Corporate Compliance Program

Commitment to Excellent Corporate Citizenship

UATN/UAHC is committed to maintaining the highest level of professional and ethical
standards in the conduct of its business. The Company places the highest importance
upon its reputation for honesty, integrity and high ethical standards through the
implementation of the UATN/UAHC Compliance Program. The Compliance Program
shall be applicable to all staff and independent contractors whose functions and
responsibilities involve compliance, and are subject to the laws and regulations of the
United States, the State of Tennessee, and UATN/UAHC policies, procedures and
standards of conduct.

These standards can only be achieved and sustained through the actions and conduct
of all personnel of the Company. All employees of UATN/UAHC are obligated to conduct
themselves in a manner that ensures the maintenance of these standards.
UATN/UAHC will promote compliance through the continuous utilization of education,
communication, monitoring and corrective action. The primary objectives of the
Compliance Program are to:

• Generate written standards of conduct, policies and procedures for all staff
  and independent contractors.
• Appoint a compliance/privacy officer and other designated personnel, who
  are authorized to oversee that UATN/UAHC’s operations comply with the written
  standards of conduct, policies and procedures; and to ensure that the
  Compliance Program functions properly.
• Facilitate continuing education and training programs on corporate
  compliance.
• Promote effective lines of communication between the compliance
  manager, management, staff and independent contractors that will
  encourage constant adherence to the Compliance Program.
• Implement regular monitoring and auditing procedures that will proactively
  identify and reduce issues in problematic areas; and identify any activity that
  does not comply with the standards of conduct, policies and procedures.
• Formulate standards and implement processes to report, detect and
  investigate any activities that do not comply with the Compliance Program.
• Develop corrective action plans that will enforce disciplinary processes that
  are appropriate, efficient and timely for management, staff and independent
  contractors who do not comply with the Compliance Program.
• Handle inquiries by employees, subcontractors or other individuals regarding
  any aspect of compliance.
• Investigate any information or allegation concerning possible unethical or
  improper business practices and recommend corrective action when
  necessary.
• Provide guidance and interpretation to the board of directors, the chief
  executive officer and company personnel on matters related to the
  Compliance Program.
• Plan and oversee, in conjunction with the operations auditor, regular, periodic
  audits of the Company’s operations in order to identify and rectify any
  possible barriers to the efficacy of the Compliance Program.
• Ensure that independent contractors and agents who furnish medical services
  to the Company are aware of the Company’s Compliance Program including,
  without limitation, its policies with respect to the specific areas of
  documentation, coding, billing and competitive practices.
• Work with the Board of Directors, Corporate Compliance Committee, chief
  executive officer, chief financial officer, director of operations and other
  members of senior management in the preparation, development, oversight
  and the implementation of written guidelines on specific federal and state
  legal and regulatory issues as well as matters involving ethical and legal
  business practices applicable to the Company.
• Prepare an annual report to the board of directors, Corporate Compliance
  Committee and the chief executive officer concerning the compliance
  activities and actions undertaken during the preceding year, the proposed
  Compliance Program for the next year, and any recommendations for
  changes in the Compliance Program.
• Track applicable laws and regulations in the jurisdictions where UATN/UAHC
  conducts business.
• Ensure that UATN/UAHC complies with applicable laws and regulations.

Click here to download the Corporate Compliance Document (PDF 219KB).