ORGANIZATIONAL DISCLOSURE STATEMENT
Multi-Role Practice, Conflict of Interest Policy & HIPAA Privacy Commitment
Effective Date: June 2020 | Reviewed Annually
Our Commitment to Full Transparency:
Direct Care Training & Resource Center, Inc. (DCTRC) is a multi-discipline organization providing continuing education, professional training, care coordination, litigation consultation, medical claims auditing, and billing advocacy services to providers, practitioners, and facilities across the long-term care, allied health, and residential care sectors in Michigan and throughout the United States. Because our practice spans multiple service categories — some of which may intersect with the professional and financial interests of our clients and the individuals they serve — we believe that full, proactive disclosure of our organizational roles, our conflict-of-interest policies, and our privacy commitments is both an ethical obligation and a professional duty. This Disclosure Statement is provided to all current and prospective clients, learners, partners, and visitors to our website for that purpose.
Our Multi-Role Practice: What We Do and Who We Serve
DCTRC operates across several distinct but related service divisions, each of which serves a defined client population with a defined professional function. These roles include, but are not limited to, the following:
• Continuing Education and Professional Development: We design, deliver, and administer CEU courses and training programs for direct care workers, adult foster care operators, nursing home administrators, allied health professionals, physicians, pharmacy technicians, occupational and physical therapists, professional guardians, and
others across multiple states and disciplines.
• Medical Claims Auditing: We serve as independent auditors for medical and care providers — including physician practices, home health agencies, rehabilitation facilities, adult foster care homes, and long-term care facilities — reviewing billing records, documentation, and reimbursement submissions for accuracy, compliance, and regulatory conformity.
• Billing Dispute Advocacy and Spokesperson Services: We act as authorized spokespersons and advocates on behalf of care providers and medical practices involved in billing disputes with third-party payers, including Michigan No-Fault personal injury protection (PIP) insurers, Medicaid managed care organizations, Medicare Administrative Contractors, and private health insurance carriers. In this capacity, we represent our clients’ documented positions in written submissions, reconsideration requests, and pre-litigation communications with payers.
• Care Coordination: We provide care coordination and case management support services for individuals receiving long-term care, residential services, and community-based supports.
• Litigation Consultation: We provide expert consultation, documentation review, and professional opinion services in litigation matters involving long-term care, billing compliance, and related healthcare regulatory issues.
• Project Management and Provider Development: We assist prospective and operating care providers with program development, regulatory navigation, survey preparation, and operational support across multiple states.
We disclose these roles in full because we recognize that the breadth of our practice creates the theoretical possibility that a client or partner in one service line may also be — or may in the future become — a subject of, or a participant in, a matter handled by another service line. Our policy is to identify any such overlap proactively, to communicate it to all affected parties, and to implement appropriate management strategies as described below.
Conflict of Interest Policy
DCTRC has adopted a formal Conflict of Interest Policy governing all of its service lines and professional relationships. We do not believe that our multi-role practice inherently creates conflicts of interest that compromise our professional obligations to any client, learner, or partner. The services we provide in each division are functionally and structurally distinct, they are rendered pursuant to separate engagement agreements with separate client parties, and they are subject to the information segregation and confidentiality protections described in this Disclosure and in our standard HIPAA Attestation Document. Our position is grounded in the following principles:
First, our billing audit and dispute advocacy services are rendered on behalf of providers — not against them. The providers we audit and the providers we represent in billing disputes are our clients, and our obligations in both roles run entirely in their favor. There is no inherent conflict between helping a provider maintain accurate billing records and representing that provider’s interests in a dispute with an insurer over reimbursement for those same records.
Second, our education and training services are designed to improve the professional competence and regulatory compliance of the individuals and organizations we serve. Providers who use our CEU products are better equipped to maintain compliant documentation — which directly benefits them in any audit or billing dispute context. We view these roles as mutually reinforcing, not competing.
