Daybreak Venture, LLC Compliance Information

Daybreak Venture, LLC and the nursing facilities it manages (collectively “Daybreak”) are committed to conducting its operations in an ethical and lawful manner. Daybreak has developed and implemented a Compliance Program that applies to all employees. Daybreak intends to prevent, detect and correct violations of applicable law, regulations, Daybreak’s policy and procedures and the Ethics Code of Conduct and other applicable standards. As stated in our Ethics Code of Conduct policy and procedures, adherence to the law and the highest ethical standards of Integrity is the foundation of everything we do. Meeting this standard and complying with all applicable laws, regulations and Daybreak’s policy and procedures requires a commitment from each of us.

Ethics Code of Conduct Principles:

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A. Quality Resident Care: It is an expectation that Daybreak will provide high quality resident care, in a compassionate manner and in a safe environment.
B. Responsible for Reporting: it’s every employee’s duty to report abuse, fraud, neglect, violations of the Code of Conduct, and violations of Federal and/or State standards.
C. Reporting Concerns: Employees are urged to call the Chief Compliance Officer/designee using the Compliance Hotline (888) 983-4310 or use the compliance reporting form, or email at Compliance@DaybreakVenture.com and/or call Texas Health and Human Services Abuse Hotline at (800) 252-5400.
D. Workplace Conduct – will be safe, professional and cooperative.
E. Non-Discrimination –equal opportunity and non-discrimination.
F. Non-Retaliation – No harassment for reporting violations.
G. Compliance with Federal, State and local laws and Regulations – obey the law.
H. Health Care Fraud and Abuse Prevention – if you suspect it, report IT.
I. Coding and Reimbursement Truthfulness – code and bill accurately.
J. Accurate and Truthful Documentation – do not falsify documents.
K. Record Retention and Destruction – keep records according to the law.
L. Confidentially – HIPAA, keep employees and resident health information private.
M. Conflict of Interest – no bribes and/or inappropriate behavior for self-gain.
N. Business Relationships and Referrals (Anti-Kick Back) – do not “Pay” for residents referrals.
O. Protection of Daybreak Assets – Protect items from damage, theft and/or loss.
P. Gifts and Gratuities – No solicit or receive outside of the limits of the law.
Q. Political/Lobbying Activity – do not use Daybreak for self-political or self -lobbying activity.
R. Fair Competition – violation and unfair trade practice; bribery also known as anti-trust laws.
S. Prescription Drugs and Controlled Substance – report medication errors; misuse of prescriptions.
T. Environmental Health and Safety – provide a habitable environment.
U. Government Investigations, Accreditations and Surveys – cooperate with investigations/surveys.
V. Ethics Code of Conduct – all Employees are expected to up hold and enforce.
W. False Claims Act, Whistleblower Provision & Texas laws – prevent fraud, waste & abuse The Employee Ethics Code of Conduct is important and by my signature below I am acknowledging that I have received, read, understands and agrees to abide by its provisions.

Compliance Integrity Agreement

To all: The Office of Inspector General (OIG) along with the Department of Justice (DOJ) and Daybreak Venture, LLC (Daybreak) and subsidiary settled an investigation. A negotiated agreement was reached. Daybreak accepts no liability but did agree to implement a plan of supervised corrective actions.

Daybreak entered into a Corporate Integrity Agreement (CIA) with the Office of Inspector General (OIG) of the United States Department of Health and Human Services (HHS) to promote compliance with the statutes, regulations and written directives of Medicare, Medicaid and all other Federal health care programs (as defined in 42 U.S.C. § 1320a-7b(f)) (Federal health care program requirements). Daybreak will ensure that during the term of the CIA it shall comply with the obligations set forth herein the CIA.

Strategic Healthcare Solutions (SHS) will be the Independent Reviewer Organization (IRO) assessing the effectiveness, reliability and thoroughness of systems, quality of care, professionally recognized standards in addition to other areas. Since all parties involved have signed off on the “Settlement Agreement”, Daybreak voluntarily entered into a Corporate Integrity Agreement (CIA) effective September 29, 2016.

The compliance obligation assumed by Daybreak under the CIA shall be five years from the effective date of the CIA. Daybreak’s Compliance Program consists of a Chief Compliance Officer, Compliance Committee, Compliance Department and Compliance Hotline (888) 983-4310.

Job responsibilities include ensuring compliance with regard to the department you work in and with all applicable Federal health care programs requirements, obligations of the Corporate Integrity Agreement, professionally recognized standards of healthcare and Daybreak’s policies. Employees are to take steps to promote such compliance. To the best of your knowledge, the department you work in is in compliance with all applicable Federal health care program requirements, the obligations of the Corporate Integrity Agreement and professionally recognized standards of healthcare. If an employee is unable to provide such a proclamation then notify the Compliance Department with the reasons at (800) 983-4310 or submit your concerns to Compliance@Daybreakventure.com .

Reporting Concerns?

Compliance Hotline (888) 983-4310 / Compliance@DaybreakVenture.com
Texas Health and Human Services Abuse Hotline at (800) 252-5400

The Seven (7) Elements to an effective Compliance Program

Policy, Procedures and Practice and Code of Conduct – are the commitments to adhere to compliance and provide quality care and ethical behavior, within the regulatory and legal requirements.
Compliance Officer and Compliance Committee Oversight – have the responsibility of monitoring the compliance program within the company and ensure the company is doing the right thing.
Sanctioned Individuals/LEIE program – is a list of Excluded individuals and organizations not allowed to work in Nursing homes who receive Medicare and Medicaid funding.
Education and Training – is the development and implementation of regular, effective education and training programs for all affected employees and the Board of Directors.
Communication and Hotlines – is the maintenance of a process, such as a hotline to receive complaints and adoption of procedures to protect the anonymity of complainants and to protect whistleblowers from retaliation. Daybreak Compliance Hotline number: (888) 983-4310.
Corrective Action – Is the development of a system to respond to allegations of improper or illegal activities and the enforcement of appropriate disciplinary actions against employees or vendors who have violated internal compliance policies, applicable statues, regulating of federal health care program requirements.
Auditing and Monitoring – is the use of audits and/or other evaluation techniques to monitor compliance and assist in the reduction of identified problem areas.