Written Policies and Procedure Code of Conduct and Ethics POLICY NO.: 001 DATE ISSUED: January 1, 2013 PROCEDURE: The SDM maintains a Compliance Plan and Code of The Compliance Plan is reviewed and updated on a routine basis by the Compliance Officer and Compliance Committee every time an issue is identified or a Bulletin/Alert is issued by NY OMIG or the OIG. The SDM Governing Board is driving the Compliance Program. The Compliance Plan and Code of Conduct is reviewed and approved by the Board of Directors on an annual basis. The requirements of the compliance plan and Code of Conduct are communicated throughout the SDM during annual trainings and when necessary.
Designation of Compliance Officer POLICY NO.: 002 DATE ISSUED: January 1, 2013 PROCEDURE: The SDM has designated a Compliance Officer to oversee the compliance program. The Compliance Officer in conjunction with the Compliance Committee, address each of the required elements through audits, training, reporting, investigations and communication.
Training and Education POLICY NO.: 003 DATE ISSUED: January 1, 2013 PROCEDURE: Compliance training is provided to all new hires during orientation and compliance information is included in the employee handbook. Compliance training is provided annually to the Governing Board, Management and staff.
Communication POLICY NO.: 004 DATE ISSUED: January 1, 2013 PROCEDURE: A confidential hotline number is provided for complaints or reporting of suspected compliance issues. Individuals making a report may remain anonymous. The hotline poster includes the SDM hotline number as well as the hotline numbers for the OIG and OMIG. Suspected compliance issues can be reported internally through management or the Compliance Officer.
Disciplinary Policies POLICY NO.: 005 DATE ISSUED: January 1, 2013 PROCEDURE: Consistent compliance discipline policies are in place and apply to all staff and management. The discipline varies according to the level of severity of the compliance violation.
Identification of Risk Areas and Noncompliance POLICY NO.: 006 DATE ISSUED: January 1, 2013 PROCEDURE: When risk areas are discovered or identified, they are required to be reported to management and/or the Compliance Officer. Risk areas will be discovered through the audit process. All issues are documented by the Compliance Officer including the details, outcome and corrective action plan. Risk is prioritized and scheduled for frequent monitoring with high risk areas having a more urgent schedule and lower risk areas having a more routine schedule until such a time measurement results in success.
Response to Compliance Issues POLICY NO.: 007 DATE ISSUED: January 1, 2013 compliance requirements for all providers. Effective Compliance Programs per NY OIG contain 8 PROCEDURE: All reported issues will be responded to timely and documented. The issue will be identified and investigated to identify who is involved and obtain the details of the compliance issue. The issues identified are addressed with a corrective action plan and are monitored accordingly to ensure the corrective action is successful. Significant risk areas may become a self-report to an appropriate agency at which time the Governing Board and SUNY Legal will immediately be notified and briefed. The self- report will be made timely.
Policy of Non-intimidation and Non-retaliation POLICY NO.: 008 DATE ISSUED: January 1, 2013 SCOPE: All staff member, employees, management and volunteers are expected to adhere to this policy and procedure. PROCEDURE: The SDM encourages reporting of suspected non-compliance issues to management and/or Compliance Officer. At no time will intimidation or retaliation be tolerated, especially towards anyone who has come forward to make the SDM aware of a suspected compliance issue, fraud, waste or abuse. Intimidation and retaliation will result in discipline which may include discharge from employment.