Provider Policies

How to use this document. These Provider Policies are the operational standards referenced throughout your Provider Agreement. They govern how Services are performed on the Total Life Platform and may be updated from time to time as provided in the Agreement. Sections marked “UNIVERSAL” apply to every Provider regardless of license. Sections or paragraphs marked with an APPLIES TO box apply only to the Provider types named. You are responsible for the universal sections and the addenda relevant to your license and the Services you have agreed to perform.

Relationship to other documents. These Policies are subordinate to the signed Provider Agreement and Business Terms. The order of precedence among the documents governing your engagement is: (1) the Business Terms; (2) the Provider Agreement; (3) these Provider Policies; and (4) the Total Life Terms of Use and other platform policies applicable to all users. In the event of a conflict, the higher-ranked document controls. Compensation amounts, rates, and pay timing are set solely in the Business Terms. Liability allocation, indemnification, and forfeiture provisions are set in the Provider Agreement. Where supervision or collaborative practice is required, it is governed by a separate Supervision and Collaborative Practice Agreement. The Total Life Terms of Use govern all users of the Platform, including both patients and Providers; you must comply with them in your use of the Platform, and be familiar with the patient-facing Notice of Privacy Practices, Consent to Telehealth, and Privacy Policy that frame the services you deliver. The clinical services entity contracting with you is Total Life FL, P.A.; the Platform and certain administrative services are provided by Total Life, Inc. and its affiliates. Nothing in these Policies is intended to direct or control the manner or means by which you exercise independent clinical judgment.

1. Platform and Technology Standards

UNIVERSAL, applies to all Providers.

1.1 Platform Access and Use

All Services must be performed through the Company's designated Platform. Provider may not deliver, schedule, or document Services outside the Platform except where expressly directed by the Company. Provider accounts are personal and may not be shared, delegated, or accessed by any other individual. Provider is responsible for all activity occurring under their credentials.

1.2 Device and Connection Security

Provider shall perform all Services using: (i) hardware that is encrypted and protected by two-factor authentication; (ii) a secure, private, and stable internet connection; and (iii) a Virtual Private Network (VPN) where requested by the Company. Provider shall not perform Services or access the Platform over public Wi-Fi or any unsecured network. Provider shall keep operating systems, browsers, and security software current.

1.3 Environment and Presentation

Provider shall perform video Services from a private, professional setting that protects patient confidentiality, free from interruption and from anyone who is not a party to the visit, using a neutral, professional backdrop. Provider shall be physically located within the United States at all times when delivering Services.

1.4 Technical Failure and Downtime

If a session is interrupted by a technical failure, Provider shall attempt to reconnect promptly and, if reconnection is not possible, follow the Company's session-recovery protocol, document the interruption, and arrange to complete or reschedule the session so that patient care is not compromised. Provider shall report recurring Platform issues to the Company through the designated support channel.

1.5 Acceptable Use

Provider's license to use the Platform is limited to delivering Services and is governed by the Total Life Terms of Use, which apply to all Platform users. Operationally, Provider shall use the Platform only in compliance with applicable law and shall not:

• Use the Platform for any purpose other than delivering Services to Total Life patients.
• Share, disclose, or transfer login credentials or account access to any other person, or permit any third party to access the Platform.
• Reverse engineer, decompile, modify, copy, or create derivative works of the Platform, or attempt to disrupt its functionality, integrity, or performance.
• Attempt to gain unauthorized access to, scan, probe, or test the vulnerability of the Platform or any related systems, networks, or data, or circumvent any security or monitoring measures.
• Scrape, harvest, or collect information about other users or patients except as required to deliver Services.
• Upload or transmit any virus, malware, or other harmful code.
• Use the Platform to build or support a competing product or service, or publish benchmarking or comparison results regarding the Platform without the Company's prior written consent.

1.6 Geographic Restrictions

Provider shall deliver Services and access the Platform only from a location within the United States. Provider shall not access the Platform or perform Services from any country subject to a U.S. Government embargo, designated as a State Sponsor of Terrorism, or while listed on any U.S. Government list of prohibited or restricted parties.

2. Clinical Documentation Standards

UNIVERSAL core, with license-specific additions noted below.

