"Do Not Call" policy for manual and digital outreach
Purpose
To establish yuvo Health’s (“Company”) commitment to compliance with the Telephone Consumer Protection Act (“TCPA”) and all other applicable laws when conducting manual and digital patient outreach on behalf of contracted federally qualified health center (“FQHC”) partners.
Policy
The TCPA is a federal law designed to safeguard consumer privacy by restricting telemarketing communications. The Company is committed to complying with this and all applicable rules and regulations when conducting manual and digital outreach on behalf of FQHC partners for the purpose of closing quality care gaps and supporting attributed patients with notifications of opportunities for their care. To that end, the Company has established this policy to provide all outreached patients with the option to opt out of receiving messages and with the expectation that all employees and stakeholders adhere to the procedures listed below.
Scope
This policy applies to all Company employees and stakeholders who conduct manual and digital patient outreach on behalf of the FQHC partners.
Definitions
1. Attributed patient
“Attributed patient” means a patient that is active with a Company contracted health plan and assigned to a Company contracted center and/or participating provider under a value-based care arrangement.
2. Data source
“Data source” means the source of current state, patient lists for various health plan partners. Data sources may differ between health plans, Company outreach staff are expected to know which data source to use when pulling patient outreach lists.
3. Do not call list
“Do not call list” means the list of patients who have exercised their opt out option and thus have been identified as not wanting to be contacted through any of the Company’s outreach strategies.
4. Employee
“Employee” means an individual who performs services for compensation under the supervision, direction, and control of the Company.
5. Opt out
“Opt out” means patient option to disclose through any modality that they wish to no longer be outreached by the Company.
6. Outreach campaign
“Outreach campaign” means the Quality team strategy for closing care gaps through manually outreaching patients identified as having open care gaps for specifically identified metrics.
7. Stakeholder
“Stakeholder” means any party who has an interest in and might be affected by the
performance and outcome of an entity’s business or enterprise. Stakeholders can include
employees, consultants, suppliers, and vendors.
8. Telephone Consumer Protection Act (“ TCPA” )
“TCPA” is a federal statute designed to safeguard consumer privacy by restricting telemarketing communications via voice calls, SMS texts and fax. The statute requires companies to adhere to strict solicitations rules and to honor the consumer’s right to opt out of receiving communications.
Procedure
● Patient lists for the outreach campaigns will be pulled by Company outreach staff from the
appropriate data source. The data source may vary depending on the health plan in which the patient is enrolled. Company outreach staff will be trained and are expected to know which data source to use when pulling the outreach campaign patient lists.
● The patient list that is pulled for outreach will be compared to the standing Do Not Call List and patients identified on the list will be removed from the new outreach list.
● Once removal of patients on the Do Not Call List from the outreach campaign list is completed, the outreach staff will outreach the individuals noted in the updated patient list.
● During digital outreach, patients will be provided with the option to opt out of further outreach. If a patient requests to “opt out” during manual or digital outreach, the outreach staff will immediately add the patient information to the Do Not Call List to ensure that the patient is removed from all future outreach attempts.
Enforcement
Anyone, regardless of position or title, who the Company determines has engaged in conduct that violates a Company policy may be subject to disciplinary action, up to and including termination of employment, at the discretion of the Company. In addition, the Company reserves the right to pursue criminal and/or civil action(s) for wrongdoing where appropriate.