The mission of Clover Rest Home, Inc. (“Clover Rest Home”) is to provide quality, cost-effective health care in a positive and productive work environment. In fulfilling this mission, Clover Rest Home is dedicated to adhering to the highest ethical standards and, accordingly, recognizes the importance of compliance with all applicable state and federal laws. To evidence this dedication, Clover Rest Home’s Board of Directors has adopted, developed, and implemented the Compliance Program.
The Compliance Program is intended to become a part of the fabric of Clover Rest Home’s
routine operations. Clover Rest Home endeavors to communicate to all personnel Clover Rest
Home’s intent to comply with applicable law through the Compliance Program. In addition, the
Compliance Program will:
• Assess Clover Rest Home’s business activities and consequent legal risks
• Educate all personnel regarding compliance requirements and train personnel to conduct their
job activities in compliance with state and federal law and according to the policies and
procedures of the Compliance Program
• Implement monitoring and reporting functions to measure the effectiveness of the Program
and to address problems in an efficient and timely manner
• Include enforcement and discipline components that ensure that all personnel take their
compliance responsibilities seriously
Overall responsibility for operation and oversight of the Compliance Program belongs to the
Board; however, the day-to-day responsibility for operation and oversight of the Compliance
Program rests with the Compliance Officer. The Compliance Officer will be assisted in these
duties by the Compliance Committee, which will be comprised of persons appointed by the
Board of Directors, as well as by Special Counsel.
Because of the extreme importance Clover Rest Home places on understanding and abiding by
all applicable laws and acting in accordance with its standards and procedures, the Compliance
Officer will make available a copy of the Compliance Program to all of the following persons:
directors, officers, employees, members of the medical staff, and contractors, vendors, and
suppliers (hereinafter collectively referred to as “Corporation Representatives”).
All Corporation Representatives receiving a Compliance Program Manual will be required to
submit to the Compliance Officer a written certification form to be provided by Clover Rest
Home (i) acknowledging receipt of the Manual; (ii) confirming that the person receiving the
Manual has read and understood its contents; and (iii) agreeing to be bound by and to comply
with all aspects of the Compliance Program. In addition, the agreement to be bound by and to
comply with the Compliance Program shall be included in all contracts with vendors and
No Corporation Representatives have authority to act contrary to any provision of the
Compliance Program or to condone any such violation by others. Any Corporation
Representative with knowledge of information concerning a suspected violation of law or
violation of a provision of the Compliance Program is required to report promptly such
violations in accordance with the Compliance Program’s Reporting Policy.
Corporation Representatives who violate any provision of the Compliance Program, including
the duty to report suspected violations, shall be subject to disciplinary measures. Clover Rest
Home will take steps to investigate all reported violations and will endeavor through constant
vigilance to ensure that the Compliance Program is effective in preventing, detecting, and
eliminating violations of the law in accordance with Policy 13010, Compliance Investigation
Policy and Procedure. In addition, promotion of and adherence to the Compliance Program will
be part of the job performance evaluation criteria for all Corporation Representatives.
Clover Rest Home will attempt to communicate changes to or modification of the Compliance
Program concurrent with or prior to the implementation of such changes or modifications;
however, Clover Rest Home reserves the right to change, modify, or amend the Compliance
Program or the Policy Manual as deemed necessary by Clover Rest Home without notice to
Corporation Representatives or other persons.
Should Corporation Representatives have any questions or uncertainties regarding compliance
with applicable state or federal law, or any aspect of the Compliance Program, including related
policies or procedures, they should seek immediate clarification from the Compliance Officer, a
Department Leader, Special Counsel or through the Compliance Hotline.