2.0 Strict Non-Discrimination Policy

In accordance with Title VI of the Civil Rights Act of 1964, Section 1557 of the Affordable Care Act (ACA), the Americans with Disabilities Act (ADA), the Age Discrimination Act of 1975, and Section 504 of the Rehabilitation Act of 1973, circYoulation strictly prohibits discrimination.

We do not exclude, deny benefits to, or otherwise discriminate against any person on the basis of:

Race, Color, or National Origin

Age

Physical, Mental, or Intellectual Disability

Sex (including gender identity and sexual orientation)

Religion or Creed

Socioeconomic Status

This unconditional standard of equity applies to all facets of our network, including state-credentialed transit routing, in-home non-clinical health assessments, Social Determinants of Health (SDOH) surveys, and administrative coordination.

3.0 Safe, Equitable Delivery of Non-Clinical Services

circYoulation guarantees that all members are treated with professional boundaries and complete confidentiality, whether in transit or within their personal living environments.

Strictly Non-Clinical Capacity:

To protect member safety and mitigate operational risk, all accommodations and assistance are provided strictly in a non-clinical capacity. Our credentialed network partners will never offer medical advice, attempt clinical diagnoses, or exceed their certified scope of non-clinical field enablement.

In-Home Professionalism:

When authorized personnel from circYoulation Health, LLC enter a member’s private residence to conduct administrative health surveys, they operate under strict professional and ethical protocols. We respect the diverse cultural backgrounds and physical environments of the communities we serve.

4.0 Accessibility and Accommodations

To ensure our healthcare logistics network is truly universal and accessible to vulnerable populations, circYoulation provides the following accommodations free of charge:

Mobility Assistance:

Our state-credentialed commercial fleet network and credentialed operators safely accommodate and secure specialized mobility devices, including wheelchairs and walkers, providing ADA-compliant ambulatory passenger assistance.

Service Animals:

Legally recognized, highly trained service animals required to assist members with disabilities are fully accommodated within our commercial vehicles.

Language Access Services (LEP):

We coordinate with state brokers and healthcare partners to facilitate access to free language assistance services, qualified interpreters, and translated health assessment information for individuals with Limited English Proficiency.

5.0 Vetted, Professional Network Partners

Insurance underwriters, healthcare partners, and our members rely on our uncompromising commitment to safety. Safety and compliance begin with the professionals representing our brand. circYoulation partners exclusively with highly vetted, credentialed independent business operators.

Every credentialed operator undergoes extensive federal and state background checks, strict Motor Vehicle Record (MVR) audits, and mandatory substance screenings. Compliance with this Notice of Non-Discrimination is a non-negotiable requirement for all credentialed operators and field specialists. Any network partner found engaging in discriminatory practices, harassment, or refusal of equitable service faces immediate network removal.

6.0 Grievance and Ethics Reporting Procedure

circYoulation actively mitigates risk and ensures operational excellence through a transparent, anti-retaliation grievance framework.

If any member, state broker, facility partner, or stakeholder believes that circYoulation or its credentialed network operators have failed to provide equitable services or discriminated in any way, they have the right to file a formal grievance.

How to File a Grievance:

Grievances may be reported securely directly to the circYoulation Corporate Compliance Department for swift, impartial investigation:

Email: [email protected]

Corporate Mail: circYoulation Compliance Department, PO Box 2505, Myrtle Beach, SC 29578

Filing a Federal Civil Rights Complaint:

Individuals also maintain the right to file a civil rights complaint directly with the U.S. Department of Health and Human Services, Office for Civil Rights (OCR):

Online: OCR Complaint Portal at https://ocrportal.hhs.gov/ocr/portal/lobby.jsf

Mail: U.S. Department of Health and Human Services, 200 Independence Avenue, SW, Room 509F, HHH Building, Washington, D.C. 20201

Phone: 1-800-368-1019, 800-537-7697 (TDD)