The Corporate Compliance Program enhances Prospect’s strong commitment to providing the highest quality of care and service by creating a work environment that emphasizes ethical, legal and prudent practices. Although it is recognized that no code of conduct or compliance plan can substitute for a person’s own internal sense of fairness, honesty and integrity, Prospect Child & Family Center provides guidance and education to all parties involved to promote ethical behavior and reduce the likelihood of abuse, fraud and health care violations.
What is Abuse and Fraud?
Abuse is provider practices that are inconsistent with sound fiscal, business or medical practices that result in an unnecessary cost to the Medicaid program, in reimbursement for services that are not medically necessary, or that fail to meet professionally recognized standards for health care. Consistent/repetitive errors or improper behavior also constitute abuse.
Fraud is defined as intentional deception or misrepresentation made by a person with the knowledge that the deception could result in some unauthorized benefit to himself or some other person. Fraud occurs when a person participates in, knows or suspects but fails to report, and/or facilitates or encourages non-compliant behavior.
What is My Duty Regarding the Compliance Program?
All persons associated with the Center are responsible for understanding and complying with Agency’s compliance program, meeting all regulatory requirements, and reporting all known or suspected violations of abuse or fraud.
How Do I Identify Compliance Issues?
Examples of compliance violations that would need to be reported include, but are not limited to, the following:
- Inappropriately revealing or using confidential information regarding Agency employees or clients.
- Billing for services not provided for or for more time than was actually provided.
- Being unlicensed and performing services that only a licensed professional should render.
- Falsifying client, employee or financial documentation.
- Unauthorized financial transactions involving Agency or consumer funds.
- Accepting a bribe from a vendor or contractor.
How Do I Report an Issue?
Compliance concerns can be reported to the Agency’s Compliance Officer, Kathy Bee (518-798-0170) OR by calling our outside anonymous hotline number (1-866-219-1122). If you would prefer to submit a written report, please include the following information:
All written concerns should be addressed to the Compliance Officer, placed in a sealed envelope marked “PERSONAL”, and mailed to: 133 Aviation Road, Queensbury, NY 12804.
Non-Intimidation / Non-Retaliation Policy
Prospect Child & Family Center strives to create an environment that encourages confidence in raising, questioning and acting upon a person’s concerns. Therefore, the Agency has a non-intimidation, non-retaliation policy which assures protection if a person comes forward with a compliance issue, as long as the report is made in “good faith”. Prospect Child & Family Center will not tolerate any complaints made maliciously or falsely against another individual. Please note that this policy does not protect people who whistleblow on themselves.
How Will the Center Respond?
The action taken by the Agency will depend on the nature of the concern; however, all concerns will be taken seriously and addressed appropriately. The Agency will investigate all suspected or known compliance matters. If a violation is found, appropriate action will be taken to include pslan to immediately correct the issue, as well as to prevent a recurrence. Fraudulent behavior will lead to immediate action, up to and including referral to the appropriate law enforcement agency and/or NYS Medicaid Inspector General’s office.
Auditing and Monitoring
The Agency conducts self-evaluations and audits of client, employee and billing records in order to prevent and/or detect compliance issues. Any issues found are corrected, a plan is put into place to prevent a recurrence, and any overpayments are promptly refunded.
False Claims Act
The False Claims Act prohibits knowingly presenting (or causing to be presented) to the government a false or fraudulent claim for payment or approval. It also allows private citizens with knowledge of potential violations to file their own personal lawsuits of fraud, abuse or waste on behalf of the government with potential proceeds coming to them if the lawsuit finds in the government’s favor. ‘Whistleblowers’ are protected against discharge, demotion, suspension, threat, harassment, or other discrimination with regard to their employment as a result of their furtherance of an action under this Act. For further information on the Federal and State False Claims Act, visit the NYS Medicaid Inspector General’s website at www.omig.state.ny.us.
Compliance Officer: Kathy R. Bee
E-mail: kbee.pcfc@roadrunner.com
Prospect Child & Family Center, 133 Aviation Road, Queensbury, NY 12804
Phone: (518) 798-0170
Hotline: 1-866-219-1122