This notice is required by federal law and describes how medical
information about you may be used and disclosed, and how you
can get access to this information. Please review it carefully.

One of our highest priorities is protecting the privacy and confidentiality of your personal health information is used and shared on a need to know basis for the following reasons:

• The coordination and planning of your health care with the many professionals involved in your care.
• Referrals to another provider, such as a specialist, therapist, or hospital.
• Determining coverage and obtaining payment from health plans, such as private insurance or Medicare or Medicaid
• Assessing our practices, improving our care and conducting training programs for the staff involved in your care.
• Operational activities designed to maintain the required accreditation, certification, licensing and credentialing.
• To help our accountants, auditors, lawyers and other consultants maintain and improve our overall operations and delivery of care.
• Requests from or referrals to public health authorities, government oversight agencies, law enforcement agencies, the courts, coroners, or a funeral home, to the extent of the law.
• Notification and communication with your family members or your personal representative, unless you object.

By signing this notice at the end, you are acknowledging that you understand and consent to the above uses of your personal information as a normal part of your care and treatment. If there is a specific area you object to there is a space to record those objections and we will make reasonable attempts to accommodate, to the extent the law allows us.
We will NOT release of disclose your personal health information for any other uses without your specific written authorization, which you may revoke at any time. Among the circumstances where your information will NOT be released without your knowledge and specific written authorization are:

• Research information unrelated to treatment
• Psychotherapy notes containing private conversations
• Disclosure of your information to other companies for
  the purpose of marketing products or services to you.
• Fund raising purposes.

Your Health Information Rights

• Although your health record is the physical property of the nursing facility, the information in your health record belongs to you.
• You may request restrictions on certain uses and disclosures of your health information. We will attempt to accommodate if we can; however, when it relates to your treatment or billing for care provided, we are not required to agree to the restriction.
• You may request to inspect your health records and obtain copies for a reasonable copying fee. If you request your records be sent somewhere else, we cannot ensure their privacy if we do not have a privacy agreement with that agency. You may also request written copies of electronic transmissions.
• You may request in writing that we disclosed your health information to outside parties with your authorization.
• You may revoke in writing any prior written authorizations you made to disclose health information.

SIR Management referenced within this document
includes SIR Management and the facilities it consults.

l. INTRODUCTION

SIR Management and its consulting facilities are committed to conducting its business in compliance with all federal, state and local laws. In some circumstances, the interpretation and application of the law is highly technical, and common concepts of right and wrong lend little guidance. Thus, employees, who believe that they are conducting themselves properly may, in fact, be violating applicable laws. Violations of the law by employees, even unwitting violations, can subject Our Facility and the person to the risk of penalties and embarrassment. However, effective adherence to the Compliance Plan will assure employees of a maximum blanket of insulation from negative actions by others.

SIR Management and its consulting facilities can meet this commitment only through the efforts of our highly skilled care givers and dedicated support staffs. It is they who must earn the trust and respect of nursing home residents (“residents”), family members, the community and others by continuing to conduct their daily affairs with honesty, integrity, and in compliance with the letter and spirit of all applicable laws. Although honesty and integrity are individual attributes, and each individual ultimately is responsible for his or her own conduct, Our Facility is committed to maintaining a working environment that promotes these ideals and permits our employees to demonstrate the highest ethical standards in performing their daily tasks.

In order to avoid violations of law, SIR Management and its consulting facilities have implemented a formal Corporate Compliance Program concerning its nursing home practice operations. Our action in proceeding in the development and implementation of a Corporate Compliance Program should not be interpreted as concern that present management systems are inadequate. Rather, development and implementation of a Corporate Compliance Program is an element in Our Facility’s continuing effort to improve quality and performance. Federal and state agencies responsible for enforcement of Medicare and Medicaid laws and regulations applicable to healthcare providers recently have encouraged the development and implementation of Corporate Compliance Programs by healthcare providers. Because this facility is continually reviewing its compliance procedures, and because the government issues regulation changes from time to time, this Compliance Manual is fluid in that it is in a continual state of revision and updating.

Our Program will:
1. Meet or exceed the seven elements (see below) of an effective compliance program
recommended by the Department of Health and Human Services’ Office of Inspector General (“OIG”). These require an organization to:

* implement written policies, procedures and standards of conduct;

* designate a Compliance Officer, the Facility Compliance Liaison
and Compliance Committee;

* conduct effective training and education;

* develop effective lines of communication;

* conduct internal monitoring and auditing;

* enforce standards through well-publicized disciplinary guidelines; and

* respond promptly to detected offenses and develop corrective action.