Defined term. “Clinical Documentation” means the complete, accurate, legible, and timely medical record required to substantiate the performance, medical necessity, coding, and billing of Services in accordance with CMS, Medicare, and other applicable payer requirements, including, as applicable, treatment plans, progress notes, assessments, diagnoses, CPT/HCPCS codes, and CMS allowable ICD diagnostic codes.

2.1 Timeliness and the Payment Condition

Provider shall complete and electronically lock all required Clinical Documentation for each Service within seventy-two (72) hours of the session. Timely, locked documentation is a condition of payment. The detailed payment, withholding, and forfeiture mechanics, including the limited exceptional-case window through twenty (20) days and the permanent forfeiture thereafter, are set forth in the Clinical Documentation section of the Provider Agreement and control over any summary here. Completion of documentation remains a professional obligation that survives any forfeiture of payment.

2.2 Provider Responsibility for Comprehensiveness

Provider is solely responsible for the clinical accuracy, completeness, and adequacy of all Clinical Documentation, including ensuring that each note fully supports the medical necessity, coding, and billing of the Service rendered. The Company's templates, fields, and prompts are aids only and do not define the limits of a complete note; Provider shall document all clinically and billing-relevant information whether or not a corresponding field is provided. If Provider's license, the Services Provider performs (including prescribing or asynchronous services), or applicable payer or regulatory requirements call for documentation fields not present in the Platform, Provider shall promptly notify the Company to request their addition and, pending any change, shall document the required information within the available note. Provider may not rely on the absence of a template field to excuse incomplete or non-compliant documentation.

2.3 Treatment Plans

Provider shall establish and maintain a treatment plan for each patient receiving ongoing Services. Treatment plans must identify diagnoses, clinically relevant findings, individualized goals and interventions, and the anticipated frequency and modality of services, and must be reviewed and updated at least once every thirty (30) days or sooner if clinically indicated.

2.4 Progress Notes

Provider shall complete a progress note for each Service sufficient to support medical necessity and the codes billed. Progress notes must document the date of service, duration, services provided, patient response or findings, progress toward treatment goals or the clinical rationale for continued services, and must be authenticated in accordance with CMS requirements.

2.5 Diagnoses and Coding Integrity

All diagnoses submitted for billing shall be drawn from CMS-approved ICD-10-CM code sets, be clinically supported, and be consistent across the treatment plan, progress notes, and services billed. Provider shall not upcode, downcode, or otherwise select codes inconsistent with the services actually rendered, and shall ensure that any time-based code is supported by documented time that meets the code's threshold. Pay follows a properly documented, billable code; a service that does not meet the requirements of the code may not be billed or compensated as such.

2.6 Corrections and Addenda

Corrections shall be made only by addendum or the Platform's amendment function, never by deleting or overwriting locked entries. Each correction must be dated, attributed, and reasoned. Provider shall not alter documentation to conform to a payer outcome.

APPLIES TO: Physicians, Nurse Practitioners, Physician Assistants

Prescribers shall additionally document medication rationale, dosing and titration decisions, informed consent for psychotropic medications where applicable, and medication reconciliation. Controlled substances may not be prescribed through the Platform (see Section 5.6).

APPLIES TO: Any Provider performing asynchronous Services

For any asynchronous Service (for example, message-based review, results review, or care coordination performed outside a live session), Provider shall document the date and time the work was performed, the specific activity undertaken and information reviewed, the clinical assessment or decision reached, any communication sent to the patient or care team, and the total time spent, in a manner sufficient to support the medical necessity and the code billed for the asynchronous Service.

APPLIES TO: Licensed Therapists, Psychologists

Therapy and psychology Providers shall additionally document the modality used, the treatment-plan goal addressed, risk assessment (including suicidal/homicidal ideation screening and findings), and any safety planning performed, in a manner consistent with the time-based psychotherapy code billed.

APPLIES TO: Psychologists (testing)

Providers performing psychological or neurocognitive testing shall document the instruments administered, raw and interpreted results, the testing environment and any accommodations, and the clinical interpretation supporting any diagnostic conclusion.

