Effective Date: October 2, 2026
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About this Code‍This Code of Conduct and Ethics is a high-level guide.
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‍It describes the values, principles, and expectations that govern how Abby Care operates. It is not a comprehensive policy manual. Abby Care maintains a broader set of policies and procedures that provide more detailed requirements on many of the topics covered here, including the Employee Handbook for U.S.-based employees. Where applicable, the strictest standard of this Code, policy, or law prevails. Team members are responsible for knowing the policies relevant to their roles or services.

‍No document can anticipate every situation.

‍When something does not feel right or the right course of action is not clear, ask questions, seek guidance, and speak up. Resources are listed at the end of this document.

‍Abby Care Compliance Program and the Code

‍This Code does not stand alone. It is part of Abby Care's formal Compliance Program, which provides the training, oversight, and resources that make our standards real. If you have questions about this Code or need guidance on the right course of action, reach out to Compliance. They are here to help.

‍Disclaimer for U.S.-based employees: This Code is not an employment contract and does not change at-will employment. Nothing in this Code is intended or should be construed to interfere with any rights under applicable state or federal law, including the National Labor Relations Act. Nor does this Code restrict or limit employees’ right to disclose facts relating to certain claims for harassment, retaliation, discrimination, other unlawful acts in the workplace, or related to the terms and conditions of their employment. Nothing in this Code restricts or limits employees’ rights to testify truthfully in any public forum, exercise protected rights, or comply with an applicable law or valid order of a court or government agency. Furthermore, nothing in this Code is intended to restrict employees from reporting concerns to, filing a charge or complaint with, making lawful disclosures to, providing documents or other information to, or participating in an investigation or hearing conducted by the National Labor Relations Board, Equal Employment Opportunity Commission, Securities and Exchange Commission or any other federal, state, or local agency. ‍

‍Who this Code applies to‍This Code applies to: All Abby Care employees, officers, directors, and other members of its workforce, including contract workers and consultants.Certain provisions also apply to vendors, business partners, and others who act on Abby Care's behalf.References to "team members" throughout this document are intended to include all members of the Abby Care workforce.

‍Violations 

‍We are accountable for following this Code and the policies that apply to our work.  Violations may result in corrective or disciplinary action, up to and including termination of employment or business relationship.  In some circumstances, Abby Care may also be required to report conduct to a licensing board, government agency, or other appropriate authority.  

‍Waivers

‍Abby Care does not expect that waivers of this Code will be granted. Any exception is a serious matter. Waivers for executive leadership may only be granted by the appropriate governance authority. Waivers for other team members may only be granted by the Chief Compliance Officer. No one may grant themselves a waiver. If you believe your circumstances may warrant an exception, contact Compliance before acting.

‍Acting with Integrity

‍Integrity means doing the right thing even when the answer is not clear, even when no one is watching, and even when it is hard.We expect everyone on our team to: Raise concerns when something feels offSeek guidance when they need itNever compromise the trust our patients and families place in usThis Code is not aspirational. It describes how we actually expect our organization to operate. When conduct falls short of these standards, Abby Care takes it seriously and responds appropriately, up to and including ending the working relationship. In some circumstances, Abby Care may also be required to report conduct to a licensing board, government agency, or other appropriate authority.

‍Asking questions and speaking up

‍Anyone connected to Abby Care, whether as a team member, patient, family member, or partner, should feel comfortable raising a concern when something does not seem right. You do not need to have all the facts or be certain that a rule has been broken.

‍How to raise a concern:Talk to your leader — most concerns can be addressed by an honest conversation with your supervisor or manager.

Contact People, Legal, or Compliance directly — you do not need to go through your leader first.

‍Use the Ethics Hotline — available 24/7, operated independently of Abby Care management, at 888-209-4069 or abbycarecompliance.com. You may report anonymously where permitted by law. Hotline services are available in multiple languages.

‍Report to a government authority — Nothing in this Code prevents you from reporting a concern directly to a federal or state government agency, including the Office of Inspector General (OIG), the Department of Health and Human Services, or the applicable state Medicaid authority. You have the right to do so, and Abby Care will not retaliate against you for it.Abby Care reviews every concern promptly. Information is shared only with those who need it. Everyone is expected to cooperate honestly with any internal review or investigation.

‍No individual will be disciplined, discharged, or otherwise penalized for making a good faith report, even if an investigation concludes that no violation occurred.‍Non-retaliation‍Abby Care strictly prohibits retaliation against anyone who, in good faith, asks a question, reports a concern, or participates in an investigation.

