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eQHealth Solutions, Inc.

eQHealth Solutions, Inc. Compliance Plan Introduction. Corporate Mission “To improve the quality of health and health care by using information and collaborative relationships to enable change.” Corporate Vision

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eQHealth Solutions, Inc.

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  1. eQHealth Solutions, Inc. Compliance Plan Introduction

  2. Corporate Mission “To improve the quality of health and health care by using information and collaborative relationships to enable change.” Corporate Vision “To be an effective leader in improving the quality and value of health care in diverse and global markets.” Compliance Plan

  3. Corporate Core Values The pursuit of innovation; Integrity in the work we do; Sharing the responsibility for achieving corporate goals; Treating people with respect; Delivering products and services that are valuable to our customer; An environment of professional growth and fulfillment; Engaging in work that is socially relevant; and Continuous quality improvement. Compliance Plan

  4. The mission of eQHealth Solutions is to support our core values in an environment where professional behavior is expected by all. As we pursue this mission, we are committed to conducting all of our business in an ethical and law-abiding fashion. We will maintain a business culture that builds and promotes compliance consciousness and encourages employees, managers, subcontractors and board members to conduct eQHealth Solutions business with honesty and integrity. Compliance Plan Introduction

  5. Responsibility and accountability for actual compliance with laws, regulations and policies rests with each individual employee, manager, sub-contractor or board member. Managers are accountable for ensuring that those for whom they are responsible are adequately trained and for detecting noncompliance with applicable policies and legal requirements when reasonable management efforts would have led to the discovery of problems or violations. Compliance Plan Introduction

  6. To promote compliance and implement a compliance program, eQHealth Solutions and its Board of Directors have taken the following steps: Established a Compliance Committee (CC) consisting of appointed members of the eQHealth Solutions Board of Directors and employees of the Company appointed by the Board. Currently the appointed employees are the Director of Human Resources. The CC shall: *Appoint a Compliance Officer (CO) *Oversee the design, implementation and effectiveness of the Compliance Program *Ensure that the Compliance Program is communicated to all employees, managers, sub-contractors and Board members. *Provide appropriate guidance to investigations being conducted by the Compliance Officer Compliance Plan Introduction

  7. Designate a Compliance Officer (CO) who shall: *Report directly to the Board of Directors *Establish policies and procedures to ensure compliance withal applicable federal and state laws and regulations as well as eQHealth Solutions Company policies. *Monitor day-to-day compliance activities *Develop training programs relative to eQHealth Solutions’s Compliance program *Communicate instances of non-compliance to the Board of Directors for corrective, restorative and/or disciplinary action. Compliance Plan Introduction

  8. 3. Approve the following components of the Compliance Program: a. A “Standards of Conduct Guide” (SOC) – To communicate to all employees, managers, sub-contractors and board members an expectation and requirement of ethical conduct and compliance with all applicable laws, policies rules and regulations. b. A “Statement of Values and Code of Ethics” – Ethical behavior is the responsibility of every eQHealth Solutions employee, manager, sub-contractor and Board member. Each has a personal obligation to report any activity that appears to violate applicable laws, regulations, rules policies, procedures or this SOC Guide. c. A “Conflict of Interest Policy” – To protect eQHealth Solutions when it is contemplating entering into a transaction or arrangement that might benefit the private interest of eQHealth Solutions and other business entities affiliated to it and those employees, officers, directors, managers and sub-contractors or might result in a possible excess benefit transaction. Compliance Plan Introduction

  9. d. A “Fraud and Abuse Hotline” – The purpose of the hotline is to provide eQHealth Solutions employees, managers and board members an alternative method of reporting instances of wrongdoing, fraud, waste and abuse, other than using regular administrative channels. Compliance Plan Introduction

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