapist. Please note that excessive repeated missed visits and no-shows may be considered for dismissal from the agency. 
PHYSICAL, OCCUPATIONAL, AND SPEECH THERAPY
Physical, Occupational, and Speech Therapy services are proveded by a licensed therapist or therapy assistant under the direction of a therapist. The appropriate therapist develops a plan in coordination with the physician to support the patient's achievement of maximum function, development, communication, mobility, and independence or to address another specifically identified care need. 
SUPPLIES AND EQUIPMENT
The child receiving home care services may require supplies and equipment to perform care needed and outlined in the plan of care. Personal care items usually must be provided by the family and are not reimbursed by most insurance programs. Supply needs are coordinated through appropriate providers according to payer guidelines, necessity, and patient/caregiver references. The agency may bill for some items, or may arrange for services through another provider, or may refer to another organization for services, supplies, and equipment. 
NON-DISCRIMINATION:
As a recipient of Federal financial assistance, WHEN KIDS PLAY LLC does not exclude, deny benefits to, or otherwise discriminate against any person on the basis of race, color, national origin, disability, or age in admission to, participation in, or receipt of the services and benefits under any of its programs and activities, whether carried out by WHEN KIDS PLAY LLC directly or through a contractor or any other entity with which WHEN KIDS PLAY LLC arranges to carry out its programs and activities.

This statement is in accordance with the provisions of Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975, and Regulations of the U.S. Department of Health and Human Services issued pursuant to these statutes at Title 45 Code of Federal Regulations Parts 80, 84, and 91.

In case of questions, please contact:
WHEN KIDS PLAY LLC 
Contact Person/Section 504 Coordinator:  Leilani Brown
Telephone number:  817-475-3358
TDD or State Relay number:  800-735-2989