2. We will develop and implement specific standards, educating and training employees with respect to those specific standards, and reviewing and possibly enhancing internal controls and monitoring systems. Implementation will proceed in phases, but management should make steady progress toward the creation and implementation of specific standards and systems relating to all material areas of SIR Management’s consulting operations where there are compliance obligations. The Corporate Compliance Committee through the Compliance Officer shall provide periodic progress reports to SIR Management’s Compliance Officer.

II. ADMINISTRATION AND APPLICATION OF THE CODE OF CONDUCT

SIR Management and its consulting facilities expect each person to abide by the Principles and Standards set forth herein and to conduct the business and affairs of Our Facility in a manner consistent with the general statement of principles set forth herein.

Failure to abide by the Code of Conduct or the guidelines for behavior which the Code of Conduct represents may lead to disciplinary action. For alleged violations of the Code of Conduct, the Administrator (Compliance Liaison) and Compliance Officer will weigh relevant facts and circumstances, including, but not limited to, the extent to which the behavior was contrary to the express language or general intent of the Code of Conduct, the seriousness of the behavior, the employee’s history with the organization and other factors which they deem relevant. Discipline for failure to abide by the Code of Conduct may, in our (Administration’s) discretion, range from oral correction to termination. Prior to administering termination action, we may seek the concurrence of our Counsel. In the event that an employee is covered by the terms of a collective bargaining agreement, discipline shall be in accordance with the provisions of the collective bargaining agreement.

Nothing in this Code of Conduct is intended to nor shall be construed as providing any additional employment or contract rights to employees or other persons.
While SIR Management will generally attempt to communicate changes concurrent with or prior to the implementation of such changes, Our Facility reserves the right to modify, amend or alter the Code of Conduct without notice to any person or employee. After a change in the Code of Conduct is made, all employees will be so notified.

III. DEFICIT REDUCTION ACT

SIR Management (and facilities) are committed to its role in preventing health care fraud and abuse and complying with applicable state and federal law related to health care fraud and abuse. The Deficit Reduction Act of 2005 requires information about both federal False Claims Act and other laws, including state laws, dealing with fraud, waste and whistleblower protections for reporting these issues. To ensure compliance with such laws, SIR Management has policies and procedures in place to detect and prevent fraud, waste, and abuse, and also supports the efforts of federal and state authorities in identifying fraud and abuse.

An individual is not required to report any allegations of False Claims, abuse or fraud violations to SIR Management first. A report may be made directly to the Federal or State Departments of Justice, or the Offices of Inspector General. However, in many instances SIR Management believes that use of its own internal reporting process, and the internal compliance program is a better option because it allows SIR Management to quickly address any potential issues. SIR Management encourages contractors, employees or any other concerned individuals to consider first reporting suspected false claims, abuse or fraud issues to the facility administrator or the corporate compliance officer. SIR Management nor its consulting facilitieswill not retaliate against any individual for informing us or the federal or state government of possible violations.

Concerns of Compliance, False Claims Acts, fraud or abuse can be reported to:

Mark Solomon, Compliance Officer
SIR Management
6840 N. Lincoln
Lincolnwood, IL 60712
Tel: 847-675-7979
Fax: 847-675-0555
email: compliance@nursinghomeshelp.com
Compliance Hotline: 847-679-ABUSE

SIR Management referenced within this document includes
SIR Management and the facilities it consults.

Purpose of the Code of Conduct:

Provides all employees, directors and owners of SIR Management (and consulting facilities) guidance in carrying out their regular daily activities within appropriate ethical and legal standards. This code of conduct applies to our relationships with residents, vendors, consultants and each other.

Introduction:

The Code of Conduct is a critical component of our Corporate Compliance Program.

It contains principles that state the policies of our organization. Further, some principles have standards to give more specifics and to help make our expectations clear.

If you need any assistance in understanding the Code of Conduct, the Compliance Program or need to discuss any concerns please contact:

Mark Solomon, Compliance Officer
SIR Management
6840 N. Lincoln
Lincolnwood, IL 60712
Tel: 847-675-7979
Fax: 847-675-0555
email: compliance@nursinghomeshelp.com
Compliance Hotline: 847-679-ABUSE

Administration and Application of this Code of Conduct

SIR Management and its consulting facilities expect each person to follow the Principles and Standards in this document and to conduct the business and affairs of SIR Management and its consulting facilities in a manner consistent with the general statement of principles set forth.