‍This protection extends to team members, patients, families, and anyone else who raises a concern about Abby Care's conduct. A report does not have to turn out to be correct. What matters is that the person honestly believed there was a reason to speak up. Protection applies even when an investigation concludes that no violation occurred.Knowingly filing a false report or using the reporting process to harm someone else is not protected and may result in appropriate action.If you believe you have experienced retaliation for raising a concern, report it immediately through any of the channels listed in the Resources section of this document.Raising a question early can prevent a small issue from becoming a much larger one. Speaking up protects our patients, our teammates, and the trust placed in Abby Care.

‍Leaders are role models

‍Everyone at Abby Care is expected to act with integrity, but leaders carry a special responsibility. How you behave every day sets the standard more powerfully than any policy document.

‍Leaders at every level are expected to:Read and understand this Code and apply it consistentlyModel the conduct it describesEnsure their teams complete required training and understand the standards that apply to their rolesCreate an environment where speaking up is encouraged and protectedActively monitor their teams for signs of Fraud, Waste and Abuse, and escalate concerns to Compliance promptlyNever ask, pressure, or allow team members to compromise their integrity to meet a business goalIf someone on your team comes to you with a question or concern, take it seriously, respond appropriately, and escalate when needed. Failing to act on a concern that was brought to you is itself a violation of this Code.

‍Equal Opportunity

‍Abby Care makes employment decisions based on qualifications, experience, performance, and legitimate business needs, not on personal characteristics.Protected characteristics include race, color, religion, national origin, ancestry, sex, pregnancy, sexual orientation, gender identity or expression, age, disability, genetic information, military or veteran status, marital status, and all other categories protected by applicable law.Where state law provides broader protections than federal law, we apply the more protective standard.For disability or religious accommodation requests and questions, please consult with the People team.

‍Diversity and Inclusion

‍Different experiences, backgrounds, and perspectives make us stronger and better able to serve the diverse families who depend on us.

‍Inclusion is a shared responsibility. 

‍We expect everyone to treat others with respect and help create a workplace where people feel welcome and supported.This means showing up for your colleagues the same way you show up for patients. It means speaking up when you see someone being treated unfairly. And it means recognizing that a truly inclusive workplace is built through daily choices, not policies.

‍Anti-discrimination and anti-harassment

‍Abby Care does not tolerate discrimination, harassment, or inappropriate conduct based on any characteristic protected by applicable law. Harassment is any unwelcome conduct that creates an intimidating, hostile, or offensive work environment. It can be verbal, physical, visual, or sexual, whether in person or through electronic communication. Our expectations apply everywhere our work takes place, including patients' homes, company vehicles, and company-sponsored events.

‍Examples of harassment include: Unwanted comments about appearance, identity, or personal characteristicsJokes or remarks targeting a protected characteristicUnwelcome physical contact or gesturesThreatening, intimidating, or demeaning behaviorPersistent unwanted communication, in person or electronic

‍Our shared responsibility

‍Creating a respectful workplace is everyone's job. Every team member is expected to speak up when they witness or become aware of harassment or discrimination, not only when they experience it personally. Supervisors and managers have an additional legal obligation to report harassment they observe or are informed about. This is not discretionary.If you experience or witness discrimination or harassment, report it to your leader, People, Legal, Compliance, or the Ethics Hotline. Abby Care investigates all reports promptly and keeps reporters informed of outcomes to the extent permitted. Retaliation against anyone who raises a concern in good faith is prohibited.

‍Harassment by patients or family members

‍Because some of our team members work in patients' homes, they may encounter harassing, threatening, or inappropriate conduct from patients, family members, or other household members. This conduct is not acceptable, and Abby Care does not expect team members to tolerate it as a condition of the job. If you experience harassment or threatening behavior in a patient's home, you may remove yourself from the situation and must report it to your leader promptly. Abby Care will work with you to address the situation, which may include modifying the care assignment.

‍A safe and healthy environment

‍Everyone has a role in keeping our workplace safe. Because much of our work takes place in patients' homes, your environment changes from assignment to assignment. You should never feel expected to work in conditions you reasonably believe are unsafe.

‍Home environment hazards

‍Before beginning care, assess the home environment for conditions that could pose a risk, including unsafe structures, animals, evidence of drug activity, or other hazards. If conditions are unsafe, leave if necessary and report to your leader promptly. Do not place yourself in danger to deliver a visit.

