IAHD’s Compliance Program guides the organization’s governing body, CEO, managers, clinicians, billing personnel and other employees in the efficient management and operation of an organization relative to its services and programs. The Compliance Program is to be used to augment and complement existing quality assurance and utilization review programs currently in place. It is incumbent upon IAHD’s corporate officers and managers to provide ethical leadership to the organization and to assure that adequate systems are in place to facilitate ethical and legal conduct. The Compliance Program also sends an important message to employees that while IAHD recognizes that mistakes will occur, employees have an affirmative, ethical duty to come forward and report erroneous or fraudulent conduct, so that it may be addressed.
All employees, contracted practitioners, volunteers, interns, members of the Board of Directors and vendors shall acknowledge that it is their responsibility to report any suspected instances of suspected or known noncompliance to their immediate supervisor, or the Compliance Officer Reports may be made anonymously without fear of retaliation or retribution. Failure to report known noncompliance or making reports which are not in good faith will be grounds for disciplinary action, up to and including termination. Reports related to harassment or other workplace-oriented issues will be referred to Human Resources.
The Compliance Officer also chairs IAHD’s Compliance Committee (the Committee). IAHD’s Compliance Committee membership has been formed at the direction of the Chief Executive Officer and IAHD’s Board of Directors. Membership of the committee is made up of the following:
- Chief Quality Enhancement Officer (Compliance Officer) - Chair
- Chief Operating Officer
- Chief Financial Officer
- Chief Innovation Officer
- Chief People Officer
- Director(s) of Residential Services
- Director of Adult Day Services
- Director of Clinical Supports
- Director of Finance
- Director of Workforce Development
- Compliance Manager
- Board of Directors Compliance Liaison
The Committee meets bi-monthly, but may meet more often, as needed. Contact information for all Compliance Committee members can be found by contacting the Chief Quality Enhancement Officer.
This Compliance Program is a critical element to implementing an effective compliance program as required by the federal Office of the Inspector General and New York State Office of the Medicaid Inspector General.
It is IAHD’s policy to comply with all applicable federal, state and local laws and regulations and payer requirements. It is also IAHD’s policy to adhere to the Code of Conduct that is adopted by the Board of Directors, the Chief Executive Officer and the Compliance Committee. The “Code of Conduct” describes the behaviors and practices that are expected by those who work at, or for, IAHD. The Corporate Compliance Program operationalizes these expectations. It provides the practices, rules and laws related to each expectation, as well as a description of how an instance of failure to comply, both suspected and actual, is identified, managed, investigated and corrected.
At the core of IAHD’s Compliance Program is the expectation that all employees, board members, vendors and associates follow all applicable laws, rules and regulations. All internal policies and protocols must also be adhered to by all parties. Transparency is paramount to our agency’s successes. IAHD respects the dignity of all persons and expects that others also demonstrate that level of respect toward others. This is accomplished by the following actions:
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Expecting honesty, trust and fair dealing in our relationships with others.
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Creating a professional atmosphere.
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IAHD has an intolerance of any actions which discriminate against anyone, or that diminishes their dignity.
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Fostering an environment in which inappropriate or unlawful behavior is addressed swiftly and effectively.
The Chief Quality Enhancement Officer is Elizabeth K. Matthews and is appointed the Compliance Officer for IAHD. This position has a direct line of communication to the Chief Executive Officer, Board of Directors and IAHD Counsel. The Compliance officer is responsible for investigating, or delegating the investigation of, any concerns or issues reported pertaining to inappropriate practices, in violation of statutes, regulations and/or IAHD policies. The Compliance officer is also responsible for ensuring all “affected individuals” receive training and information on how concerns may be reported.
The Compliance Officer is also responsible for, but not limited to, performing risk assessments to identify any areas of concern pertaining to compliance related matters, and to remedy any deficiencies detected.
IAHD is committed to complying with all federal and state requirements for education and training Compliance training is conducted during orientation for all new employees and within three months of appointing new board members.
On an annual basis, all employees are trained on Corporate Compliance through our online learning management system, Relias, with pre and post testing to measure comprehension. Completion of training is a condition of continued employment. For those whose responsibilities will include billing, the appropriate supervisor will provide more targeted, detailed billing training.
Members of the Board of Directors and volunteers receive in person training on an annual basis, with a pre and post test to measure comprehension of the materials.
The Compliance Officer, Elizabeth Matthews, may be contacted at:
- Direct Telephone: 914-220-4383
- Email: EMatthews@iahdny.org
Reports may be made anonymously and are kept confidential, to the fullest extent possible, and a report made in good faith will be protected from retaliation or intimidation, in accordance with the law and the IAHD Whistleblower policy.
