360o Compliance Program

“At Outreach Management, our instinct is to exercise our ethics every day.
Compliance is the cornerstone of our company. It drives quality and innovation
and safeguards the trust we have cultivated with our patients and providers.”
– Ryan Frazier, CEO

Compliance Program

At Outreach, we understand that-more than ever-trust and ethics play key roles in the evolving world of healthcare. Outreachs 360 Compliance Program was designed to bring our business practices into full view, and we welcome end-to-end accountability, every day, for the support and services we provide both patients and clinicians. Our mission is to empower all of our stakeholders to operate at the highest levels of integrity as we work together toward improved patient outcomes.

Beginning with our Board and employees, and extending to our patients and clinicians, our compliance focus is always top of mind. Putting our ideals into practice, Outreach voluntarily elected to adopt a Corporate Integrity Agreement (CIA) with the Office of Inspector General. The CIA has established rigorous compliance measures that are above and beyond standard industry regulations. By voluntarily adopting these business and compliance benchmarks, we have set high standards for our own workforce and a clear example to our industry peers that compliance in and of itself must be the guiding principle for healthcare organizations.

Outreach’s 360 Compliance Program is led by Senior Vice President and Chief of Regulatory Affairs and Compliance, Robert Rossi, a compliance executive with more than 25 years’ experience in healthcare law.

Here are a few examples of how we have ingrained this mindset into our daily business:

• All employees must participate in Outreach’s mandatory, ongoing compliance education training.

• All agreements and company programs must comply with the federal Stark Law and Anti-Kickback Statute.

• All employees must abide by True Health’s Code of Conduct and Ethics, which includes detailed expectations for legal and regulatory compliance, integrity, quality, and the duty to comply and report.

• All laboratory team members must adhere to the strict regulations of the Clinical Laboratory Improvement Amendments (CLIA).

• Executive leaders and Board members proactively participate in compliance by serving on the Executive Compliance Committee.

• The Compliance team performs regular independent audits of the company’s compliance program and business practices.

• All documents, including agreements, contracts, and company assets are put through a rigorous document control process.

Ethics Training

Our Code of Business Conduct and Ethics identifies the values and obligations that all Outreach employees, officers, directors, consultants, and sales force must follow. The following corporate values are the core of True Health’s business practices and corporate conduct:


True Health is dedicated to meeting the highest standards for clinical and scientific quality. We strive to continuously innovate and improve the health and quality of life for the patients we serve.


True Health believes that long-term, trusting business relationships are built by being honest, open and fair to our colleagues within the company, our outside team members, and our valued patients and providers.

Legal and Regulatory Compliance

True Health complies with all applicable laws and regulations in all of its operations. This means that each team member must not only follow the letter but also spirit of the law, i.e. always act ethically and “do the right thing.” even when the law is not specific.

Duty to Comply and to Report

Team members are not only responsible for complying with legal and regulatory requirements, but must also report known or suspected violations of legal or ethical requirements. True Health team members are protected from all forms of retaliation for making good faith reports or inquires.