APPLIES TO: Registered Dietitians, Nutrition Professionals

Nutrition Providers shall additionally document the nutrition assessment, the individualized nutrition care plan, and coordination with medical or psychiatric providers where nutrition intersects with the behavioral-health treatment plan.

3. Billing, Coding, and Compensable Time

UNIVERSAL core, with license-specific additions noted below.

3.1 What Counts as Compensable Patient Work

Compensation is set in the Business Terms and is based on patient care time actually performed. For the avoidance of doubt at the operational level:

• Live (synchronous) patient time, time spent in real-time evaluation, management, therapy, or assessment with the patient present, is compensable.
• Documentation and note-taking time, time spent writing, completing, or locking Clinical Documentation, is not separately compensable, even where CMS permits such time to be counted for billing purposes. Documentation is a required, unpaid professional obligation that conditions payment for the underlying Service.

Where the Business Terms provide for any asynchronous patient work to be compensated, the Company will define the qualifying activities; absent such provision, only live patient time is compensable.

3.2 E/M and Time-Based Services

For evaluation and management and other time-based services, compensable time is measured by actual minutes of direct patient care and prorated accordingly, exclusive of documentation time. Provider shall accurately record start and stop times or total direct-care minutes as required by the Platform.

3.3 Therapy Sessions

Psychotherapy sessions are compensated based on the time associated with the CPT code billed (for example, 90832, 90834, 90837), regardless of minor variance in actual session length, provided the documented time meets the threshold required for that code. A session that does not meet a code's minimum time threshold may not be billed under that code.

3.4 Billing Records and Cooperation

Provider shall prepare and submit complete and accurate billing records for all Services in accordance with these Policies and shall provide all information reasonably required to support collections and payer reimbursement. Provider shall cooperate with the Company's billing operations, including any affiliated management services organization engaged by the Company.

APPLIES TO: Physicians, Nurse Practitioners, Physician Assistants, and CoCM team members

Prescribers and CoCM participants shall follow the Company's E/M code-selection guidance and, for Collaborative Care Management, accurately track and attribute monthly care-management minutes to the correct CoCM code, recognizing that CoCM time is tracked at the program level across the care team.

APPLIES TO: Care Management and Remote Therapeutic Monitoring Providers

Care management and RTM Providers shall track and document the monthly time and touchpoints required to support the applicable care-management or RTM codes, and shall ensure each billed period meets the code's minimum time and contact requirements.

3.5 Provider Attestation at Billing

As the licensed clinician rendering the Service, Provider is responsible for the truthfulness and accuracy of every claim attributable to Provider's Services. By completing and locking Clinical Documentation and by submitting or approving a Service for billing, Provider attests that the Service was actually rendered as documented, was medically necessary, and is accurately and completely supported by the documentation and the code selected. Provider shall not submit, approve, or support any claim that Provider knows or reasonably should know is inaccurate, unsupported, or non-compliant. Where billing is performed by the Company or its affiliated management services organization on Provider's behalf, such billing relies on Provider's attestation, and Provider remains responsible for the accuracy of the underlying documentation and coding.

4. Coordination of Care and Continuity

UNIVERSAL, applies to all Providers.

Timely coordination of care is central to Total Life's commitments to its patients and to its referral and clinical partners. Provider shall:

• Communicate clinically significant findings, changes in status, and treatment changes to the patient's primary care provider and other treating clinicians as clinically indicated and as required by the applicable program (for example, monthly PCP communication under CoCM).
• Respond to patient and care-team messages within the timeframes established by the Company.
• Support warm hand-offs and transitions of care, ensuring that records and care plans move with the patient.
• Maintain availability sufficiently far in advance to allow established patients to schedule follow-up sessions, consistent with the continuity-of-care commitment in the Provider Agreement.
• Escalate any patient who is deteriorating or at risk in accordance with Section 5 (Clinical Quality and Safety).

5. Clinical Quality and Safety Protocols

UNIVERSAL core, with a license-specific addition noted below.

5.1 Provider as Treating Clinician

Provider is the licensed clinician responsible for the care of each patient Provider treats. All diagnostic, treatment, prescribing, and patient-care decisions are made by Provider in the exercise of Provider's independent professional judgment. The Company operates the Platform and provides administrative, technology, and operational support; the Company does not practice medicine, does not provide clinical care, and does not direct or override Provider's clinical judgment. Responsibility for the clinical appropriateness, safety, and outcomes of the Services rendered rests with Provider as the treating clinician.

