Definition of Noncompliance
Noncompliance to HIPPA or the Corporate Compliance Plan has the potential to take many forms. The following list provides several examples of noncompliance, but it is not to be considered an all-inclusive list:
Falsifying information on verbal or written reports.
Signing for a service that was not provided.
Falsifying a signature on any documentation.
Removal of official documents from its’ home file without authorization.
Clocking In or Out for another employee.
Missing and/or potential loss of Consumer funds.
Providing confidential information to unauthorized persons.
Destroying documents without permission.
Failure to report witnessed noncompliance.
Procedures to Report Noncompliance
Living Resources has extended much effort into establishing a very successful “open-door” policy whereby any employee, at any level of the organization, may attain easy, direct access to the CEO. In fact the CEO, Fred Erlich, expends a great deal of time and energy toward assuring staff members of his availability and desire to communicate in an informal, yet effective manner.
To this end, Living Resources continues to encourage all employees to report any needs or concerns related to the agency’s operations directly to the CEO. In addition, the agency’s Compliance Officer, Joe Morelli is also available to receive and investigate any reports made by an employee.
Employees of Living Resources can be well assured that there will be no reprisal or retaliation of any kind when presenting problematic situations to the CEO or any other member of the administrative or management team. It has been the philosophy of the agency and its leadership to encourage the presentation of problems in order that the agency may gain knowledge and insight – thus creating opportunities to make improvements that will lead to better quality care of our consumers.
For those employees who feel it necessary to remain anonymous when reporting problematic situations, they are welcome to contact the Compliance Officer, Joe Morelli by telephone voicemail or by mail.
Attention: Joe Morelli
300 Washington Avenue Extension
Albany, New York 12203
Reporting of Misconduct
When the Compliance Officer, Compliance Committee, or an administrative staff member discovers credible evidence of misconduct from any source and, after a reasonable inquiry, has reason to believe that the misconduct may violate criminal, civil, or administrative law, Living Resources will promptly report the existence of misconduct to the appropriate Federal, State, or local authorities. Such a report, as validated, will be made within a reasonable time period, but not more than 60 days.
Some of the Federal & State authorities include:
U.S. Office of Inspector General (OIG)
U.S. Criminal & Civil Divisions of the Department of Justice
U.S. Attorney General
U.S. Federal Bureau of Investigation (FBI)
Office for People with Developmental Disabilities
New York State Medicaid Fraud Control
New York State Department of Health
County District Attorney
Any questions, concerns, interest or general comment to this policy or any policy related to corporate compliance can be presented to Joe Morelli, the agency’s Corporate Compliance Officer.