2.0 Strict Scope of Non-Clinical Health Services & In-Home Conduct

To protect our members and mitigate operational liability, circYoulation maintains rigid boundaries regarding the scope of care provided by our network, both in transit and within the home.

In-Home Professionalism & Boundaries:

Through circYoulation Health, authorized personnel frequently enter members' private residences to conduct critical, non-clinical administrative health surveys (such as Health Risk Assessments and SDOH evaluations). When executing in-home services, personnel operate under strict professional and ethical protocols. Network partners are trained to respectfully gather administrative data while strictly observing physical and personal boundaries, prioritizing the safety, privacy, and dignity of the member in their living environment at all times.

Strictly Non-Clinical Capacity:

Personnel providing administrative coordination, transportation, survey facilitation, and health assessments operate strictly in a non-clinical capacity. Network participants are explicitly prohibited from providing clinical diagnoses, medical triage, skilled nursing care, medical advice, or medication administration.

Emergency Medical Disclaimer (Call 911):

circYoulation does not provide emergency medical transportation or emergency response services. If a passenger or member exhibits signs of acute distress, trauma, or a life-threatening crisis, personnel are strictly mandated to contact 911 immediately.

3.0 Rigorous Operator Vetting and Credentialing

Safety is the foundational metric of our network. circYoulation maintains a stringent vetting process to ensure only highly qualified, thoroughly vetted professionals interact with our members.

Comprehensive Background Screening:

Prior to field deployment, all personnel must pass mandatory federal and state background checks. Individuals with convictions for substance abuse, violence, sexual offenses, or breaches of trust are strictly prohibited from our network.

Motor Vehicle Record (MVR) Excellence:

We demand exemplary safety behind the wheel. All operators are subject to 10-year MVR audits, strict limits on moving violations, and a zero-tolerance policy for severe driving infractions.

Zero Tolerance for Impairment:

Performing contracted services or operating any vehicle while under the influence of alcohol, illegal substances, or impairing prescription medications is strictly forbidden. We enforce a strictly drug-free environment utilizing mandatory pre-service, random, and post-incident screening protocols.

Safety Credentialing:

Before executing a single route or in-home assessment, operators must successfully complete comprehensive credentialing, including Defensive Driving, First Aid, CPR, Bio-Hazard/Spill Kit Protocol, and Passenger Assistance training.

4.0 Healthcare Program Integrity: Fraud, Waste & Abuse (FWA)

Because our network supports health plans, Medicaid Managed Care Organizations (MCOs), and Medicare Advantage programs, all participants must strictly adhere to federal and state healthcare compliance mandates.

Truth-in-Reporting & False Claims Act:

Every trip confirmation, GPS arrival stamp, in-home Health Risk Assessment (HRA), and Social Determinants of Health (SDOH) intake must reflect an actual, completed encounter. Falsifying logs, manipulating arrival timestamps, or fabricating survey responses constitutes federal healthcare fraud and will result in immediate regulatory reporting.

Anti-Kickback Statute (AKS):

Network participants are strictly prohibited from offering, soliciting, giving, or receiving any kickback, bribe, or unauthorized referral fee to induce member volume or influence healthcare decisions.

Prohibition of Tips & Gratuities:

To protect vulnerable individuals and ensure compliance with healthcare benefit guidelines, personnel may not solicit or accept personal cash tips, gifts, loans, or financial favors from health plan members or their families.

5.0 Patient Privacy, Confidentiality & HIPAA Compliance

Protecting Member Protected Health Information (PHI) and Personally Identifiable Information (PII) is a fundamental legal obligation governed by the Health Insurance Portability and Accountability Act (HIPAA) and the HITECH Act.

Strict Confidentiality:

Member names, home addresses, phone numbers, medical appointments, and assessment answers are strictly confidential. PHI must never be shared, discussed, or exposed to unauthorized parties.

Secure Digital Infrastructure:

All member data, transit logs, and non-clinical health assessments are processed exclusively through encrypted, secure digital management portals.

Social Media & Recording Prohibition:

Taking photographs, capturing video or audio of members, or discussing member encounters on social media, messaging platforms, or public forums is strictly prohibited under federal law.

6.0 Fleet Safety & Commercial Asset Integrity

The vehicles utilized in the circYoulation network are highly regulated, state-credentialed commercial NEMT assets equipped with mandated life-safety equipment.

Daily Digital Vehicle Audits:

To ensure absolute fleet integrity and the proactive identification of safety hazards, operators are required to perform comprehensive digital pre-trip and post-trip safety inspections.

Telematics and Active Route Monitoring:

Our commercial assets are continuously monitored utilizing advanced GPS and telematics technology. This ensures efficient routing, tracks safe driving behaviors, and provides state brokers and auto-liability underwriters with transparent, verifiable transit data.

Distraction-Free Driving:

The use of mobile devices while operating a commercial vehicle is restricted exclusively to hands-free GPS routing and official dispatch communication.

Pristine Fleet Hygiene:

To protect the respiratory health of our vulnerable members, smoking and vaping are strictly banned inside all commercial assets.

7.0 Non-Discrimination & Civil Rights Compliance

In accordance with Title VI of the Civil Rights Act and Section 1557 of the Affordable Care Act (ACA), circYoulation enforces an uncompromising standard of equity.

Equitable Service Delivery:

Services must be provided without discrimination based on race, color, national origin, age, disability, sex, religion, gender identity, or socioeconomic standing.

Harassment-Free Operations:

We enforce zero tolerance for harassment, discrimination, verbal abuse, or disrespectful conduct directed at members, facility personnel, fellow network partners, or administrative staff.

8.0 Ethics Reporting and Whistleblower Protection

circYoulation is committed to continuous operational improvement and ethical business practices. Upholding these ethical benchmarks is a universal obligation across our network.

Duty to Report:

Any individual who witnesses, suspects, or becomes aware of a safety violation, HIPAA breach, fraudulent billing activity, or breach of this Code must report it immediately.

Strict Non-Retaliation Policy:

circYoulation strictly prohibits retaliation, intimidation, or adverse action against any individual who reports a compliance concern in good faith or assists in an investigation.

Reporting Channels:

Reports may be filed securely and transparently by contacting the circYoulation Compliance Department directly through our corporate portal.