5.2 Quality Assurance and Chart Review

Provider's documentation and care are subject to periodic quality review and audit. Where a chart fails review, Provider shall promptly correct deficiencies through proper addendum and participate in any corrective-action plan. Repeated or uncorrected quality deficiencies may affect Provider's good standing on the Platform.

5.3 Crisis, Emergency, and Risk Escalation

Provider shall follow the Company's crisis and emergency protocols at all times, including for suicidal or homicidal ideation, acute medical emergencies arising during a telehealth session, and any situation presenting imminent risk. Because Services are delivered remotely, Provider shall confirm the patient's physical location at the start of each session so that local emergency services can be directed if needed. Provider shall document all risk findings, safety planning, and escalations.

5.4 Mandatory Reporting

Provider shall comply with all applicable mandatory-reporting obligations, including suspected abuse, neglect, or exploitation of vulnerable adults, consistent with the law of the state in which the patient is located. Given Total Life's older-adult population, Provider shall be alert to signs of elder abuse and self-neglect and shall report and document as required by law.

5.5 Validated Screening

Provider shall administer or direct the administration of validated screening instruments at intake and at clinically indicated intervals in accordance with Company protocols and payer requirements, review each result individually, review results directly with the patient at the appointment, and incorporate findings into the treatment plan. Screening instruments include, without limitation, PHQ-9/PHQ-2, GAD-7, C-SSRS, MoCA/MMSE, AUDIT/DAST, and PROMIS measures. Failure to administer required screenings in a timely manner is a documentation deficiency subject to Section 2.

5.6 Prescribing

APPLIES TO: Physicians, Nurse Practitioners, Physician Assistants, and other Providers with prescriptive authority

No controlled substances. Provider is strictly prohibited from prescribing, ordering, dispensing, or arranging for any controlled substance (any substance in DEA Schedules II through V) through the Platform or in connection with any Service rendered for Total Life. This prohibition applies regardless of Provider's DEA registration or state authority, and regardless of clinical indication. A patient requiring a controlled substance shall be referred to an appropriate in-person or external provider; Provider shall not use the Platform to initiate, continue, refill, or adjust any controlled-substance prescription. Violation of this prohibition is a material breach of the Provider Agreement.

For all permitted (non-controlled) medications, Provider shall prescribe only within Provider's license and applicable state and federal law, and is solely responsible for knowing, following, and keeping current with all laws and regulations governing prescribing via telehealth as they change from time to time. For each prescription, Provider shall verify the patient's identity and physical location, complete any examination required by applicable law, use electronic prescribing, and document the clinical rationale, informed consent, and monitoring plan. Provider is responsible for appropriate ongoing medication monitoring and for ensuring continuity of clinically necessary medications, including responsibly managing active prescriptions upon any transition or termination of care so that no patient is left without clinically necessary medication.

Nothing in this Section or in any Company protocol overrides the prescriber's independent clinical judgment as to permitted medications.

5.7 Laboratory and Diagnostic Ordering

APPLIES TO: Providers authorized to order tests within their licensure

Where clinically indicated and within Provider's scope of licensure and applicable law, Provider may order laboratory or diagnostic tests, whether through the Platform's designated ordering process or through an external laboratory or facility. In all cases, Provider shall document the clinical indication for each order and is responsible for the timely review, documentation, and clinical follow-up of all results for tests Provider orders, including prompt action on and documentation of abnormal or critical findings, regardless of whether the order was placed on or off the Platform. Provider shall communicate clinically significant results to the patient and relevant care-team members consistent with Section 4 (Coordination of Care). Where ordering or resulting occurs outside the Platform, Provider remains responsible for ensuring the order, result, and follow-up are documented in the patient's record on the Platform.

6. Telehealth and Multi-State Licensure

UNIVERSAL, applies to all Providers.

License-where-the-patient-is rule. Provider may deliver Services only to patients physically located in a state where Provider holds an active, valid, unrestricted license and all required authorizations. Provider shall confirm the patient's state at the start of each session and shall not proceed if Provider is not licensed in that state.