DOCUMENTATION AND SUPERVISION:
When Kids Play maintains a clinical record on each client receiving services in accordance with applicable state and federal regulations. Agency representative are instructed on documentation requirements, and documentation is required for completion of billing and payroll functions. Your clinical record is used to coordinate care, communicate between staff and other providers, document progress and care delivered, and assist with validating care for third party payers.  
We review the record when it is turned into the agency and evaluate the documentation of care delivered for compliance to the physician orders, regulations, agency policies, and standards of care. Documentation also includes supervision performed, assessments, summaries, addendums, and physician orders for care. Your records are kept strictly confidential by our staff and are protected against loss, destruction, unauthorized use / access / tampering. Your records are used to provide clinical information and for authorization purposes. Please see our privacy policies for more information about rights and responsibilities regarding client records. 
PATIENT AND FAMILY SATISFACTION:
We are committed to providing high quality care and we value your input into how well we are doing. Please ask questions if something is unclear regarding the care you receive or don’t receive. Ask if you are unclear about your plan of care, your responsibilities, or if you do not understand something about the way services are provided. 
Periodically, we will contact you to conduct a Patient / Family Satisfaction Survey. Please help us measure and improve the care we provide by participating in this feedback. 
If you have a concern or complaint, we welcome your input. Please call 817-435-7233, or email sbrown@whenkidsplay.com or write to us at Compliance Officer 1169 N. Burleson Blvd. Ste 107-225, Burleson, TX 76028. Please refer to our Compliance Plan and Policies for more information. 
PLAN OF CARE, TREATMENT / SERVICES, PHYSICIAN INVOLVEMENT
The individualized plan of care for each client is developed with the involvement / input from you, your child, family/caregivers, and other professional team members, and designated physicians. This plan is based on the identified needs, problems, goals, and physician's orders. The schedule of interventions, your environment, and personal preferences will be considered whenever possible. Each plan of care is reviewed and updated as needed, based on changing needs, progress, and as required by law. 
You have certain rights associated with the patient's care: 
As family or guardian, you may exercise rights for the patient (child) until they are able to exercise their own rights independently. Proper identification and verification of identity will be conducted. 
You will be requested to consent for treatment prior to the beginning of care. Care providers will be identified by name and title prior to start of care. 
You have the right to be a part of identifying needs and problems and determining goals.
You have the right to be a part of determining the plan of care (what kind of services, including frequency / duration).  
You have the right to be informed in advance about changes in the plan of care. 
You have the right to request information about diagnoses, prognosis, and treatment for the purpose of informed consent. 
You have the right, before the initiation of care, to be advised of financial responsibilities for both you and for any third party payer. 
You have the right to refuse, withhold, or withdraw medical treatment at any time.
You have the right to choose to change providers.  
You have the right to be referred elsewhere if the needed services cannot be provided by this agency. 
We will inform you if the patient will need to be discharged for any reason, other than your request, and provide for a transfer of care as much as possible. (Please see agency policy for Discharge and Transfer of Care.)
You have the right to an appropriate assessment in response to reports of pain, receive information about pain relief measures, and pain management strategies. Our staff will attempt to assist in pain management that is within their scope of practice. 
You may provide an advance written Directive to Physicians and to the agency, or to make a non-written directive regarding your right to withhold or withdraw life sustaining procedures in the event of a terminal condition (DNR orders). Agency policy is to provide life sustaining / life saving care in the absence of a DNR order.  
You have the right to execute a Durable Power of Attorney for Health Care under the Civil Practice and Remedies Code. 
You may File a complaint if you believe your rights have been violated without retaliation from the agency.
You have certain responsibilities associated with the patient's care:
Give accurate and complete health information concerning past illnesses, hospitalizations, medications, allergies, and other pertinent information. 
Assist in developing and maintaining a safe environment for the patient.
Use and maintain equipment as instructed. 
Inform the agency / staff when you will not be able to keep a home health visit, allow time ahead to allow us to cancel / reschedule. 
Participate in the development and update in the plan of care and remain under a physician's care. 
Express any concerns about the ability to follow and comply with proposed plan of care / course of treatment. Understand / ask about and accept consequences of non-compliance. 
Notify us of unexpected changes in the patient's condition, including contagious illnesses, hospitalizations, emergency room visits, etc. 
Treat agency staff and property with respect. Provide for a safe environment for staff to provide services. 
Report the presence of pain and participate in pain management. 
Pay for all services not paid by a third party in a timely manner. 
Provide feedback about service needs and expectations. 
Notify the agency immediately if there are any changes in prescriptions, advanced directives, guardianship of the child, residence, phone number, physician, emergency contacts, choice of home providers, or insurance providers. 
RESPONSIBILITIES OF WHEN KIDS PLAY
Be prompt and courteous with delivery and provision of services.  
Inform patients / caregivers of changes in plans of care / scheduling. 
Educate the caregiver on use of equipment, care provided, and home program / strategies. 
Treat client and family with respect and dignity and use age and developmentally appropriate activities. 
Use fully screened, qualified health care professionals. 
Provide quality care without condition or discrimination. Respect advanced directives. 

​

Notice: When Kids Play may photograph or video clients and surroundings for the purposes of evaluation and treatment. These photos/videos are considered PHI and are protected under privacy policy. They are not used publicly or published without permission and not shared with persons outside of direct care for the client. Consent for this is implied in consent for treatment, but opting out of photo/video consent can be requested. 

If you need to contact us regarding any policies, complaints, concerns, or questions, please feel free to do so here or to call 817-475-3358. 

WHEN KIDS PLAY

• PRIVACY POLICY

Notice of Privacy and Confidentiality Practices NOTICE OF PRIVACY PRACTICES Your Information. Your Rights. Our Responsibilities. THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY WHEN KIDS PLAY is dedicated to maintaining the privacy of your Protected Health Information. Protected Health Information (PHI) is information about you, including demographic information, that may identify you and that relates to your past, present or future physical or mental health conditions and related health care services. In conducting day-to-day business, WHEN KIDS PLAY will create PHI regarding you and the treatment and services we provide to you. WHEN KIDS PLAY is required by law to maintain the privacy of PHI that identifies you, and to abide by the terms of this Notice. Your Rights

• You have the right to:

Get a copy of your paper or electronic medical record
Request confidential communication
Ask us to limit the information we share
Get a list of those with whom we’ve shared your information
Get a copy of this privacy notice
Choose someone to act for you
File a complaint if you believe your privacy rights have been violated
Your Choices You have some choices (you may opt out or opt in) in the way that we use and share information as we:
Tell family and friends about your condition
Provide disaster relief
Include you in an agency directory
Provide mental health care
Market our services and sell your information
Raise funds

• Our Uses and Disclosures We may use and share your information as we:

Treat you
Run our organization
Bill for your services
Help with public health and safety issues
Do research
Comply with the law
Respond to organ and tissue donation requests
Work with a medical examiner or funeral director
Address workers’ compensation, law enforcement, and other government requests
Respond to lawsuits and legal actions

Your Rights

When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.

