Code of Conduct

My Digital PT, LLC

Code of Conduct

• Absolute Clinical Autonomy: Guaranteeing that remote PTs, OTs, and SLPs retain absolute independence when determining a patient's functional status and final discharge recommendations. Facility administrative metrics (e.g., census numbers, preferred discharge dates, or length-of-stay targets) must never influence the clinician's objective safety assessment.

• Anti-Inducement Commitment: A clear corporate policy stating that evaluation services are never offered, priced, or structured to incentivize a facility to refer other Medicare or federal healthcare program business to our company.

Assessment/Discharge-Specific Telehealth Policies

• Mandatory Multi-Location Verification: A strict policy requiring the remote therapist to verify and document the exact physical location of the patient (the host facility) and themselves (the distant site) to ensure complete alignment with state-specific practice acts.

• On-Site Safety Facilitation Standard: Criteria establishing that for any virtual physical or occupational mobility assessment, an on-site facility staff member must be present in the room to ensure patient safety during transfers or functional testing. The name of this facilitator must be documented in the file.

• Objective Metrics Mandate: Requiring all evaluations to utilize standardized, validated functional scoring tools adaptable to telehealth (e.g., specific cognitive tests or visual mobility trackers), entirely banning subjective "rubber-stamp" narratives or copied-and-pasted assessments.

2. Compliance Leadership and Oversight

• Compliance Officer (CO): Appointed by and reporting directly to executive leadership and the Board. Because this business operates a high-volume B2B contract model, the CO has the explicit authority to suspend evaluation services for any contracting facility found attempting to manipulate clinical recommendations.

• Compliance Committee: Composed of the CO, the Chief Clinical Officer (representing PT, OT, and ST modalities), and Legal Counsel. The committee meets semi-annually to review cross-state licensure updates, platform access logs, and B2B pricing compliance.

3. Effective Training and Education

All remote evaluating clinicians and corporate account managers must complete mandatory compliance training upon hire and annually thereafter.

• B2B Anti-Kickback Statute (AKS) Training: Education on how providing services to a facility at below Fair Market Value, or providing free hardware, can be viewed as an illegal inducement if it reduces the facility's operational costs in exchange for business.

• The False Claims Act in Non-Billing Models: Training on how inaccurate or backdated clinical documentation—even when not billed to insurance—can create legal liabilities if a facility relies on it to justify administrative billing or safe discharge timing.

• Cross-State Licensure & Compact Rules: Training on the specific rules governing the Physical Therapy, Occupational Therapy, and Speech-Language Pathology compact networks, emphasizing that a therapist must hold an active privilege where the patient sits before initiating an evaluation.

4. Effective Lines of Communication

• Clinician Protection Hotline: A secure, anonymous reporting portal allowing remote therapists to immediately report if an internal manager or a contracting facility partner is pressuring them to modify a discharge recommendation or clear a patient prematurely.

• The Non-Retaliation Policy: Explicit protection for any therapist who refuses to finalize an evaluation due to an unviable video connection or a facility's failure to provide an on-site safety assistant.

5. Risk Assessment, Auditing, and Monitoring

The auditing protocols focus on clinical consistency, software data validation, and contract integrity rather than time logs.

Core Risk Audits

• Evaluation Volume vs. Contract Terms: Regular audits ensuring that contracting facilities are being billed a consistent, flat, Fair Market Value fee per evaluation. Any fluctuations in pricing based on the outcome of the evaluation or the facility’s census are strictly prohibited.

• "Rubber-Stamping" Text Analysis: Electronic screening of completed evaluation text to identify repetitive, cloned, or copied narratives across patients within the same facility.

• Licensure-to-Location Cross-Checks: Routine monthly audits matching the physical location of evaluated patients against the therapist’s active licensure and compact privilege database logs at the exact hour of the encounter.

6. Enforcing Standards Through Well-Publicized Disciplinary Guidelines

• Uniform Application: Standards are enforced equally from per-diem evaluating speech therapists to executive business development managers.

• Immediate Termination Offenses: Clear boundaries regarding actions that result in contract termination or employment dismissal, specifically:

  • Falsifying or altering a patient’s functional scores to match a facility's desired discharge date.

  • Conducting a telehealth evaluation in a state where active licensure or compact privileges are not held.

  • Sharing platform access credentials with unlicensed or unverified personnel.

7. Responding Promptly to Detected Offenses and Corrective Action

• Investigation Timelines: The Compliance Officer must investigate any allegation of clinical coercion or credential lapses within 72 hours.

• B2B Contract Intervention: If a routine internal audit reveals that a contracting facility is systematically attempting to override the clinical judgments of our evaluating therapists to accelerate discharge processing, the company will immediately freeze the contract, suspend service delivery, and review the arrangement for regulatory compliance.