Third, where a specific situation arises in which our organization’s engagement with one client could create an actual or apparent conflict with respect to a separate client in another service line, we will disclose that situation to all affected parties promptly, in writing, and will implement a conflict management plan — which may include information barriers, recusal from the affected matter, or referral to independent counsel — appropriate to the nature and severity of the conflict. We will not proceed with any engagement under conditions of undisclosed conflict.
Clients, learners, and partners who believe they have identified an actual or potential conflict of interest involving DCTRC’s multi-role practice are encouraged to contact us directly at the information provided at the conclusion of this Disclosure. We take all conflict concerns seriously and respond to them promptly.
HIPAA Privacy Commitment and Attestation:
DCTRC operates in environments that routinely involve access to protected health information (PHI) as defined under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and its implementing regulations at 45 C.F.R. Parts 160 and 164. Our medical claims auditing services, billing dispute advocacy work, care coordination activities, and litigation consultation engagements all require access to PHI — including patient records, billing documentation, clinical notes, and insurance claims data — that is entrusted to us by our clients in the course of those engagements.
DCTRC issues a formal HIPAA Attestation Document to each client prior to or concurrent with the commencement of any engagement that involves access to PHI. This Attestation constitutes our binding written commitment to each client that:
• All protected health information accessed, received, created, or transmitted by DCTRC in connection with the client engagement will be used solely for the purposes authorized by the client and permitted under applicable law, and for no other purpose.
• DCTRC will implement and maintain appropriate administrative, physical, and technical safeguards to protect the confidentiality, integrity, and availability of all PHI it handles on the client’s behalf, in accordance with the HIPAA Security Rule.
• DCTRC will not disclose PHI to any third party without the prior written authorization of the client, except as expressly required by law or as necessary to carry out the specific service for which the PHI was provided.
• DCTRC will report to the client, without unreasonable delay and in no case later than sixty (60) calendar days following discovery, any breach of unsecured PHI or any security incident involving PHI accessed in connection with the client engagement.
• PHI accessed in connection with one client engagement will not be used, referenced, or disclosed in connection with any other client engagement, regardless of whether a relationship exists between the two clients in other service lines.
• Upon termination of the client engagement, DCTRC will, at the client’s election, return or securely destroy all PHI received or created in connection with that engagement, except to the extent that applicable law requires retention.
Clients who have not yet received a HIPAA Attestation Document in connection with their engagement with DCTRC and who believe one is required should contact us immediately at the information provided below. We treat HIPAA compliance as a non-negotiable professional commitment, not a procedural formality.
Information Separation and Client Confidentiality
DCTRC maintains strict information separation protocols to ensure that PHI and confidential business information accessed in one service engagement is not used, referenced, or disclosed in any other engagement, including engagements with other clients in the same or different service lines. Each client engagement is handled by a designated service team with access limited to the information necessary to perform the specific services contracted for that client. Our interna information management policies prohibit the use of any client’s confidential information for any purpose other than the
services for which it was provided, and our staff are trained on these requirements and subject to confidentiality obligations as a condition of their engagement with DCTRC.
Questions, Concerns, and Contact Information
This Disclosure Statement is reviewed and updated at least annually and is available on our website at www.directcaretraining.com. If you have questions about our multi-role practice, our conflict of interest policies, our HIPAA compliance program, or any other matter addressed in this Disclosure, please contact us using the information below. We are committed to responding to all inquiries promptly and completely.
Direct Care Training & Resource Center, Inc.
Website: www.directcaretraining.com
Phone: 866.982.4449
Email: carecoordination@directcaretraining.com
Offices in Florida, Georgia, Hawaii, Michigan, and Pennsylvania — Serving All of North America
© 2020 Direct Care Training & Resource Center, Inc. | All Rights Reserved | www.directcaretraining.com
This Disclosure Statement does not constitute legal advice. Clients with specific legal questions regarding HIPAA compliance or conflict of interest obligations are encouraged to consult qualified legal counsel.
