Med-max, Inc. is a privately-hold company that developed and markets billing software

Med-max, Inc. is a privately-hold company that developed and markets billing software that electronically reviews health
care claim forms for eligibility and compliance with major private and federal-payer rules, and then submits claims
directly to those payers for its clients. The goal of the software is to submit claims fast and error-free, while maximizing
reimbursement for its clients. The target market for Med-max’s billing software is hospitals and medical practices.

While Med-max is headquartered in Albany, New York, the company sells its products throughout the United States and
has offices in five states and employs 500 people nationwide. Med-max markets and sells its products direct to medical
providers. The billing software is hosted by servers owned and operated by or on behalf of Med-max.

The billing software segment of the healthcare industry is very competitive and price sensitive. To stay competitive, Med-
max recently transitioned from charging clients solely on a per-claim basis to charging based, in part, on a percentage of
collections. Med-max is a member of the Billing AssociationTM, Inc. a not-for-profit trade association representing
businesses that develop and market medical billing software in the United States, and regularly attends BillFest, the
Billing AssociationTM, Inc.‘s three-day conference featuring general assembly presentations by myriad influencers and
thought-leaders, interactive workshops, networking lunches, evening events, social activities, and more. There are lots
of &quot:freebees" provided by vendors at BellFest, ranging from lollipops and cookies to iPads and weeklong
island getaways,

Please create draft Code of Ethics/Code of Compliance for Med-max, Inc. In addition to covering “general compliance’
topics, it should address the specific risks related to its business and business model. Feel free to assume additional
facts that would be consistent with privately-held company of this size and scope.

After preparing your Code of EthicsiCode of Compliance, you will be asked to schedule a meeting with your professor to
present the specific risks related to this business and business model that you identified, and why you chose to include
in your code the provisions that you did