MEDBILL RESOURCES CORPORATION’S
POLICY STATEMENT ON COMPLIANCE

We are committed to conducting our business practices with integrity, honesty, and compassion, and in compliance with the laws and regulations that govern our operations.  In order to achieve this commitment, we have periodically adopted policies and procedures that are intended to guide our actions and protect against unlawful activity.  Our Code of Conduct has been specifically designed to provide the necessary guidance that will allow each of us to perform our jobs with the highest level of integrity, and thereby avoid even the appearance of unlawful behavior.

However, we must all make personal commitments to adhere to these guiding principles and to comply with our policies, procedures and regulatory requirements.  If you have questions or concerns about what is appropriate conduct, or if you become aware of any situation that may jeopardize the ethical integrity of our organization, I must ask that you please refer to the Code of Conduct, or promptly contact your supervisor, another member of management, or our Compliance Officer, Eileen Dudgeon, at medbill@medbillcorp.com.  To the extent possible, all communication to the Compliance Officer will be treated confidentially.

MedBill Resources Corporation depends on all of us to carry out its values and achieve its mission of responding to the healthcare needs of our communities.  We must all commit ourselves to conducting business ethically and in accordance with applicable laws, rules and regulations.

CORPORATE COMPLIANCE

MedBill Resources Corporation implemented its corporate compliance program early in 2002, in anticipation that the government’s mounting focus on compliance would reach the medical transportation industry, and, more specifically, third party billing agencies.  As a forerunner in the implementation of a compliance program, MedBill has committed to:

• Appointing a compliance officer and forming a compliance committee to oversee corporate compliance activities;

• Performing background investigations for prospective employees, subcontractors, clients, and vendors consistent with The Office of Inspector General’s List of Excluded Individuals/Entities and the General Services Administration’s List of Parties Excluded from Federal Procurement and Non-procurement Programs database;

• Implementing an anonymous reporting mechanism for employees to report any incidence of unethical activity or fraud and abuse violation;

• Providing its employees education pertinent to a client’s Medicare carrier’s and Medicaid payer’s requirements for billing;

• Providing its employees annual corporate compliance training in fulfillment of the OIG’s Compliance Program Guidance for Ambulance Suppliers;

• Developing policies and procedures for all aspects of billing and collection activities; and

• Implementing prepayment and post payment claims monitoring and auditing.