Introduction

 
Numotion is the leading provider of Complex Rehab Technology (CRT) in the United States, helping thousands of people with individually configured, medically necessary mobility products and services. It is a privilege to serve our customers and their families and we are committed to serving our customers ethically and in compliance with all applicable laws and regulations.  As part of that commitment, Numotion has established and maintains an effective compliance program designed to comply with applicable federal and state laws and industry standards.  Our Compliance Program takes many of its cues from the Compliance Program Guidance from the Department of Health and Human Services Office of Inspector General and other industry guidance. 

Purpose of the Compliance Program

 
Our Compliance Program's purpose is to help Numotion comply with the laws, regulations and company directives and guidance that apply to our products and services; to train our employees on these matters; and to prevent, detect and correct instances of non-compliance. Numotion expects directors, officers, employees and agents to comply with all applicable Numotion directives and guidance, as well as all applicable laws and regulations. If Numotion becomes aware of suspected non-compliance, we will investigate the matter. In the event of noncompliance, where appropriate, we will take disciplinary action, up to and including termination of employment, and we will implement measures to prevent future non-compliance.

The Elements of our Compliance Program


Numotion’s Compliance Program is modeled after the United States Sentencing Guidelines and guidance from the Office of Inspector General, the United States Department of Justice, and various other healthcare industry guidance. An effective compliance program has seven elements that, when implemented, enhance an organization’s ability to prevent, detect, and respond to conduct that does not conform to laws, regulations and policies applicable to the organization.  Numotion’s Compliance Program addresses each of the seven elements of an effective compliance program:
 
  1. Standards, Policies, and Procedures – The development and distribution of written standards, policies and procedures that promote Numotion’s commitment to compliance by guiding Numotion personnel regarding encouraged and acceptable behaviors and practices.
 
  1. Compliance Leadership and Management – The creation and development of a leadership structure that promotes a culture of compliance within Numotion, including the designation of a Chief Compliance Officer who actively manages the Compliance Program, and an active Compliance Committee of the Board of Directors that is responsible for overseeing the effective operation of the Compliance Program. 
 
  1. Training and Education – The development and implementation of regular, effective training and education programs for all Numotion personnel. 
 
  1. Effective Lines of Communication – A commitment to communicating expectations and developments to personnel and fostering a culture of compliance and transparency, including through the provision of multiple avenues for personnel to anonymously or confidentially report compliance-related concerns or seek guidance on compliance issues, the adoption of procedures to protect from retaliation personnel who raise concerns in good faith, and the adoption of procedures to adequately follow up on personnel’s questions and reports.
 
  1. Monitoring, Auditing and Internal Reporting – The use of audits and other risk evaluation techniques to monitor compliance, identify problem areas and assist in the reduction of identified problem areas; implementation of a system for tracking issues, including those raised by personnel via compliance issues reporting channels and identified through periodic self-reviews in a variety of areas; and regularly reviewing the results of monitoring, auditing and internal reporting activity with leadership to help the organization improve.
 
  1. Responsive Corrective Action and Prevention – The prompt and effective response to identified concerns through a consistent and effective investigative approach.
 
  1. Corrective Actions and Enforcement of Standards – The development and implementation of measures to correct identified issues, and the creation of a uniform system of expectations for compliance violations, including the consistent and unbiased enforcement of those standards at all levels of Numotion.
 

California Compliance Declaration

 
Numotion has developed a comprehensive compliance program that is designed to comply with applicable federal and state laws and industry standards relating to the marketing and promotion of its products and services.  To Numotion’s knowledge as of the date of this declaration, Numotion is in material compliance with its Compliance Program, as described here, and with California Health and Safety Code sections 119400-119402.  While Numotion’s Compliance Program cannot completely eliminate the possibility that an individual will engage in improper conduct, our program is reasonably designed to prevent and detect violations of applicable laws, rules, and regulations, as well as our own internal policies and procedures.
 
A written copy of this Declaration, or of the description of Numotion’s Compliance Program, may be obtained by emailing or by calling 1-800-500-9150.
 
Date: August 1, 2018