Licensure maintenance. Provider is solely responsible for maintaining licensure in all applicable states, including continuing-education and, where applicable, DEA obligations. Provider shall renew each license no later than sixty (60) days before expiration, or notify the Company in writing no later than ninety (90) days before expiration if Provider does not intend to renew. If any license is restricted, suspended, or revoked, Provider shall notify the Company immediately and cease all Services in the corresponding state.

Telehealth standards. Provider shall comply with all Medicare telehealth rules and applicable state telehealth requirements, including identity verification, telehealth consent capture, and originating/distant-site documentation, and shall follow the modality specified for each Service.

7. Scheduling, Cancellations, and Reliability

UNIVERSAL, applies to all Providers.

Provider controls their own availability through the Platform. Once a patient appointment is booked within Provider's posted availability, it is a professional commitment. Provider shall not cancel or reschedule a booked session except in cases of documented illness, personal emergency, or other circumstances beyond Provider's reasonable control, and, except where impracticable, shall give no less than twenty-four (24) hours' advance notice to both the patient and the Company and reschedule directly through the Platform.

Reliability standards. A “No-Show” is Provider's failure to enter a scheduled session within ten (10) minutes of the start time without prior notice. A “Pattern of Unreliability”, defined as two (2) No-Shows, or three (3) late cancellations or reschedules with less than twenty-four (24) hours' notice (excluding the excused circumstances above), within any rolling ninety (90)-day period, may, at the Company's discretion, result in suspension of new-patient assignment, restriction or revocation of Platform access, or termination as provided in the Provider Agreement.

Patient cancellations and no-shows. Any patient no-show or late-cancellation fee is governed by the Company's patient-facing policies and is administered by the Company directly with the patient. Such fees are never billed to Medicare, are applied uniformly across patients regardless of payer, and are not charged where prohibited (including to Qualified Medicare Beneficiaries). Whether Provider is compensated for a patient no-show or late-cancelled slot is determined solely by the Business Terms.

8. Compliance, Fraud, Waste, and Abuse

UNIVERSAL, applies to all Providers.

Provider shall perform all Services in accordance with applicable law and the Company's compliance program, including:

• No referral-based compensation. Compensation is never based on the volume or value of referrals or of business generated between the parties, consistent with the Anti-Kickback Statute and the Stark Law.
• Exclusion and licensure integrity. Provider represents they are not, and have never been, excluded from any federal or state health care program, and shall notify the Company immediately of any exclusion, debarment, licensure action, investigation, or discipline.
• Billing integrity. Provider shall not submit or support any claim for services not rendered, not medically necessary, or not meeting the requirements of the code billed.
• Reporting and non-retaliation. Provider shall report suspected fraud, waste, abuse, or compliance concerns through the Company's designated channel. The Company prohibits retaliation for good-faith reporting.
• Training. Provider shall complete required compliance and fraud-waste-abuse training as assigned.

8.1 Notification of Claims, Complaints, and Investigations

Provider shall notify the Company promptly, and in any event within the timeframe specified by the Company, upon becoming aware of any of the following relating to Provider or to Services performed on the Platform: any malpractice or liability claim or threatened claim; any licensure-board complaint, inquiry, or disciplinary action; any payer audit, overpayment demand, or recoupment; any government investigation, subpoena, civil investigative demand, or exclusion action; and any change to the representations Provider made in the Provider Agreement (including license status, insurance, or program eligibility). Provider shall not respond to any audit, investigation, or demand concerning Company-billed Services without coordinating with the Company, except where independent action is required by law or to meet a legal deadline.

8.2 Cooperation with Audits and Defense

Provider shall cooperate fully and in good faith with the Company in responding to any audit, investigation, payer inquiry, or claim relating to Services performed on the Platform, including by providing requested documentation, participating in the defense or response, and giving truthful information. This obligation applies whether the matter arises during or after the term of the engagement.

