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Corporate Compliance

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A

Employee Handbook

The handbook given to each employee sets out several types of conduct, which are unacceptable.

These are:

  • Intentionally or knowingly making false or erroneous entries on reports, patient charts or other agency records
  • Dishonesty
  • Unauthorized alteration or destruction of agency records including patients’ charts
  • Coding or billing which violates Medicaid rules or regulations or other federal rules or regulations
  • Behavior detrimental to the operation
  • Other unacceptable conduct may be found in the handbook.
B

Conflict of Interest

Employees are expected to act with honesty, fairness, and in the best interest of the agency at all times. Any situation that may create a conflict of interest—such as outside business involvement, accepting gifts or gratuities, or using agency resources for personal use—must be avoided.
If there is any uncertainty regarding a potential conflict, employees should seek guidance from the Human Resources Department.
All Board members, management, office staff, and nursing personnel are required to sign a Conflict of Interest Statement. These statements are maintained on file, and all applicable individuals must disclose any actual or potential conflicts.
C

Confidentiality of Information

A patient’s health care record is the property of the agency and shall be maintained to serve the patient, necessary health care providers, the institution and third party payers such as Medicaid in accordance with legal, accrediting and regulatory agency requirements. The information contained in the health care record belongs to the patient and the patient is entitled to the protection of that information. All patient care information is regarded as confidential and available only to authorized users such as treating or consulting physicians and employees who may be providing patient care and to third party payers in order to facilitate reimbursement. The operations, activities, business affairs and finances of the agency should also be kept confidential and discussed or made available only to authorized users.

D

Workplace Administrative Searches

To maintain a safe, secure, and efficient work environment, the agency reserves the right to conduct unannounced administrative searches of its premises, offices, work areas, and equipment.
Employees should not expect privacy when using agency property, including desks, lockers, cabinets, computers, or other workspaces. Personal items of a sensitive nature should not be brought into the workplace.
The agency also reserves the right to monitor and access computers, email, and internet usage. All use of agency technology must be appropriate and work-related.
For full details, employees may request a copy of this policy from the Human Resources Department.
E

Fraud and Abuse

Employees shall refrain from conduct, which may violate the fraud and abuse laws. These laws prohibit (1) direct, indirect or disguised payments in exchange for the referral or patients; (2) the submission of false, fraudulent or misleading claims to any government entity or third party payer, including claims for services not rendered, claims which characterize the service differently than the service actually rendered or claims which do not otherwise comply with applicable program or contractual requirements; and (3) making false representations to any person or entity in order to gain or retain participation in a program or to obtain payment or excessive payment for any service.

F

Business Ethics

Employees must accurately and honestly represent the agency and should not engage in any activity or scheme intended to defraud anyone of money, property or honest services

G

Financial Reporting

All financial reports, accounting records, research reports, expense accounts, time sheets and other documents must accurately and clearly represent the relevant facts or the true nature of a transaction. Improper or fraudulent accounting, documentation or financial reporting is not only contrary to agency policy, it may be in violation of applicable laws. Sufficient and competent evidential matter or documentation shall support all cost reports.

H

Protection Of Assets

The agency will make available to employees assets and equipment necessary to conduct agency business including such items as computer hardware and software, billing and medical records, both hardcopy and in electronic format, fax machines, office supplies. Employees should strive to use agency assets in a prudent and effective manner. The agency property should not be used for personal reasons or be removed from the agency without approval from a departmental manager

I

Anti-Competitive Conduct

The agency will not engage in anticompetitive conduct that could produce an unreasonable restraint of trade of a substantial lessening of competition. Evaluation of anti-competitive conduct requires legal guidance. Communication by employees with competitors about matters that could be perceived to have the effect of lessening competition or could be considered as collusion or an attempt to fix prices should take place only after consultation with legal counsel.

J

Credit Balance

The agency encourages employees to report concerns or suspected misconduct in good faith without fear of retaliation. Any form of retaliation, retribution, or harassment against an individual who reports a concern is strictly prohibited and may result in disciplinary action, up to and including termination.
All reported concerns will be reviewed by the Compliance Officer in coordination with Human Resources and Legal, with appropriate action taken as needed.
Employees are expected to report concerns honestly and promptly. While self-reporting does not exempt individuals from accountability, it is viewed as a responsible and constructive action.
The agency remains committed to upholding its Standards of Conduct and complying with all federal and state regulations, including the timely reporting and refunding of any credit balances or overpayments.
K

Additional Standards

The agency maintains comprehensive policies and procedures to guide employees in performing their responsibilities with honesty, integrity, and compliance with applicable laws and regulations. These Standards apply to all employees, including leadership, temporary staff, contractors, and others conducting business with the agency.
Employees are responsible for following all applicable policies, procedures, and regulatory requirements, including accurate coding, billing, and claims submission practices. Questions regarding compliance or the interpretation of any policy should be directed to a supervisor, department leader, or Compliance Officer.
The Compliance Program and related standards are reviewed and updated as needed to reflect changes in laws and regulations. Failure to comply with these standards may result in disciplinary action, up to and including termination, as well as potential legal consequences.
Supervisors are responsible for ensuring employees receive appropriate training and understand their compliance responsibilities.
L

False Claims Act

The Federal and New York State False Claims Acts prohibit individuals and organizations from knowingly submitting false or fraudulent claims, making false statements, or misrepresenting information to obtain payment from government healthcare programs, including Medicare and Medicaid.
Violations may result in significant penalties, including financial fines, repayment obligations, exclusion from government healthcare programs, and potential criminal consequences.
The agency is committed to accurate billing, documentation, and compliance with all applicable laws and regulations. Employees are required to report suspected fraud, waste, or abuse in good faith and are protected under the agency’s Non-Retaliation and Non-Retribution Policy.
Individuals who report concerns may be protected from retaliation and may be eligible for certain legal protections and rewards under applicable False Claims Act provisions.

                         

                         Procedure

A signed statement from Governing Body/Management members to assure compliance with privacy of company policies

The Board of Directors will review relationships with other agencies, organizations, educational organizations, health care providers and payers, in order to ensure that those relationships comply with local, state and federal regulations, as well as promote the Agency’s mission and philosophy

The Board Members and staff upon hire will sign the Conflict of Interest form attached, during orientation. Forms are filed in the administrative office

The Agency has coordinated it’s Conflict of Interest Statement with company attorney and financial officers for legality and appropriateness

Conflict of Interest includes:

Double billing

Patient’s referral to agency you also work for

Kickbacks

                         

                          Purpose

To ensure no conflict of interest. The Agency defines “conflict of interest” as those activities or actions which:

Conflict with the mission, philosophy of objection of the Agency

Violate local, state or federal regulations

Place the Agency, personnel, clients or their families at risk ethically, financially or legally

To protect the Agency’s assets, both material, concepts and publications

Confidentiality of patient diagnosis

Financial matters

Staff salaries

Nursing or executive plans that can go to unauthorized agencies

Anything given to staff (e.g. forms, systems, equipment) that go to unauthorized people

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