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.
The Elements of our Compliance Program
Numotion strives for the highest standards of corporate conduct and is committed to establishing and maintaining an effective and comprehensive corporate compliance program. As part of this effort, we have adopted a compliance program that includes elements discussed in 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. Numotion’s Compliance Program addresses each of the following elements of an effective compliance program:
- 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 Executive Compliance Committee that is responsible for overseeing the effective operation of the compliance program. Additionally, the Board of Directors is responsible for ultimate oversight of the compliance program and the performance of the Chief Compliance Officer.
- Standards, Policies, and Procedures – The development and distribution of written standards, policies and procedures that promote Numotion’s commitment to compliance by guiding Personnel regarding encouraged and acceptable behaviors and practices.
- Training and Education – The development and implementation of regular, effective training and education programs for all Personnel.
- 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. Numotion is committed to ensuring staff do not experience any form of retaliation because of their concern reporting and/or participating in any review, audit or investigation.
- 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.
- Ineligible Persons Screening – The use of routine screenings and disclosure requirements for prospective and current Personnel to avoid employing or contracting with Ineligible Persons.
- 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.
In accordance with California law (California Health and Safety Code section 119402), Numotion has established an annual spending limit for certain promotional activities directed toward healthcare professionals who prescribe or may influence prescribing in California. At the present time, our annual, per-prescriber spending limit is $500. Examples of items that fall within this spending limit are occasional modest meals in connection with informational presentations and educational items. This annual spending limit does not apply to payments to healthcare professionals for bona fide consulting or other services or other payment excepted from the requirements of California Health and Safety Code section 119402. It is Numotion’s policy to not provide any item of value to any healthcare professional with the intent of influencing that healthcare professional’s prescribing habits.
A written copy of this Declaration may be obtained by emailing
compliance@numotion.com or by calling
1-800-500-9150.
Date: April 26, 2023