POLICY NO.: 135
POLICY: It is the policy of Community Connections, Inc. to ensure that all representatives of Community Connections, Inc. are aware of the organization’s mandate to conduct all services and business activities with the highest level of integrity and ethical standards.
PURPOSE: To detect and prevent Medicaid fraud, waste and abuse or other criminal activity by representatives of Community Connections, Inc.
PERSON(S) RESPONSIBLE: President/CEO, Board of Directors, designee(s) as assigned by President/CEO, Leadership Management Team
Date Reviewed: 10/13, 3/15, 10/16, 1/17
Community Connection, Inc.’s President & CEO, or designee serves as the Corporate Compliance Officer for the agency’s Compliance Committee and is responsible for the oversight and implementation of activities relating to the agency’s compliance. These activities can include, but are not limited to: running committee meetings, initiating internal audits and investigations, designating persons responsible for committee activities, trainings, etc.
The above-stated Compliance Committee will consist of the agency’s Leadership team and others, as designated. This committee shall meet bi-annually but can be convened in conjunction with the identification of a compliance violation.
The Corporate Compliance Officer is the only person authorized to schedule or call a Compliance Committee meeting. If the Corporate Compliance Officer is unavailable, the appropriate Vice President will establish the agenda and call a Committee meeting.
The Committee’s responsibilities include:
• Assessing existing agency policies and procedures to ensure that changes in legal and regulatory requirements are being addressed
• Developing standards of conduct, policies and procedures
• Determining the appropriate strategy/approach to promote compliance throughout the organization
• Developing a system to solicit, evaluate and respond to complaints and problems
• Developing and monitoring internal and external audits and investigations for the purpose of identifying troublesome issues and deficient areas
• Assisting in the investigation(s) of alleged compliance violations and implementing corrective prevention plans
• Developing appropriate changes to operational procedures to eliminate reoccurrences of any violations.
Meeting summaries will be created to help document corporate compliance activities and will be provided to each member of the committee.
Process for reporting a potential compliance violation
• A report of a potential compliance violation should be submitted to an employee’s immediate supervisor by either: a) direct telephone call, b) personal meeting or c) e-mail. If for any reason the employee finds it difficult to report their concern to their supervisor, the employee can report it directly to the Vice President of Human Resources or designee. Compliance violations can include but are not limited to: misrepresentation of services, duplicate billing, improper coding, over-billing and false claims/statements.
• This policy assumes that employees will act in good faith and will not make false accusations. An employee who knowingly makes false statements or disclosures that are not in good faith may be subject to disciplinary action up to termination.
Supervisors response to a complaint
Community Connections, Inc. maintains a working environment where employees, volunteers, interns or other agency stakeholders can report any suspected fraud, waste or abuse without fear of retaliation. Please refer to policy #124 Reporting Suspected Fraud, Waste or Abuse.
• Upon receipt of a complaint, the supervisor will report it to the Vice President of Human Resources, who will, in turn, report the incident to the President.
• The Vice President of Human Resources will investigate within five business days of the receipt of the complaint. All person(s) designated to be involved in the investigation process shall have direct access to relevant agency information as needed. This information can include but is not limited to accounting documentation, legal counsel consultation, employee interviews, personnel files, agency policies, etc.
• The supervisor will not discuss the case with anyone except his or her supervisor or the Vice President of Human Resources, and will not contact the suspected person to conduct an investigation.
• A written report of the written report of the investigation will be submitted to the President and the Corporate Complaince Committee for review and, if necessary, corrective action.
• The final written report of the findings, significant compliance issues and recommended corrective actions will be submitted to the Board of Directors for review, input and/or approval (as appropriate).
• Following this Board review, the President/CEO will implement appropriate and timely action to correct any corporate compliance infraction. This action may include employee disciplinary action, suspension or termination.
Conflict of Interest, Ethics and Confidentiality
Due to the potentially sensitive nature of Committee activities (i.e.: employee discipline recommendations, etc) each Committee member will be held to the highest standard of confidentiality and will be expected to adhere to all agency privacy policies and procedures. All information discussed during Committee meetings will be considered confidential in nature. Policies for reference: Confidentiality and Case Records (#7) and WISP.
No employee of Community Connections will make any decision on behalf of the agency that would represent, result in or give the appearance of personal gain or benefit. In such cases, employees will discuss the situation with the President/CEO or designee prior to making any decision that would represent a commitment of the company’s assets, obligate the company in any way and/or have the potential to give the appearance of impropriety or conflict of interest. Policies for reference: Conflict of Interest (#83)
Community Connections, Inc. expects the highest level of ethical conduct from all employees and members of the Board of Directors. As such, the Board of Directors will act and operate in a manner consistent with Policy # 114, Board of Directors Code of Ethics. Similarly, employees, volunteers and interns will operate under the agency’s Code of Ethical Conduct.
Corporate Compliance Plan
All employees, volunteers, interns, Board members and other stakeholders are to adhere to Community Connections’ mission to provide the highest quality services and opportunities for people with disabilities and to operate within the agency’s core values of dignity, compassion, respect, family, innovation, commitment, achievement, quality, communication, teamwork, leadership, safety, collaboration, growth and fiscal responsibility.
As such, an agency Corporate Compliance Plan and Program has been developed and is available as a reference and guide to this process.