Team Post-Op, Inc. operates in a highly competitive environment and under complex and rapidly changing laws and regulations. The Compliance Program was created to define the scope of conduct expected officers, employees, agents and vendors. Compliance with applicable laws and regulations presents on-going challenges due to the complexity of the health care environment and the constantly changing regulatory landscape. In order to effectively address these challenges the Compliance Program will have the following core components:

1. Establishment of a written Code of Conduct and written policies and procedures.
2. The appointment of the Chief Operating Officer (“COO”) who is charged with the responsibility of directing Team Post-Op, Inc.’s compliance efforts, including implementing the Compliance Program.
3. The development and implementation of an education and training program.
4. Maintenance of a process for employees/agents of Team Post-Op, Inc. to report instances of possible non-compliance with applicable rules without fear of retaliation, and the adoption of procedures to protect the anonymity and confidentiality of complainants.
5. The establishment of a system to respond to allegations of improper or illegal activities and the enforcement of appropriate disciplinary action against those who have violated the applicable rules.
6. The use of audits or reviews to assess compliance and to assist in the reduction of identified problem areas.
7. The investigation and correction of identified systemic problems, and the development of policies addressing the non-employment or retention of sanctioned individuals.
8. A policy of non-intimidation and non retaliation for good faith participation in the program.

The Compliance Program is primarily intended to establish a framework for ethical responsibilities and legal compliance by Team Post-Op, Inc.

Procedure

Each core component requires more detail for implementation of Team Post-Op, Inc.’s Corporate Compliance Program

1. Written policies and procedures that describe compliance expectations :
   • Code of Conduct
   • Code of Ethics
   • Operation of the Compliance Program
   • Guidance to employees on how to communicate compliance issues
   • Describe how Potential Compliance Issues are Investigated and Resolved
2. Designate an employee vested with responsibility for the day-to-day operation of the compliance program:
   • Employee's duties may solely relate to compliance or may be combined with other duties so long as compliance responsibilities are satisfactorily carried out
   • Employee shall report directly to the entity's chief executive
   • Employee will periodically report directly to the governing body on the activities of the compliance program.
3. Training and education of all affected employees and persons associated with the provider, including executives and governing body members, on compliance issues, expectations and the compliance program operation:
   • Training will occur periodically
   • Will be made a part of the orientation for a new employee, appointee or associate, executive and governing body member.
4. Communication lines that are accessible to all employees, persons associated with the provider, executives and governing body members, to allow compliance issues to be reported; communication lines will include:
   • The Corporate Compliance Officer
   • Any member of the Governing Body
   • The Department Manager
5. Disciplinary policies to encourage good faith participation in the compliance program by all affected individuals, including policies that articulate expectations for reporting compliance issues and assist in their resolution and outline sanctions for:
   • failing to report suspected problems;
   • participating in non-compliant behavior; or
   • Encouraging, directing, facilitating or permitting non-compliant behavior; such disciplinary policies shall be fairly and firmly enforced.
6. A system for routine identification of compliance risk areas specific to the provider type:
   • Self-evaluation of such risk areas, including internal audits and as appropriate external audits
   • Evaluation of potential or actual non-compliance as a result of such self-evaluations and audits.
7. A system for responding to compliance issues as they are raised:
   • Investigation of potential compliance problems
   • Responding to compliance problems as identified in the course of self-evaluations and audits
   • Correcting such problems promptly and thoroughly and implementing procedures, policies and systems as necessary to reduce the potential for recurrence

A policy of non-intimidation and non-retaliation for good faith participation in the compliance program, including but not limited to reporting potential issues, investigating issues, self-evaluations, audits and remedial actions, and reporting to appropriate officials.