‍Infection control

‍Follow all applicable infection control protocols, including hand hygiene, use of personal protective equipment, and proper handling and disposal of clinical supplies. Report any exposure incident immediately.

‍Substance-free workplace

‍Team members must not be under the influence of alcohol, illegal drugs, or any substance that impairs judgment or performance while on duty or in a patient's home. This applies to prescription medications that affect your ability to work safely.

‍Violence and personal safety

‍Violence, threats, and intimidation are not tolerated. If there is an immediate threat, leave and contact emergency services, then notify your leader. Report all incidents, near-misses, and injuries to your leader promptly, even if no harm occurred.

‍Integrity in patient care

‍We provide care based on each patient's needs and the appropriate standard of care. Clinical decisions must never be driven by financial considerations, business pressures, or personal interests. Every patient has the right to be treated with dignity, to be informed about their care, and to have their preferences respected. Work within the scope of your role and seek guidance when a patient's situation goes beyond your training or authority.

‍Patient rights

‍Patients we serve have rights established by law and by Abby Care's own standards, including the right to be informed about their care and treatment options, the right to participate in care planning, the right to refuse care, the right to file a complaint or grievance without fear of retaliation, and the right to have their privacy respected. These rights apply regardless of payer, program, or state. Familiarize yourself with the patient rights applicable to your program and role. 

‍Professional boundaries

‍We are guests in a patient's home to provide care. Do not accept gifts, tips, or other items of personal value from patients or their families. Do not enter into personal financial relationships with patients, including loans, purchases, or arrangements that benefit you personally. Do not allow personal or social relationships to develop out of the care relationship in a way that compromises your professional judgment. These boundaries protect patients and protect you.

‍Mandatory reporting

‍Concerns about a patient's safety, living conditions, or possible abuse, neglect, or exploitation must be reported promptly. Internal reporting alone is not sufficient when external reporting is required by law. Certain team members are mandated reporters under state law and are required to report suspected abuse directly to Adult Protective Services, Child Protective Services, or the appropriate authority, depending on the patient population or applicable state law. Know whether you are a mandated reporter and act accordingly. The duty to report applies even when the suspected abuser is an Abby Care employee, family member, caregiver, or other person close to the patient. Do not allow a personal relationship or concern about disrupting the care relationship to delay a required report.

‍Documentation matters

‍Patient records must truthfully reflect the care provided. Documentation must be completed at the time of service or as close to it as possible. Late or amended entries must be clearly identified as such. Records must never be falsified, altered, or created for services not rendered.

‍Questions and concerns

‍Questions about patient care standards, professional boundaries, or mandatory reporting obligations should go to Legal, Compliance, or People. Do not wait until a situation escalates. Reach out early.

‍Protecting patient privacy

‍Protecting patient information is not just a legal requirement, it is a core part of the trust that makes our work possible. Every team member, regardless of role, has an obligation to handle patient information with care.

‍What is PHI?

‍Protected Health Information (PHI) is any information that could identify a patient and relates to their health condition, care, or payment for care. In home health, PHI is everywhere. It includes:Names, addresses, phone numbers, and dates of birthDiagnoses, medications, treatment plans, and clinical notesPhotos or videos taken in a patient's homeScheduling information that connects a patient to a serviceAnything you hear, see, or learn in the course of providing care

‍Your obligations

‍Only access, use, or share patient information (i.e., PHI) when your job requires it — whether you are providing care or supporting it through scheduling, intake, eligibility, billing, quality, or technical work — and only the minimum amount you need for the task in front of you. Do not look up patients you are not assigned to, even out of curiosity. Do not share logins or leave devices unlocked. Never use personal apps, personal email, or unapproved tools to document, store, or transmit clinical information. Caregivers who access approved clinical systems on a personal device must do so only through Abby Care-approved applications and may not use personal apps, personal email, or other unapproved channels for clinical documentation or communication.  HIPAA's minimum necessary standard requires you to limit access to only what you need to perform your specific role, and for the specific task or function you are performing at the time. Access that may be appropriate for one job function is not automatically appropriate for another, even within the same role.

