Cam-Held Enterprises, Inc.

CODE OF CONDUCT

MEDICAID COMPLIANCE PROGRAM

Effective Date:	September 1, 2026	Approved By:	Compliance Committee
Policy Owner:	Chief Compliance Officer	Compliance Officer:	Monique Villalta

POLICY

It is the policy of Just Kids, an early childhood learning center operated by Cam-Held Enterprises, Inc., to conduct its operations honestly, ethically, and in compliance with applicable federal and New York State laws, regulations, Medicaid program requirements, contracts, and organizational policies. This Code of Conduct establishes the standards expected of individuals participating in Just Kids operations and its Medicaid Compliance Program.

SCOPE

This Code applies, as appropriate to their roles and responsibilities, to employees, senior administrators, managers, governing body and corporate officers, and applicable contractors, agents, subcontractors, and independent contractors. Each individual is responsible for understanding and following the requirements relevant to his or her duties.

GENERAL CONDUCT

All personnel shall perform their duties honestly, accurately, professionally, and in accordance with applicable requirements. Personnel shall follow Just Kids policies and procedures, seek guidance when requirements are unclear, promptly report known or suspected compliance concerns, cooperate with compliance activities, and complete required education and training.

MEDICAID BILLING AND CLAIMS

Just Kids shall submit or cause to be submitted only claims that are accurate, complete, supported by appropriate documentation, and consistent with applicable Medicaid requirements. No individual may knowingly create, submit, direct, or permit a false, misleading, duplicate, inflated, or otherwise improper claim. Services may be billed only when provided and when applicable eligibility, authorization, documentation, and program requirements have been satisfied.

DOCUMENTATION AND RECORDS

Service, billing, attendance, evaluation, treatment, authorization, credentialing, time, and other Medicaid-related records must be truthful, accurate, complete, timely, and maintained in accordance with applicable requirements and Just Kids policy. Records may not be fabricated, improperly backdated, concealed, destroyed, or altered for the purpose of misleading a payer, auditor, regulator, investigator, family, or other authorized party.

FRAUD, WASTE AND ABUSE

Just Kids prohibits fraud, waste, abuse, kickbacks, deliberate misrepresentation, improper billing, and other conduct intended to obtain Medicaid funds improperly. Suspected fraud, waste, abuse, overpayments, or other compliance concerns must be reported promptly so that the organization can investigate and take appropriate corrective action.

SERVICE QUALITY, AUTHORIZATION AND PROFESSIONAL RESPONSIBILITY

Medicaid-funded services shall be furnished in accordance with applicable eligibility, authorization, plan-of-care, medical-necessity, scope-of-practice, supervision, and service requirements. Personnel shall work within the scope of their licensure, certification, credentials, training, and assigned responsibilities. Financial considerations shall not compromise required quality, safety, or the rights of children and families.

CREDENTIALS AND PROGRAM ELIGIBILITY

Just Kids shall take steps required by law and policy to ensure that individuals and entities participating in Medicaid-related activities are appropriately credentialed and eligible. Individuals must promptly disclose any exclusion, sanction, loss or restriction of license, or other matter that could affect their eligibility or ability to perform assigned duties.

CONFLICTS OF INTEREST AND IMPROPER INDUCEMENTS

Personnel shall avoid improper conflicts between personal interests and their responsibilities to Just Kids and shall disclose potential conflicts in accordance with organizational policy. Bribes, kickbacks, improper remuneration, or anything of value offered or accepted to improperly influence referrals, purchasing, contracting, billing, or health-care program decisions are prohibited.

PRIVACY AND CONFIDENTIALITY

Information concerning children, families, employees, business operations, Medicaid records, and other protected information shall be accessed, used, stored, and disclosed only as authorized. Personnel shall comply with applicable privacy, confidentiality, records, and information-security requirements, including HIPAA when applicable, and shall report suspected privacy or security incidents promptly.

REPORTING COMPLIANCE CONCERNS

Just Kids maintains lines of communication through which compliance questions and potential compliance issues may be raised. Concerns may be reported to the Chief Compliance Officer or through approved reporting channels. Individuals may report concerns anonymously through the Just Kids Anonymous Compliance Hotline.

ANONYMOUS COMPLIANCE HOTLINE: 1-877-386-0966

Chief Compliance Officer: Monique Villalta

Compliance Email: Mvillalta@justkidseclc.org

NON-INTIMIDATION AND NON-RETALIATION

Just Kids prohibits intimidation or retaliation against any person for good-faith participation in the Compliance Program. This includes reporting potential compliance issues; participating in investigations, audits, self-evaluations, or corrective actions; and reporting potential fraud, waste, abuse, intimidation, or retaliation to appropriate internal or governmental authorities. Confidentiality will be maintained to the extent required and permitted by law.

AUDITS, INVESTIGATIONS AND COOPERATION

Personnel shall cooperate truthfully and completely with authorized internal audits, monitoring, investigations, corrective actions, and lawful governmental reviews. No person may conceal, destroy, falsify, or alter records or information in anticipation of or during an audit, investigation, or review.

CORRECTIVE ACTION AND OVERPAYMENTS

When a compliance issue is substantiated, Just Kids shall take timely and appropriate corrective action. Corrective action may include education, process or policy changes, claim correction, repayment of identified overpayments, disciplinary action, increased monitoring, or reporting to governmental authorities when required.

DISCIPLINARY STANDARDS

Failure to comply with this Code, Just Kids policies, or applicable legal requirements may result in corrective or disciplinary action consistent with organizational policies, contractual obligations, and applicable law. Violations may include participation in noncompliant conduct, failure to report known concerns, encouraging or permitting violations, failure to cooperate with compliance activities, retaliation, or knowingly providing false information. Sanctions may include termination of employment or contractual relationships when appropriate.

TRAINING AND EDUCATION

Personnel subject to compliance training requirements shall complete required education at orientation and at least annually, as applicable. Training shall address the Compliance Program, this Code of Conduct, identified risk areas, reporting responsibilities and methods, non-intimidation and non-retaliation protections, fraud, waste and abuse, and other topics required by law or organizational risk.

MANAGEMENT RESPONSIBILITY

Managers and supervisors shall model compliant conduct, promote open communication, ensure personnel understand applicable requirements, respond appropriately to reported concerns, and refrain from discouraging or obstructing good-faith reporting. No manager may direct or permit another individual to violate this Code or applicable law.

ANNUAL REVIEW AND WEBSITE AVAILABILITY

Just Kids shall review its written compliance policies, procedures, and Code of Conduct at least annually and revise them as appropriate. In accordance with 18 NYCRR § 521-1.4(e)(5), when applicable, information concerning the Compliance Program, including this Code of Conduct, shall be made available on the Just Kids website.

COMPLIANCE CONTACT INFORMATION

Chief Compliance Officer: Monique Villalta

Email: Mvillalta@justkidseclc.org

Anonymous Compliance Hotline: 1-877-386-0966