The follow methods allow for anonymous reporting:
- Compliance Hotline: 914-220-4397
- Written notification, in form of an anonymous letter, to the Compliance Officer:
Elizabeth K. Mathews, Compliance Officer
IAHD
32 Warren Avenue, 3rd Floor
Tarrytown, NY 10591
All reports and communications received will be deemed confidential and privileged. Upon receipt, the communication will be reviewed, and appropriate investigatory steps will be decided by the Compliance Officer, in conjunction with other appropriate individuals. The cooperation of the reporting individual may be sought during any investigation.
Conversely, the failure to cooperate with IAHD will be considered unacceptable. Upon conclusion of the investigation, the Compliance Officer will make a recommendation to the appropriate parties for necessary follow-up action to be taken.
Possible consequences of any evidence of non-compliance or false reporting may result in disciplinary action up to and including termination for employees, removal from the Board of Directors, or cancellation of agreements or contracts with vendors. Reports of intimidating, harassment or retaliation against any person(s) reporting a concern in good faith, will also be considered unacceptable and appropriate measures will be taken.
The Compliance Officer, or designee, will conduct periodic audits in accordance with all laws and regulations. The Compliance Officer, or designee, shall investigate all complaints of non-compliance. Based upon the results of audits and investigations for any uncovered infraction, progressive discipline will be implemented.
Ongoing evaluation is critical in detecting non-compliance and will help ensure the success of IAHD’s Compliance Program. An ongoing auditing and monitoring system is an integral component of our auditing and monitoring systems.
When assessing payments made to IAHD for services rendered, the following steps are taken:
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Track and analyze any overpayments, underpayments and denials (See “60-day Rule); determine if self-disclosure to OMIG is necessary or required. Tracking is shared with the Committee
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Share results of accounts receivable internal audits with the Committee
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Conduct tracer audit for payments to assess accuracy of billing and resulting payments
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Determine if billing and payment weaknesses are being identified and corrected as necessary.
In addition, when an overpayment is identified, an analysis is generally conducted to determine the cause, and to address and correct any issues contributing to the overpayment. Corrective measures may be chosen as part of the Compliance Work Plan for ongoing oversight by the Committee to assure ongoing improvement.
All licensed health care professionals providing individual care services must be fully capable of providing clinical responsibilities, with the mandatory education, licensure, and experience to do so known as “credentialing.”
On a monthly basis, IAHD checks all employees, vendors, and Board Members against the General Services Administration (GSA) Excluded Parties List System (EPLS), OIG List of Excluded Individuals/Entities (LEIE), OIG Most Wanted, Specially Designated Nationals, Office of Foreign Assets Control (SDN-OFAC), and the NYS OMIG Exclusion list.
The Compliance Officer, or designee, will conduct periodic audits in accordance with all laws and regulations. The Compliance Officer, or designee, shall investigate all complaints of non-compliance. Based upon the results of audits and investigations for any uncovered infraction, progressive discipline will be implemented.
In addition, when an overpayment is identified, an analysis is generally conducted to determine the cause, and to address and correct any issues contributing to the overpayment. Corrective measures may be chosen as part of the Compliance Work Plan for ongoing oversight by the Committee to assure ongoing improvement.
When a determination is made that a compliance violation has occurred, the Compliance Officer will notify the CEO, if the violation involves an employee, the Board Chair if the violation involves a board member, and for independent contractors, the Director of the program or department currently contracting with the provider.
All concerns or reports of non-compliance brought to the Compliance Officer will be thoroughly investigated with in 30 days of the complaint. Results of the investigation will be shared with the Committee, as well as the appropriate administrative or program department involved in the alleged incident of non-compliance. Recommendations may be made as a result of the investigative findings, either by the investigator or the Committee. Corrective actions will be reviewed by the Committee.
IAHD has enacted a policy protecting all employees, board members or volunteers from retaliation or intimidation when reporting potential violation of laws, regulations or agency policy, if the report is made in good faith. These concerns may be reported directly to a supervisor or manager, the Compliance Officer, or anonymously using the Compliance hotline.
- CORPORATE COMPLIANCE OFFICER: Elizabeth K. Matthews, (914) 220-4383 or ematthews@iahdny.org
- CHIEF EXECUTIVE OFFICER: Omayra Andino, (914) 220-4333 or oandino@iahdny.org
- ANONYMOUS REPORTING HOTLINE: (914) 220-4397
- MAILING ADDRESS:
IAHD
Compliance Officer
32 Warren Avenue, 3rd Floor
Tarrytown, NY 10591