• Get an electronic or paper copy of your medical record

You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. Ask us how to do this.
We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.

• Ask us to correct your medical record

You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this.
We may say “no” to your request, but we’ll tell you why in writing within 60 days.

• Request confidential communications

You can ask us to contact you in a specific way (for example, home or office phone, text, or email) or to send mail to a different address.
We will say “yes” to all reasonable requests.

• Ask us to limit what we use or share

You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say “no” if it would affect your care.

• If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say “yes” unless a law requires us to share that information.
• Get a list of those with whom we’ve shared information

You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why.
We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

• Get a copy of this privacy notice

You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.
This policy will be posted on our agency website. 
We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

• Choose someone to act for you

If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.
We will make sure the person has this authority and can act for you before we take any action.

• File a complaint if you feel your rights are violated

You can complain if you feel we have violated your rights by contacting us using the information on page 1.
You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting hhs.gov/ocr/privacy/hipaa/complaints/.
We will not retaliate against you for filing a complaint.

Your Choices

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions. In these cases, you have both the right and choice to tell us to:
Share information with your family, close friends, or others involved in your care
Share information in a disaster relief situation
Include your information in an agency directory
If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety. 
In the following cases we never share your information unless you give us written permission:
Marketing purposes
Sale of your information
Most sharing of therapy notes
In the case of fundraising:
We may contact you for fundraising efforts, but you can tell us not to contact you again.
Our Uses and Disclosures How do we typically use or share your health information? We typically use or share your health information in the following ways. Treat You
We can use your health information and share it with other professionals who are treating you.
Example: A doctor treating you for an injury asks another doctor about your overall health condition.
Run our organization
We can use and share your health information to run our practice, improve your care, and contact you when necessary.
Example: We use health information about you to manage your treatment and services.
Bill for your services
We can use and share your health information to bill and get payment from health plans or other entities.
Example: We give information about you to your health insurance plan so it will pay for your services.
How else can we use or share your health information We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes. For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html. Help with public health and safety issues
We can share health information about you for certain situations such as:
Preventing disease
Helping with product recalls
Reporting adverse reactions to medications
Reporting suspected abuse, neglect, or domestic violence
Preventing or reducing a serious threat to anyone’s health or safety
Do research
We can use or share your information for health research.
Comply with the law
We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law.
Respond to organ and tissue donation requests
We can share health information about you with organ procurement organizations.
Work with a medical examiner or funeral director
We can share health information with a coroner, medical examiner, or funeral director when an individual dies.
Address workers’ compensation, law enforcement, and other government requests
We can use or share health information about you:
For workers’ compensation claims
For law enforcement purposes or with a law enforcement official
With health oversight agencies for activities authorized by law
For special government functions such as military, national security, and presidential protective services
Respond to lawsuits and legal actions
We can share health information about you in response to a court or administrative order, or in response to a subpoena.

Our Responsibilities
We are required by law to maintain the privacy and security of your protected health information.
We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
We must follow the duties and privacy practices described in this notice and give you a copy of it.
We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.
For more information see: hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.
Changes to the Terms of this Notice We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request and on our web site. Other Instructions for Notice
Effective June 2016
Privacy Officer Shane 817-495-7233 sbrown@whenkidsplay.com
WEBSITE PRIVACY POLICY
We recognize that you may be concerned about our use and disclosure of your personal information. Your privacy is very important to us, and the following will inform you of the information that we, When Kids Play, may collect from you, and how it is used. By using our Web site, www.whenkidsplay.com, you are accepting the practices described in this policy.
Information Collection
We may collect non-personal information, such as a domain name and IP Address. The domain name and IP address reveals nothing personal about you other than the IP address from which you have accessed our site. We may also collect information about the type of Internet browser you are using, operating system, what brought you to our Website, as well as which of our Web pages you have accessed.
Additionally, if you communicate with us regarding our Website or our services, we will collect any information that you provide to us in any such communication.
We may contact you via email in the future to tell you about specials, new products or services, or changes to this privacy policy.