8.3 Records Retention and Survival

Provider's obligations to maintain, provide access to, and cooperate regarding Clinical Documentation and billing records survive termination of the engagement for the full period required by applicable law, including Medicare and other payer record-retention and audit look-back periods. Following termination, Provider shall continue to provide reasonable access to, and cooperation regarding, records of Services performed on the Platform for the duration of any applicable retention or look-back period, and the Company may retain such records as necessary to meet its legal, billing, and audit obligations.

9. Privacy and Data Security

UNIVERSAL, applies to all Providers.

As a member of the Company's workforce under HIPAA when providing care on the Company's behalf, Provider shall handle Protected Health Information in accordance with HIPAA, the Company's Notice of Privacy Practices, and the Company's privacy and security policies. Operationally, Provider shall: access only the minimum PHI necessary; create, store, and transmit PHI only within the Platform and approved systems; never store PHI on personal or unencrypted devices; and report any suspected privacy or security incident to the Company immediately and in any event within the timeframe specified by Company policy. Upon termination, Provider's access to PHI and Company systems will be disabled, and Provider shall return or destroy Company data as directed.

10. Professional Conduct and Patient Interaction

UNIVERSAL, applies to all Providers.

Provider shall maintain professional boundaries and avoid dual or exploitative relationships with patients; treat patients, caregivers, colleagues, and Company staff with respect and without discrimination; communicate in a manner appropriate to an older-adult population, including sensitivity to sensory, cognitive, and access needs; and refrain from conduct that would compromise patient safety, the integrity of the Platform, or the Company's standing with patients and partners. Conduct standards inform Provider's good standing on the Platform.

11. Credentialing and Payer Enrollment

UNIVERSAL, applies to all Providers.

Provider shall complete all onboarding and credentialing forms provided by the Company within one (1) week of executing the Provider Agreement, and shall maintain an accurate credentialing profile (including CAQH where applicable) and cooperate with re-credentialing on the Company's cycle. Provider authorizes the Company to enroll, credential, re-credential, and contract with governmental and commercial payers on Provider's behalf as set forth in the Provider Agreement. Provider shall promptly review and confirm the accuracy of any enrollment application or attestation submitted on Provider's behalf and shall notify the Company immediately of any change affecting eligibility or enrollment.

Credentialing fees. Any credentialing-fee, waiver, or fee-recovery arrangement is governed by the Business Terms and the Provider Agreement, not by these Policies.

12. Onboarding and Training

UNIVERSAL core, with license-specific additions as assigned.

Provider shall complete required onboarding, Platform training, and recurring training (including compliance, fraud-waste-abuse, privacy/security, and telehealth) within the timeframes assigned by the Company, and shall complete any license- or program-specific competency or protocol training applicable to the Services Provider has agreed to perform (for example, CoCM workflow training for CoCM participants, or testing-protocol training for psychologists performing assessments). Completion of required training is a condition of continued access to the corresponding Services.

13. Offboarding and Transition of Care

UNIVERSAL, applies to all Providers.

On notice of termination by either party, Provider shall not abandon any patient and shall ensure continuity of care for assigned patients. Provider shall first make reasonable efforts to facilitate an internal transfer to another appropriate Platform provider and, where an internal transfer is not feasible or clinically appropriate, take reasonable steps to assist the patient in transitioning to a suitable external provider, ensuring that all appropriate medical records are transferred to the receiving provider. Provider shall participate in transition sessions and administrative hand-off protocols as directed and shall complete all final Clinical Documentation within the standard documentation timeframe. Whether transition and hand-off time is compensated is determined by the Business Terms.

14. New and Additional Services (Opt-In)

UNIVERSAL, applies to all Providers.

From time to time the Company may add service lines or programs to the Platform. Provider is not obligated to perform any service outside the scope of Provider's licensure, competence, or the Services Provider has agreed to perform. The Company will offer additional Services on an opt-in basis; Provider may elect to perform a new Service by accepting it in writing (including through the Platform), at which point the corresponding universal and license-specific Policies apply. The Company will provide reasonable notice and any required supplemental training before a new Service becomes available to Provider.

Provider Acknowledgment

By performing Services on the Platform, Provider acknowledges receipt of these Provider Policies and agrees to comply with the universal sections and the license-specific addenda applicable to Provider's license and elected Services, as updated from time to time in accordance with the Provider Agreement.