Failure to follow this Code of Conduct or the guidelines for behavior may lead to disciplinary action. This disciplinary action may range from oral correction to termination depending on the seriousness of the offense, prior actions and other factors that may be deemed relevant. In the event that an employee is covered by the terms of a collective bargaining agreement, discipline will be in accordance with the provisions of the collective bargaining agreement.

Any changes made to this Code of Conduct will be communicated to all employees.

Standard 1.1- Fraud and Abuse
We expect that all employees will follow policies and laws prohibiting fraud and abuse. These laws expressly forbid : (1) payments in cash, gift or otherwise for referrals of Medicare or Medicaid residents directly, indirectly or disguised;
(2) submitting of false, fraudulent or misleading bills to any governmental entity or third party payor. This includes bills for goods and or services not given or performed, bills which state the service differently than the service actually performed or bills which do not otherwise comply with the program or contract requirements.

Standard 1.2 - Discrimination
We believe that the fair and equal treatment of employees, residents and other persons is critical to fulfilling our vision and goals and that we must follow all laws that apply.
It is our policy to recruit, hire, promote and terminate employees based on their own ability, achievement, experience and conduct and to admit residents to our facility without regard to race, color, religion, sex, sexual orientation, ethnic origin, age or disability.
No form of harassment or discrimination of residents or employees will be tolerated on the basis of race, color, religion, sex, sexual orientation, ethnic origin, age, disability or any other classification prohibited by law. Each reported allegation of harassment or discrimination will be promptly investigated by the Corporate Compliance Committee.

Principle 2 - Business Ethics
SIR Management and its consulting facilities commitment to the highest standards of business ethics requires that employees will accurately and honestly represent our facility. This principle requires honesty from individuals in the performance of their responsibilities and in communication with our attorneys, auditors and governmental agencies.

Principle 3 - Confidentiality
SIR Management and its consulting facilities employees should strive to maintain the confidentiality of residents’ records and other business-type confidential information in accordance with all laws.

3.1 - Resident Information and HIPAA
All our employees have a responsibility for protecting the confidentiality of resident information. Employees must not reveal in any form of communication: (verbal, written, fax, electronic); any personal or confidential information such as diagnosis or treatments, etc., unless disclosure is supported by the applicable laws and/or the information is treated as required in the HIPPA regulations. If questions arise regarding confidential information or releasing information, employees should seek guidance from the Administrator.

3.2 - Business Information
Information, ideas and some business information are important aspects to an organization’s success. Information regarding our competitive position or business strategies, payment and reimbursement information and negotiations with employees or third parties should be protected and remain confidential.

3.3 - Personnel Actions / Decisions
Salary, benefit and other personal information relating to employees should be treated as confidential. All employees will use due care to prevent the release or sharing of information beyond those persons who may need such information to fulfill their job function. If questions arise regarding confidential information or releasing information, employees should seek guidance from the Administrator.

Principle 4 - Conflict of Interest
Officers and Covered Persons, which include :Compliance committee members and department heads, owe a special duty of undivided and unqualified loyalty, consistent with state and federal laws, to the organization. Persons holding such positions may not use their position for profit or gain or to assist others in profiting in any way at the expense of the organization.

4.1 - Services for Competitors / Vendors
Officers of our facility should divulge to the Corporate Compliance officer any -potential conflict of interest with regard to any other business entity they may be involved in initially when the Code is implemented, upon starting of new involvement and annually thereafter.

No covered persons should perform work or services for any competitor of ours or for any organization with which we do business with or which seeks to do business with us without written approval of the Corporate Compliance Liaison which will receive approval of the Corporate Compliance Committee.

Nor should any employee allow their name to be used in any fashion that would tend to indicate a business connection with other organizations without the written approval of the Corporate Compliance Liaison which will receive approval of the Corporate Compliance Committee.

4.2 - Participation on Board of Directors / Trustees
Covered persons must obtain approval from the Corporate Compliance Liaison which will receive approval of the Corporate Compliance Committee to serve as a member of the Board of Directors / Trustees of any organization whose interests may potentially or actually conflict with ours. Any questions regarding whether or not Board / Trustee participation might present a conflict of interest should be discussed with the Corporate Compliance Committee.

Once approved the covered person must disclose all Board / Trustee activities in a written Conflict of Interest disclosure statement that should be submitted to the Corporate Compliance Committee before such activity is undertaken, and again annually.

All fees or compensation (other than reimbursement for expenses from Board participation) that are received for Board services provided during normal work time may be required to be paid directly to SIR Management.

SIR Management reserves the right to prohibit membership on any Board of Directors / Trustees where in the judgment of the Compliance Committee such membership might conflict with our best interest.