Information Use
We use the collected information primarily for our own internal purposes, such as providing, maintaining, evaluating, and improving our services and Website, fulfilling requests for information, and providing customer support.

Security
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it.
If we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for "https" at the beginning of the address of the web page.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

• Cookies

We use "cookies" on this site. A cookie is a piece of data stored on a site visitor's hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site.

• Sharing

We will not sell or otherwise provide the information we collect to outside third parties for the purpose of direct or indirect mass email marketing.
We will disclose personal information and/or an IP address, when required by law or in the good-faith belief that such action is necessary to:
Cooperate with the investigations of purported unlawful activities and conform to the edicts of the law or comply with legal process served on our company
Protect and defend the rights or property of our Website and related properties
Identify persons who may be violating the law, the rights of third parties, or otherwise misusing our Website or its related properties
Please keep in mind that whenever you voluntarily disclose personal information online - for example through e-mail, discussion boards, or elsewhere - that information can be collected and used by others. In short, if you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return.
Ultimately, you are solely responsible for maintaining the secrecy of your personal information. Please be careful and responsible whenever you are online.

• Links

This Website may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

• Surveys & Contests

From time-to-time our site may request information via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.

• Consent

By using this Website, you consent to the collection and use of information as specified above. If we make changes to our Privacy Policy, we will post those changes on this page. Please review this page frequently to remain up-to-date with the information we collect, how we use it, and under what circumstances we disclose it. You must review the new Privacy Policy carefully to make sure you understand our practices and procedures.

If you feel that we are not abiding by this privacy policy, you should contact us immediately via telephone at (817) 495-7233 or via mail Attn: Privacy Policy, 1169 N. Burleson Blvd Ste. 107-225, Burleson, TX 76028.

WHEN KIDS PLAY

• COMPLIANCE PLAN

When Kids Play is a provider of Home Healthcare services. When Kids Play provides Home Health to a varied population of clients and patients between the ages of 0 and 20. When Kids Play is a provider of services with several different payer sources and under many different programs. Patient’s in many of the programs are provided those services via Federally-funded medical programs such as Medicaid, CBA, MDCP and other insurance payers. When When Kids Play provides services to our patient’s we agree to follow the rules and regulations of the government that apply to these programs.
It is the intent of When Kids Play to utilize the Ethics and Compliance Program Plan to provide guidance regarding compliance, ethics, and conduct to all employees and contractors of When Kids Play. The Ethics and Compliance program contains several parts: The Ethics and Compliance Program Plan and the Code of Conduct. These Policies have been prepared to provide a resource for managers, employees, and contractors of When Kids Play.

Policy

It is the policy of When Kids Play to:
Be educated in the regulations and standards governing our industry
Obey regulations, laws, and standards
Conduct business ethically
Participants in the Ethics and Compliance Program Plan
This Ethics and Compliance Program Plan, policies, procedures and concepts apply to all When Kids Play employees, associated providers, vendors, and patients.

Commitment
When Kids Play has an ongoing commitment to ensuring that its affairs are conducted in accordance with applicable law, standards, and sound ethical business practices. Compliance is challenging because the regulatory requirements are complex and ever changing. To further our commitment to compliance and to protect our employees and patients, When Kids Play has developed our Ethics and Compliance Program to make sure we address those regulatory issues and standards likely to be of most consequence to our operations and patient care.

Expectation of the Participants
Each of us are personally accountable for our individual decisions and actions. We must all follow a course of conduct that preserves and enhances When Kids Play’s reputation of honesty and integrity. It is critical that we understand the laws, company policies, and contractual obligations that apply to our specific area of service. We should never misuse our authority, whether for personal interests or to the detriment of When Kids Play.