‍In a patient's home

‍Be mindful of conversations that could be overheard by family members, visitors, or others in the home. Position screens so they cannot be seen by unauthorized individuals. Do not take photos inside a patient's home without explicit authorization. Do not discuss one patient's information with another patient's household. Keep paper documents containing PHI secured and dispose of them properly.For detailed requirements, refer to: Abby Care Privacy Policy
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‍Protecting privacy: Reporting and getting help ‍Reporting a privacy or security incident

‍If you become aware of a possible privacy or security incident, report it immediately to the Privacy Officer or Compliance. Do not try to decide on your own whether it rises to the level of a breach. Examples of incidents that must be reported include:A device containing PHI is lost or stolenPHI is sent to the wrong person by email, text, or faxUnauthorized access to a patient's record is discoveredClinical information is shared with someone who should not have received itA personal device used for work is compromisedBreaches must be reported within the timeframe required by applicable law. Federal law sets a maximum of 60 days from discovery, but state law or program requirements may impose a shorter deadline. Always comply with the stricter of the applicable federal and state requirements. Depending on the nature and scope of the breach, we may be required to notify affected patients, the Department of Health and Human Services, relevant state agencies and, in some cases, the media. Prompt internal reporting is what allows us to meet those obligations and limit harm.

‍Questions and concerns

‍Privacy questions go to the Privacy Officer or Compliance. If you are unsure whether something is permissible, stop and ask before acting. For detailed requirements, refer to: Abby Care Privacy Policy‍

‍Fair and honest business practices

‍Abby Care competes and builds relationships based on the quality of our services and the trust we earn. We deal honestly and fairly with patients, families, payors, healthcare providers, vendors, business partners, and competitors. We do not misrepresent facts, conceal important information, or take unfair advantage of others.

‍Representing our services accurately

‍What we tell patients, families, and referral sources about our services, coverage, and expected outcomes must be truthful and supportable. Do not overstate what Abby Care can do, what a patient's insurance will cover, or what results a patient should expect. Overpromising to secure or retain patients is not acceptable and can expose Abby Care and you to serious liability.

‍Working with payers and MCOs

‍When interacting with Medicaid, Managed Care Organizations, or other payers, all representations about patient eligibility, services provided, clinical necessity, and authorization must be accurate and complete. Submitting inaccurate information to a payer, even unintentionally, can constitute a false claim. If you are unsure whether information you are providing to a payer is accurate, stop and verify before submitting.

‍Vendor and partner selection

‍We select vendors and business partners based on legitimate business considerations including quality, cost, reliability, and fit. Team members with purchasing authority must be able to document the basis for their decisions and must avoid situations where a personal relationship with a vendor could appear to have influenced the outcome. Personal relationships, gifts, or other interests must never drive a business decision.

‍Contract execution authority

‍Only authorized individuals may sign contracts on behalf of Abby Care. No team member may bind Abby Care to a legal commitment — including vendor agreements, service contracts, or amendments — without proper delegated authority. All contracts must be routed through Legal prior to execution. If you receive or are asked to sign an agreement, contact Legal before proceeding.

‍Conflicts of interest

‍Every decision we make on behalf of Abby Care should be based on what is best for our patients and our business, not on personal interests or relationships. A conflict of interest arises when personal, financial, or outside interests interfere with your ability to make objective decisions, or appear to do so. A conflict does not require wrongdoing. What matters is that it is recognized and disclosed.

‍Examples of conflicts

‍Evaluating or selecting a vendor where a family member is employedSupervising, hiring, or reviewing the performance of a family member or close personal relationshipAccepting or giving gifts, meals, tickets, or other items of value to or from a referral source or vendorHolding a financial interest in a competitor, vendor, or referral sourceOutside employment or board service that competes with or draws on Abby Care's resources or relationships.

‍Family member conflicts

‍The outside activities of family members can create conflicts just as your own can. If a family member has a relationship with a vendor, referral source, competitor, or Abby Care business partner that could affect your objectivity, that is a conflict you need to disclose. For the purposes of this Code, family members include your spouse or domestic partner, parents, siblings, children, in-laws, and any other person whose financial interests are closely connected to yours.

‍Gifts and entertainment

‍Giving or receiving gifts, meals, entertainment, or other items of value to or from vendors, referral sources, or business partners can create or appear to create a conflict. Specific thresholds and requirements are set out in Abby Care's policies regarding gifts and gratuities.

‍Corporate opportunity

‍If you discover a business opportunity through your role at Abby Care, you may not pursue it for personal benefit without first bringing it to Abby Care. This applies to opportunities discovered through company information, company relationships, or your position.

