Section 05 / 12 · 2026 Compliance Plan

Standards of Conduct — Specific Risk Areas

Prohibited Conduct

1. Using billing codes and billing for items/services not actually documented. All claims for diagnostic procedures correctly identify the services ordered by the physician or other authorized individual and performed by the Company. The codes that are used to bill will accurately describe the service that was ordered and performed.
2. Altering or completing the physician’s order in any way. Policies will be designed to ensure that the Company can support services billed to payors with documentation obtained from the physician ordering the procedure, an authorized person on the physician’s staff or other individual authorized by law to order tests. The Company will not: (1) use information provided by the physician or other authorized individual from earlier dates of service; (2) create diagnosis information that has triggered reimbursement in the past; (3) use computer programs that automatically insert diagnosis codes without receipt of diagnostic information from the ordering physician or other authorized individual; or (4) make up information for claim submission purposes. The Company will always: (1) contact the ordering physician, authorized person on the physician’s staff or other individual authorized to order diagnostic imaging services to obtain information in the event that such information was not provided; and (2) accurately translate narrative diagnoses obtained from the physician or other authorized individual to ICD–10–CM codes.
3. Upcoding, such as, for example, using a billing code that provides a higher or reimbursement, settlement amount or other payment than the code that more accurately reflects the services performed and/or items supplied.
4. Inappropriate balance billing.
5. Inadequate resolution of overpayments.
6. Lack of integrity in computer systems.
7. Computer software programs that encourage billing personnel to enter data in fields indicating services were rendered though not actually performed or documented.
8. Failure to maintain the confidentiality of information/records.
9. Knowing misuse of provider identification numbers, which results in improper billing.
10. Duplicate billing in an attempt to gain duplicate payment.
11. Failure to properly use modifiers.
12. Incentives that violate the anti-kickback statute or other similar Federal or state statute or regulation.
13. Joint ventures with referral sources that violate applicable law.
14. Routine waiver of co-payments and billing third-party insurance only.
15. Discounts and professional courtesies.
16. Internal coding practices, including software edits, inconsistent with applicable Federal, state, and private payor health care program requirements.
17. Coding without documentation of all physician and other professional services.
18. Billing for services provided by unqualified or unlicensed clinical personnel.
19. Availability of all necessary documentation at the time of coding.
20. Billing for services with respect to which it is believed the claim will be denied, including seeking reimbursement for a service that is not covered.
21. Billing for items or services not ordered.
22. Resubmission of denied claims with different information in an attempt to be improperly reimbursed.
23. Altering medical records.
24. Manipulating a patient’s diagnosis or services rendered or items supplied in order to receive improper payment.
25. Improper billing resulting from a lack of communication among the Company, the physician and the patient.
26. Employing persons excluded from participation in Federal health care programs (applicable when dealing with those Federal programs).
27. Failure to document verbal orders and/or to receive a written confirmation from the treating physician or other authorized person.
28. Failure to use proper provider numbers and/or use such numbers correctly.
29. Failure to have written Agreements for all arrangements involving physicians and other providers, including, without limitation, physician practice management agreements.
30. Failure to have all such written agreements reviewed and approved by Corporate Counsel before they are executed and made effective.
31. Failure of any assignment or “factoring” of workers’ compensation accounts receivable liens, if applicable, to be conducted in accordance with requirements of California Labor Code Section 4903.8 concerning payment to the provider, filing and service of the assignment of lien, and declarations as to the provision of products and services to the injured employee and of the truth and accuracy of the billing statement attached to the lien.
32. Failure of any electronic billing (“e-billing”) for services provided by the Company to be conducted in accordance with electronic billing standards and rules set forth in the Medical Billing and Payment Guide, the Electronic Medical Billing and Payment Companion Guide and the regulations, which are posted on the Division of Workers’ Compensation website (www.dir.ca.gov/dwc/), and shall adhere to the specifications in the Medical Billing and Payment Guide and the Companion Guide and the regulations at title 8 California Code of Regulations sections 9792.5.0 – 9792.5.3.
33. Compliance as an Element of Employee Performance Assessment Plan. The Company believes that the promotion of and adherence to compliance is an important element in evaluating the performance of managers, supervisors and all other employees. They, along with other employees, will be periodically trained in new compliance policies and procedures. In addition, all managers and supervisors involved in the sale, marketing, or billing of the Company’s services, and those who oversee facility operations will periodically (1) discuss with all supervised employees the compliance policies and legal requirements applicable to their function; (2) inform all supervised personnel that strict compliance with these policies and requirements is a condition of employment; and (3) disclose to all supervised personnel that the Company will take disciplinary action up to and including termination for violation of these policies or requirements. In addition to making performance of these duties an element in evaluations, the Company has also chosen to include in its compliance program a policy that managers and supervisors may be sanctioned for failure to adequately instruct their subordinates or for failing to detect non-compliance with applicable policies and legal requirements, where reasonable diligence on the part of the manager or supervisor would have led to the discovery of any problems or violations and given the laboratory the opportunity to correct them earlier.

Marketing Practices

The compliance program requires honest, straightforward, fully informative and non-deceptive marketing, in recognition of the fact that it is in the best interests of patients, physician, health plans and other payors that physicians and other individuals authorized to order diagnostic imaging services fully understand the services offered by the facility, the services that will be provided when tests are ordered, and the financial consequences when services are billed. Accordingly, the Company will ensure that their marketing information is clear, correct, non-deceptive and fully informative.

Restrictions on Referrals of Workers’ Compensation Patients

The Company will comply with the restrictions on referrals by individuals having financial relationships with a provider or other “interested parties” as set forth in California Labor Code Sections 139.3 and 139.32, to the extent applicable.