Purpose of the When Kids Play Ethics and Compliance Program
The Program is designed, implemented, and maintained:
To establish a culture that promotes prevention, detection, and resolution of instances of conduct that do not conform to laws, standards, and ethical business practices.
To communicate and demonstrate the corporate commitment to compliance.
To establish monitoring and benchmarks that will ingrain compliance as part of the woven fabric of When Kids Play.
To guide management and employees in efficient management and operations.
To provide ethical leadership and install systems to facilitate ethical and legal conduct.
To improve the quality of care for our patients.
To provide information, guidance, and education regarding ethics, regulatory requirement, and standard of practice.

The Program has the following key elements:
Written practice and ethical standards promoting and ethical culture; policies, and procedures.
Director of Corporate Ethics and Compliance.
Ethics and Compliance Committee responsible for implementing and maintaining the Program who report to the President and the Board of Directors.
Appropriate education and training.
Reporting channels to field questions, concerns, and to report complaints; anonymously if preferred, and without fear of retaliation. These mechanisms include e-mails and voicemail.
Participants may voice their concerns or complaints to the following address:
 
Attention: Corporate Ethics and Compliance Department
Or to the following e-mail address: sbrown@whenkidsplay.com
Or to the following number: 817-495-7233
Participants who report concerns or complaints shall be protected from any and all retaliation.
Publicize guidelines and enforce standards
Audit and Monitor
Risk Assessment: Assess risks and use data to create an effective program
Employ detection, corrective action and prevention
(Reference: Expectations from the US Sentencing Guidelines, Healthcare Compliance Association 7 elements, COSO Risk Management and Deficit Reduction Act.)
The When Kids Play Ethics and Compliance Program as described in the document is intended to establish a pattern for legal compliance by our Owners, Managers, employees, providers, vendors and patients. It is not intended to set forth all of the programs, policies and practices of When Kids Play that are set up to maintain compliance. When Kids Play already maintains compliance practices and those practices continue to be a part of the Company’s overall compliance efforts.

SCOPE
This Plan shall apply to Federal and State regulations (as applicable) , Clinical Standards of Practice, Coding Rules, Accounting and Billing standards, Fair Labor Laws, Legal concepts, and good judgment of daily business practices.

ADMINISTRATIVE RESPONSIBILITY
Review and amend the Ethics and Compliance Program Plan.
Develop methods to ensure that When Kids Play employees are aware of and understand the Ethics and Compliance Program Plan, the Code of conduct, Policies, and standards.
Assist in developing and delivering educational and training programs.
Formulate appropriate policies to guide billing.
Work with the Board and Executive Management to develop plans for implementing When Kids Play policies.
Coordinate audits of medical charts and associated billing.
Investigate instances of suspected compliance issues and develop appropriate corrective actions.
Prepare and Annual Ethics and Compliance Review and prepare proposed revisions to the Ethics and Compliance Program Plan.
Provide other assistance as directed by the Board and the Executive Management team.

CORPORATE ETHICS AND COMPLIANCE COMMITTEE
To further its commitment and to facilitate an active Ethics and Compliance Program, When Kids Play has established an Ethics and Compliance Committee. The Ethics and Compliance Committee shall establish and maintain oversight of the When Kids Play Ethics and Compliance program activities. Any actual or perceived violations detected by the Director of Corporate Ethics and Compliance shall be immediately communicated to this Committee. Specific oversight for the Committee includes:
Conducing/directing investigations.
Serving as an appeals mechanism for alleged compliance issues.
Defining When Kids Play ethics and compliance policies and recommending changes to the bylaws as necessary.
Standardizing ethics and compliance policies across the organization.
Enforce or recommend action for policy violations.
Developing the mechanism for measuring the effectiveness of specific ethics and compliance initiatives.
Approving the audit methodology of the Ethics and Compliance program.