‍Disclosing a conflict

‍Disclosure is required before acting, not after. Contact your manager and Compliance before you engage in any outside activity or arrangement that could create a conflict.

‍What happens after you disclose

‍Compliance will review the situation and either clear it, approve it with conditions, or ask you to recuse yourself. Disclosure is not an admission of wrongdoing. It is the right thing to do and it protects you.

‍What happens if you don't

‍Undisclosed conflicts that are discovered later are treated more seriously than conflicts that were disclosed promptly. When in doubt, disclose

.Communications, social media, and marketing

‍How we communicate is part of how we represent Abby Care. Every message, post, and public statement either builds or erodes the trust that makes our work possible. Protecting that reputation is a shared responsibility.

‍Responsible communications

‍Be thoughtful, professional, and protective of confidential information in all communications, including text messages and personal devices used for work. Company systems are company resources and team members should have no expectation of privacy when using them. Electronic communications can become permanent records in litigation or government investigations. Write and send accordingly.

‍Social media

‍Never post patient information, photos, or anything that could identify a patient. This applies even when the intent is positive. A photo of a patient's home, a reference to a patient's condition, or a comment about a visit can all be HIPAA violations. If you see a colleague posting content that appears to involve patient information, report it to Compliance. Make clear that your personal views are your own and not Abby Care's. 

‍Note: Abby Care's marketing team does occasionally share authorized stories or videos featuring families, with their explicit written consent and in compliance with all applicable regulations. These are handled exclusively through the Marketing or Government Affairs teams.  Team members should never independently post such content.

‍Media requests

‍Only authorized team members may speak to the media on Abby Care's behalf. If you are not authorized to speak on behalf of Abby Care and the media contacts you, whether at the office, at a patient's home, or through personal channels, do not comment. You are not authorized to speak on Abby Care’s behalf.  Be polite and say: "All media inquiries should be directed to our communications team." Then notify your leader promptly.

‍Advertising and marketing

‍All materials must be truthful, not misleading, and compliant with applicable laws. The Beneficiary Inducement Statute prohibits offering anything of value to Medicare or Medicaid beneficiaries to influence their choice of provider. OIG guidance provides safe-harbor thresholds for certain nominal gifts (currently $10 per item and no more than $75 in aggregate per patient per year); any gifts to patients must stay within these limits and be approved in advance. Claims about our services must be substantiated. Contact Legal or Compliance before any marketing activity directed at program beneficiaries.Team members may not create, modify, or distribute marketing or promotional materials independently. All patient-facing and referral-facing materials must be reviewed and approved through a centralized process before use. Contact Marketing or Compliance for guidance.

‍Political activity

‍Abby Care respects your right to participate in the political process as a private citizen. 

‍You may:Make personal political contributionsVolunteer for campaigns on your own timeAdvocate for causes you believe in as a private individual

‍Avoid:Using Abby Care systems, email, or work time for personal political activityImplying Abby Care endorses any candidate, party, or political positionPressuring colleagues to support your political views or activitiesAny lobbying or political contributions made on behalf of Abby Care must go through appropriate channels and receive prior authorization.

‍Antitrust and fair competition

‍Abby Care competes on the quality and value of our services. We do not coordinate with competitors on business terms, and we do not engage in conduct that distorts fair competition.Antitrust violations carry serious consequences, including criminal prosecution and personal liability for the individuals involved. This is not a regulatory technicality. A team member who participates in price-fixing or market allocation with a competitor can face personal criminal exposure regardless of their seniority or intent.Never agree or discuss with a competitor:Rates, pricing, or reimbursement termsWages, compensation, or staffingPatients, territories, or service areasReferral arrangements or bid strategiesIn home health, these conversations can arise informally at industry events, in shared clinical settings, or through referral networks. The setting does not change the risk. If a conversation starts moving in this direction, stop participating, make your exit clear, and report it to Legal or Compliance.

‍Preventing Fraud, Waste, and Abuse: Your obligations

‍Every team member has a role in preventing, detecting, and reporting Fraud, Waste, and Abuse (FWA). These are not just compliance concerns. They are conditions of our participation in Medicaid and other government programs.