Principle 5 - Business Relationships
Business transactions with vendors, contractors and other third parties should be transacted in accordance with state and federal laws free from offers or solicitation of gifts, favors or other improper inducements. The following standards below are to guide employees in determining the appropriateness of the listed activities or behaviors within our business, and relationships with vendors, providers, contractors, third party payors and governmental entities. It is our intent that this policy be viewed broadly to avoid conduct with even the appearance of improper activity. Any questions regarding whether or not a relationship might present a violation of this policy should be discussed with the Corporate Compliance Committee.

5.1 - Gifts and Gratuities
It is our desire to, at all times preserve and protect our reputation and to avoid the appearance of impropriety or wrong-doing.

A. Unsolicited gifts of nominal value may be accepted or given from/to existing or potential vendors but must be disclosed to the Corporate Compliance Committee using the form in Appendix l.
An unsolicited gift of nominal value is defined as a gift, cash or cash equivalent of market value of $50.00 or less per source, per occasion, however, the total per source may not exceed $100.00 in a calendar year. This includes:
B. Employees should not accept nor offer gifts, favors, services, entertainment or other things of value to the extent that decision-making or actions affecting SIR Management might be influenced. Similarly, the offer or giving of money, services, gifts or other things of value with expectation of influencing the judgment or decision- making process of any purchaser, supplier, customer, governmental official or any other person is also prohibited.
C. Employees are prohibited from soliciting or accepting tips, gratuities or gifts from residents and or families.

5.2 - Workshops, Seminars and Training Sessions
Attendance at seminars, workshops and training sessions at a vendors’ expense outside of Illinois is permitted only with the written approval from the Corporate Compliance Liaison which will receive approval of the Corporate Compliance Committee.

5.3 - Contracting
All business relations with contractors must be conducted at arm’s length both in fact and in appearance and in compliance with the facility’s policies and procedures. Questions regarding particular relationships, etc. may be referred to the Compliance Committee.

5.4 - Business Inducements
Our employees should not seek to gain any unlawful advantage through the improper use of payments. The offering, giving, soliciting or receiving any form of bribe is prohibited.

From time to time appropriate commissions, rebates, discounts and allowances are customary and acceptable provided they are approved by the Corporate Compliance Officer. Any such payments must be reasonable in value, competitively justified, properly documented and made to the business entity to whom the original agreement or invoice was made or issued. Such payments should not be made to individuals. Any such payments where legally appropriate must be passed on to the appropriate governmental unit.

Principle 6 - Protection of Assets
All employees will strive to preserve and protect our assets by making prudent and effective use of our resources and properly and accurately reporting its financial condition. It is our intent to guide with this principle and the following standards our expectations as they relate to activities and behaviors which may impact our financial health.

6.1 - Financial Reporting
All financial reports, accounting records, expense accounts, time sheets and other documents must accurately, and clearly represent the facts or the true nature of a transaction to the preparers knowledge. Improper or fraudulent accounting, documentation or financial reporting is contrary to the policy of SIR Management and may be in violation of applicable laws and therefore is prohibited.

6.2 - Travel and Entertainment
Travel and entertainment expenses should be consistent with the employee’s job responsibilities and the organization’s needs and resources. Employee are expected to exercise reasonable judgment Employees must also comply with our policies relating to travel and entertainment which require prior approval of the Administrator.

This Code of Conduct is part of the overall Corporate Compliance Program. All employees should be familiar with our Program. The program highlights our intent to ensure that all employees follow all applicable laws and regulations.

Disclosure Information:
All employees are required to report their good faith belief of any violation of the Compliance Program, fraudulent activity, or applicable law. SIR Management and its consulting facilities, at the request of the employee, will provide anonymity to the employee(s) who report violations to the extent possible under the circumstances. SIR Management and its consulting facilities will investigate employee concerns and take necessary corrective action.

There will be no retaliation in the terms and conditions of employment as a result of such reporting.
Employees will report their good faith belief of violations of the compliance program, fraudulent activity, or applicable laws either orally or in writing to their Supervisor, Administrator (Compliance Liaison), Compliance Committee member or Compliance Officer.

Mark Solomon, Compliance Officer
SIR Management
6840 N. Lincoln
Lincolnwood, IL 60712
Tel: 847-675-7979
Fax: 847-675-0555
email: compliance@nursinghomeshelp.com

Compliance Hotline: 847-679- ABUSE

SIR Management referenced within this document includes SIR Management and it's consulting facilities.