COMPLIANCE COMMITTEE MEMBERS
To assist the Director of Ethics and Corporate Compliance in the development and implementation of compliance efforts the Ethics and Compliance Committee has been formed. The Director of Corporate Ethics and Compliance shall chair the Committee. The Ethics and Compliance Committee will consist of :
The Director of Ethics and Compliance (Chair)
President
COO
Vice President/CFO
Others as determined by the Committee
POLICY GUIDELINES
Code of Conduct
When Kids Play has adopted a Code of Conduct to guide all employees in their business activities. This Code reflects common sense and ethical behavior.

Billing
Principle: All claims shall be submitted accurately and the submission of false claims shall be avoided.
The policy of When Kids Play is to bill only for services actually provided. When Kids Play realizes that certain special billing requirements may apply to some government-sponsored programs or to other providers; any such requirements must be followed. In selecting codes to describe services rendered healthcare professionals, and billing personnel are to select codes that they believe. in good faith, correspond to services actually rendered, as documented in the medical record. When Kids Play health professionals, and billing personnel have a collective responsibility to be knowledgeable about the meaning of the codes applicable to their area of practice, including relevant directives from billing authorities. When Kids Play recognizes the importance of maintaining accurate patient accounts in accordance with applicable requirements.
When Kids Play professionals and billing personnel should never submit an invoice or a claim that is known to contain inaccurate information concerning the service provided, the charges, the identity of the provider, the date of service, the place of service, or the identity of the patient. Payments that are received in error will be refunded.
When in doubt about how to bill a particular service, including the proper code to use, no claim should be submitted until appropriate guidance is obtained from Compliance leaders. The resolution of any such billing questions should be documented in writing.
It is the responsibility of the When Kids Play health professional to ensure that appropriate documentation supports the bill being submitted.

Business Relationships
There are a variety of Federal statutes that govern the business relationships of healthcare providers such as When Kids Play. It is the responsibility of When Kids Play employees which are responsible for business relationships with persons or organizations outside of the Agency, to take steps to ensure that those relationships comply with all applicable legal requirements

EDUCATION AND TRAINING
The Director of Ethics and Compliance shall be responsible for ensuring that When Kids Play policies are disseminated to all locations.   This will be accomplished via e-mail and Website.   It will be the responsibility of the Agency Administrators and Clinical Supervisor to ensure that the employees implement and demonstrate an understanding of these policies. All training materials directed to billing or other regulatory compliance issues will be submitted to the Director of Ethics and Compliance for review prior to distribution.
All personnel up to and including the Board of Directors are required to participate in training about compliance issues. Methodologies for the dissemination of information include, but are not limited to: bulletins, professional education, memos, audio and videotapes, lectures at meetings, corporate meetings and applicable articles of interest.

PREVENTION AND DETECTION OF FRAUD
When Kids Play shall be vigilant in its efforts to recognize and prevent fraud, which is simply defined as possessing knowledge with the willful intent to deceive.
The Office of the Inspector General is the enforcement arm of the federal government. It investigates and sanctions improper conduct. It also publishes findings of its audits through special alerts:
Special Fraud Alerts serve to point out the prevalence of certain types of healthcare fraud, including:
Cost report fraud;
Billing for excessive services
Use of unlicensed or untrained staff;
Falsified plans of care;
Forged Physician signatures on plans of care;
Kickbacks that the OIG has uncovered.
The submitting of claims to Part B of Medicare for medical supplies and equipment that are not medically necessary;
Submitting claims for items that are not provided as claimed;
Double billings; and
Paying or receiving kickbacks in exchange for Medicare or Medicaid Referrals
In the early 2000s, June Gibbs Brown, HHS Inspector General, directed regulators to refocus their efforts on assisting providers to achieve compliance. Helping providers achieve compliance is a paradigm shift in philosophy.
It is philosophy that we are all in this together to deliver excellent care, meet requirements, and prevent fraud and abuse. Those of us in healthcare are called to higher duties than employees in other industries. First, we take care of patients. Second, we have the ability to detect and prevent fraud and abuse.
The Ethics and Compliance Director/Committee will participate in training employees in prevent of Fraud, Abuse, and Waste.