‍Billing standards

‍We bill only for services that are:Medically necessary and ordered by an authorized providerActually provided and accurately documented before billingAccurately recorded in the Electronic Visit Verification (EVV) system, where required. EVV records must reflect actual visit times and activities and must not be altered or fabricated.Within the authorized scope of the patient's plan of careCoded and billed in accordance with applicable payer requirementsProvided by personnel who are appropriately licensed and credentialed

‍Coordination of benefits

‍Medicaid is the payor of last resort. Before billing Medicaid, applicable third-party coverage — including Medicare, private insurance, and other available payers — must be identified and billed first. Billing Medicaid without exhausting other available coverage, or failing to identify third-party coverage, can constitute a false claim. Team members with intake, authorization, or billing responsibilities must be familiar with Abby Care's coordination of benefits requirements. Contact Compliance with questions.

‍Documentation

‍Documentation must accurately reflect what was done, by whom, when, and for how long. Records must be completed contemporaneously. Never alter, backdate, or create documentation for services that were not provided.

‍Overpayments

‍If Abby Care identifies an overpayment from a government program, it must be reported and returned within 60 days. Retaining a known overpayment is a violation of the False Claims Act. Report any suspected overpayment to Compliance immediately.

‍Preventing Fraud, Waste, and Abuse: Definitions
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‍‍Fraud

‍“Fraud” is knowingly providing false or misleading information to obtain a benefit or payment. Under the False Claims Act, "knowingly" includes actual knowledge, deliberate ignorance, and reckless disregard for the truth — proof of a specific intent to defraud is not required.

‍Examples in home health:Billing for visits not madeBilling for services without verifying that authorization and documentation existFalsifying visit notes or time recordsUpcoding: billing for a higher level of service than providedDuplicate billing for the same serviceBilling for services without verifying that authorization and documentation existMisrepresenting a patient's diagnosis to justify services

‍Waste

‍“Waste” is the unnecessary or inefficient use of healthcare resources. No intent to deceive is required.

‍Examples in home health:Scheduling visits that are not clinically necessaryProviding services beyond what the plan of care authorizesOrdering unnecessary supplies or equipmentFailing to discharge a patient when care goals have been metExcessive visit durations not supported by clinical need

‍Abuse

‍“Abuse” occurs when practices inconsistent with accepted business, medical, or fiscal standards result in unnecessary costs or improper payment. Intent is not required.

‍Examples in home health:Billing practices that do not follow applicable guidelinesRoutinely waiving co-pays or cost-sharing without a documented basisCharging for services at a level not supported by documentationPatterns of billing that deviate significantly from peers without clinical justification

‍Preventing Fraud, Waste, and Abuse: Detection and reporting‍If you observe or suspect fraud, waste, or abuse, you are required to report it.

‍You do not need to be certain. You do not need to investigate. Report what you observed to your leader, Compliance, or the Ethics Hotline. Failure to report known or suspected FWA is itself a violation of this Code and may violate applicable law.Abby Care prohibits retaliation against anyone who reports a concern in good faith.

‍Consequences of FWA

‍Civil monetary penalties and exclusion from Medicare and MedicaidCriminal prosecution and imprisonmentRepayment of amounts improperly received, plus treble damages under the False Claims ActDisciplinary action up to and including termination of employment or business relationshipLoss of professional licensureAbby Care conducts regular auditing and monitoring of billing, documentation, and clinical records as part of its Compliance Program. Team members are expected to cooperate fully with these activities.

‍Key healthcare compliance laws‍

‍Why this matters to you

‍Abby Care serves patients through Medicaid and other government programs. That means the work you do every day, including documenting care, scheduling visits, and accepting referrals, is subject to federal healthcare laws with serious personal consequences for violations. The three laws below are the ones most relevant to your work at Abby Care.

‍False Claims Act

‍The federal False Claims Act (FCA) prohibits knowingly making a false claim for payment against the government. Violations can result in civil penalties of up to three times the amount of the false claim, plus additional fines per claim. The FCA includes a qui tam provision that allows team members to file suit on behalf of the government and receive a portion of any recovery, meaning team members who are aware of FWA have a legal pathway and a financial incentive to report it externally. Many states have their own false claims laws that may be stricter.

‍Anti-Kickback Laws

‍The federal anti-kickback statute (AKS) prohibits offering, paying, soliciting, or receiving anything of value to induce or reward referrals of items or services covered by federal healthcare programs. Many states have their own anti-kickback laws that may apply to Medicaid, commercial insurance, or both, and may impose stricter standards than federal law. Where Abby Care operates in those states, the stricter standard applies. Penalties include up to $100,000 per violation and up to 10 years imprisonment. Contact Compliance before any arrangement that could be perceived as providing value in exchange for referrals. Separately, offering anything of value to government officials, including state Medicaid agency staff or other regulators, to influence a decision or obtain a favorable outcome is prohibited under federal and state anti-bribery laws. When in doubt about any interaction with a government official, contact Legal or Compliance first.

