Compliance

Compliance

Our Compliance Commitment

VitalConnect is committed to a strong culture of compliance through conducting our business ethically and in accordance with applicable healthcare laws, regulations and statutes. Our Compliance Program, Code of Business Conduct and Ethics, policies and procedures have been developed and implemented to provide guidance to our organization, reflective of our ongoing commitment to these standards.

Contact and Hotline

For questions or concerns related to VitalConnect Compliance, please contact our Office of Compliance and Ethics team using one of the following methods:

Email: compliance@vitalconnect.com
Compliance Officer: Donna Fierraro (dfierraro@vitalconnect.com)
Hotline and Inquiries: (833) 614-6177
Web Intake Site: https://vitalconnect.ethicspoint.com

Code of Conduct

We support a strong culture of compliance, both internally and for all our business interactions, through the provision, education and standards set in our Code of Business Conduct and Ethics.

Our Compliance Framework

  1. Policy and Procedure
    We have implemented policies and procedures to ensure all internal and customer-facing interactions are in accordance with applicable healthcare laws, statutes and regulations.
  2. Program Oversight
    Compliance Officer
    Compliance Committee
    Board of Directors
  3. Employee Training and Education
    Every team member undergoes new hire and annual education in general compliance; Fraud, waste and abuse; The Anti-Kickback Statute; and False Claims Act; and Interactions with Health Care Professionals. In addition, team members are provided the opportunity for focus education, both electronically and in-person, throughout the year.
  4. Reporting and Communication
    Our organization publishes access for all employees to Voice It, our Hotline that enables confidential and anonymous reporting of compliance issues and concerns.
  5. Auditing and Monitoring
    Our annual Audit Plan is developed and conducted based on annual risk assessment, policy changes, and identified compliance challenges throughout the year.
  6. Investigation and Remediation
    Investigations are conducted in a confidential manner to identify root causes, as well as to uncover and correct any areas of compliance risk or vulnerability. Corrective actions are identified and implemented as part of remediation, as dictated by the results of the investigation.
  7. Enforcement and Discipline
    Compliance policies are developed inclusive of clear disciplinary standards for anyone who is involved in misconduct to our Code of Business Conduct and Ethics, or engaged in any unlawful or unethical actions.

California Declaration

VitalConnect, Inc. (the “Company”) has established a Comprehensive Compliance Program (“CCP”) that is compliant with California Health and Safety Code §§ 119400-119402 and aligned with the guidance found in the Compliance Program Guidance for Pharmaceutical Manufacturers” issued by the Office of the Inspector General (“OIG Guidelines”), and the “Code on Interactions with Health Care Professionals” issued by the Pharmaceutical Research and Manufacturers of America.

VitalConnect’s CCP includes policies enforcing compliance with the OIG Guidance and applicable industry code. As a medical device manufacturer, VitalConnect has elected to adopt a comparable industry code – the “Code of Ethics on Interactions with Health Care Professionals” issued by the Advanced Medical Technology Association (“AdvaMed”) – that aligns more closely with medical device industry standards and business practices.

The Company has established an annual dollar limit on gifts, promotional materials, items and activities that the Company may provide to an individual Healthcare Professional (“HCP”). VitalConnect, in all material respects, is in compliance with the California requirements.

If you would like a copy or copies of VitalConnect’s CCP and this declaration, please call this toll-free number: 833-614-6177. Or you can request a copy via email to this address: compliance@vitalconnect.com.