MONITORING
Under the direction of the Ethics and Compliance Director/Committee, an audit of medical records, personnel files, corresponding bills, and other documents along with patient and employee interviews shall be conducted periodically and reviewed for compliance. These audits and interviews will be conducted at least annually. The Agency may, after consultation with legal counsel, engage external compliance experts to review records.
If any of these reviews identify billing issues or irregularities, the Director of Ethics and Compliance shall report to the Compliance Committee and proceed accordingly.

QUALITY ASSURANCE, PROCESS IMPROVEMENT
The Ethics and Compliance Director/Committee shall quantify and analyze audit data and then benchmark and report the findings. It shall make recommendations to improve compliance, quality, business efficiency, and effectiveness.

REPORTING COMPLIANCE ISSUES
As a general matter, questions should be presented initially to your supervisor. The training materials will inform employees that they may report concerns or any activity that they believe to be inconsistent with Agency policies, the Code, or legal requirements directly to the Director of Ethics and Compliance, to a designated e-mail address, or via first class mail.
The materials will explain how to report violations and how to contact the Director of Ethics and Compliance and the Compliance Committee. Employees, who in good faith report possible compliance issues, should not be subjected to retaliation or harassment as a result of the report. All concerns about possible retaliation or harassment should be reported to the Ethics and Compliance Director/Committee.
The Committee shall maintain a record of each submission, including the date of the acknowledgement and actions taken. The Director of Ethics and Compliance will review all submissions received and will determine along with the Committee, as appropriate, all means of investigating and addressing any submissions. All Submissions will remain confidential as necessary under the circumstances.
If you submit a concern, complaint, or violation with your contact information, the Director of Ethics and Compliance or a member of the Committee will follow-up with you.
If you submit a concern, complaint, or violation without your contact information, the Director of Ethics and Compliance or a member of the Committee will investigate to the fullest extent possible, given the information provided. If the submission provided to the hotline contains insufficient information to permit a meaningful investigation, the log will contain an explanation as to why no investigation was undertaken.
Participants may voice their concerns or complaints to the following address:
When Kids Play 1169 N. Burleson Blvd Ste: 107-225 Burleson TX 76028
Attn: Ethics and Compliance Director/Committee
Or to the following email: sbrown@whenkidsplay.com
Or to the following hotline number: 817-495-7233
Again any retaliation against an employee who, in good faith reports a suspected violation is prohibited.
Please report any retaliation claims to the Ethics and Compliance Director/Committee.

INVESTIGATING COMPLAINT ISSUES
Whenever conduct inconsistent with When Kids Play policies and procedures, or applicable laws, rules , and regulations is reported, the Director of Ethics and Compliance along with the Committee will determine if there is reasonable cause to believe that a material compliance issue may exist. Responsibility for conducting the review will be decided on a case-by-case basis by the Director of Ethics and Compliance and the Committee as appropriate.
The results of the inquiry will be confidential and made available to the Committee and their advisors, as necessary. When Kids Play employees shall cooperate fully with any inquiries and investigations. To the most practical and appropriate extent, efforts should be made to maintain the confidentiality of such inquiries and the information gathered.

CORRECTIVE ACTION PLANS
Whenever a compliance issue has been identified, the Director of Ethics and Compliance shall have the responsibility and authority to take or direct appropriate action to address that issue. In developing a corrective action plan, the Director of Ethics and Compliance may obtain guidance from the Committee, legal Counsel, or other personnel as necessary. All corrective action plans shall be set forth in writing and conveyed to the Ethics and Compliance Committee.
Corrective clinical, billing, or business related action, should be designed to ensure not only that the specific issue is addressed but also that similar problems do not occur in other areas or departments. For example, corrective action may require that billing is handled in a designated way, that billing responsibility is reassigned, that certain training take place, restrictions are imposed on billing by health professionals, repayment is made, or that the matter is disclosed externally.
If it appears that certain individuals have engaged in practices that raise compliance concerns, the corrective action plan should identify actions that will be taken to limit non-compliant outcomes.
Corrective action may include recommendations that a sanction or disciplinary action is imposed. Moreover, if the Director of Ethics and Compliance believes that any non-compliance has been willful, that belief, and the basis for it, should be reported to the Ethics and Compliance Committee. Employees and agents who have engaged in willful misconduct will be subject to disciplinary action up to and including termination.