‍Stark Law

‍Prohibits physician self-referrals to entities with which the physician or an immediate family member has a financial relationship. Unlike the AKS, the Stark Law is a strict liability statute, meaning no intent to violate the law is required. 

‍Beneficiary Inducement Statute

‍Prohibits offering anything of value to a Medicare or Medicaid beneficiary that is likely to influence the beneficiary's choice of provider, supplier, or item or service covered by a federal healthcare program. Unlike the AKS, this law focuses on inducements directed at patients themselves — not referral sources. Violations carry civil monetary penalties of up to $10,000 per item or service, plus exclusion from federal healthcare programs. In home health, common risk areas include offering free transportation, waiving co-pays or cost-sharing without a documented basis, and providing gifts beyond nominal value. The OIG recognizes a safe harbor for genuinely nominal gifts (currently $10 per item, no more than $75 in aggregate per patient per year). Any gift or benefit provided to a patient or their family must stay within these limits and be approved in advance. Contact Compliance before offering anything of value to a patient or their household.

‍Exclusion and Debarment

‍Federal law prohibits healthcare programs from paying for items or services provided by, ordered by, or under the medical direction of individuals or entities that have been excluded from participation in Medicare, Medicaid, or other federal healthcare programs. Exclusion can result from criminal convictions, license revocations, and certain other adverse actions. Abby Care screens team members and vendors against the OIG List of Excluded Individuals and Entities, the General Services Administration's debarment list, and applicable state Medicaid exclusions lists at hiring/engagement and on an ongoing basis.Team members have an independent obligation to disclose to Compliance immediately if they are excluded, debarred, or become aware that they are under investigation for conduct that could result in exclusion. Providing services while excluded, even if the employer is unaware, exposes both the individual and Abby Care to civil monetary penalties, repayment obligations, and potential False Claims Act liability. If you are uncertain whether a prior matter could affect your eligibility, contact Compliance before it becomes a problem.

‍Accurate records and government inquiries

‍‍Accurate records

‍Financial transactions must be recorded accurately, completely, and in accordance with our policies and applicable laws. We do not create false or misleading entries, conceal transactions, mischaracterize expenses, or maintain undisclosed funds. Never alter or conceal information to make a financial result appear different from what actually occurred.In practice, accurate recordkeeping means:Recording expenses to the correct cost center and periodNever splitting transactions to avoid approval thresholdsEnsuring documentation reflects what actually happened, not what should have happenedInaccurate financial records in a healthcare business are not just an accounting problem. They can constitute a false claim, trigger exclusion from government programs, and form the basis of criminal charges.

‍Record retention

‍Records must be retained for the period required by our record retention policy. For Medicare and Medicaid records, this is generally a minimum of 10 years. Record retention applies to clinical records, billing records, personnel records, contracts, compliance records, and incident reports. Records subject to a government inquiry, investigation, or litigation hold must not be destroyed until the matter is formally concluded. If you receive a litigation hold notice, comply with it immediately and contact Legal with any questions about what it covers.

‍Government inquiries and investigations

‍Government surveyors, auditors, or investigators may contact you at a clinical site, a patient's home, or through personal channels. If this happens, be polite, do not answer substantive questions about Abby Care's business, and do not provide any records or information. Call Legal or Compliance immediately. Abby Care will cooperate with government inquiries and will seek to support team members who are contacted in connection with their work for Abby Care, consistent with its legal obligations and subject to applicable conflict-of-interest considerations.. Never conceal, alter, or destroy information related to any audit, investigation, or government request.

‍Company assets, funds, and intellectual property

‍Every team member is a steward of Abby Care's resources. That includes the systems we use, the funds we spend, the information we hold, and the ideas we develop. Treating those resources carelessly, or using them for purposes other than Abby Care's business, puts the organization and the people we serve at risk. In a business built on trust, how we handle our own house matters as much as how we handle our patients'.

‍Email and communications tools

‍Communicate thoughtfully and in accordance with our policies. Electronic communications can be easily shared, forwarded, or preserved, and can become permanent records in litigation or government investigations. Company systems are company resources. Team members should have no expectation of privacy when using them.

‍Personal devices
‍Never use personal devices or applications to access, document, or transmit patient information or other confidential Abby Care data. In home health, this is where HIPAA breaches most commonly occur. Clinical documentation must only be completed through Abby Care-approved systems. Personal device use for clinical work creates data security risk that Abby Care cannot manage or remediate once it occurs. Managing company fundsAll purchases and expenses must have a legitimate business purpose and provide reasonable value. Submit expenses accurately and on time, with required documentation. Never approve your own expenses. Purchasing decisions must be objective and in Abby Care's best interests, never influenced by personal relationships, gifts, or conflicts of interest. Misuse of company funds, including expense fraud, is grounds for immediate termination and may result in criminal referral.Intellectual propertyAbby Care's ideas, technology, processes, data, and original work are core to our competitive position. Protect them by limiting access to those with a legitimate need and never sharing them outside the company without authorization. When team members leave Abby Care, their obligation to protect confidential and proprietary information does not leave with them. Taking Abby Care's intellectual property upon departure, including client lists, care protocols, or proprietary systems, is a serious legal matter. Company confidential information, including financial results, strategic plans, M&A activity, and business terms with payers and vendors, must be treated with the same care. Do not share it internally except on a need-to-know basis, and never externally without authorization from Legal.Securities law and inside informationAbby Care may have outside investors, convertible notes, or equity compensation arrangements that give certain people access to sensitive financial information. Whether or not Abby Care’s securities are publicly traded, we are committed to handling that information responsibly and in accordance with the law.Material non-public information (MNPI)Material non-public information (MNPI) is any information about a company that has not been made available to the public and that a reasonable investor would consider important in deciding whether to buy, sell, or hold that company’s securities. Examples include unannounced financial results, a pending acquisition or merger, a significant contract win or loss, a leadership change, or a material regulatory development. If you have access to MNPI about Abby Care or any other company through your work here, you may not trade in that company’s securities, or tip others to do so, while the information remains non-public.Insider tradingInsider trading, buying or selling securities based on MNPI, or sharing MNPI so that someone else can trade is a serious federal crime. It carries civil penalties, disgorgement of profits, and criminal sentences of up to 20 years. These rules apply to Abby Care’s own securities and to the securities of any other company whose MNPI you may come across in your work, such as a potential acquisition target or a publicly traded partner or payer.What this means in practiceIf you receive or become aware of information that you believe may be MNPI, do not trade, do not share it with anyone who does not need it for a legitimate business purpose, and contact Legal before taking any action. When in doubt, assume the information is MNPI and ask first.Responsible use of artificial intelligence (AI)AI has potential to improve how we work and how we serve patients. We embrace innovation thoughtfully, with appropriate safeguards and human oversight. Using AI does not change our responsibility to protect our patients, exercise sound judgment, and comply with all applicable laws and standards.Rules for AI use:Only Abby Care-approved AI tools may be used for company businessPHI and confidential information must never be entered into an AI tool unless the tool and the specific use have been approvedEven when a tool is approved, use only the minimum information necessaryAI-generated content should be treated as a starting point, not an unquestioned source of truthAI must not be used to make or automate clinical decisions without appropriate human oversight and clinical authorizationYou remain responsible for reviewing your work for accuracy and appropriatenessAI tools can produce biased, inaccurate, or misleading results, and can raise privacy and intellectual property concerns. Responsibility for your work stays with you, even when AI helps you do it.Where to get helpAbby Care's resources are available to team members, patients, families, and partners who may have questions or concerns:People/HREmployment matters, employee accommodations, workplace conduct, discrimination, or harassment.Contact: people@abbycare.org ‍LegalContracts, litigation, subpoenas, government inquiries, or other issues requiring legal guidance.Contact: legal@abbycare.org ‍ComplianceThis Code, healthcare compliance, fraud, waste and abuse, conflicts of interest, billing, documentation, or other ethical concerns.Contact: compliance@abbycare.org‍PrivacyPatient privacy, HIPAA, appropriate use of PHI, or to report a suspected privacy incident. Report promptly, even when you are not certain a breach occurred.Contact: privacy@abbycare.org‍Abby Care Ethics HotlineAvailable 24/7/365 to team members, patients, families, and partners. Reports may be made anonymously where permitted by law. Abby Care strictly prohibits retaliation against anyone who raises a concern in good faith.Phone: 888-209-4069 Web: abbycarecompliance.com