As a not-for-profit health and human services organization dedicated to improving the everyday lives of people with intellectual and other disabilities, Arc GLOW is committed to complying with the rules and regulations of federal, state and local government, including but not limited to those promulgated by the U.S. Centers for Medicare and Medicaid Services (“CMS”), NYS Office of Medicaid Inspector General (OMIG) and the New York State Office for People With Developmental Disabilities (OPWDD). Arc GLOW seeks to provide a work environment where high standards of ethical and legal behavior are recognized and practiced.
Because Medicaid funding makes up a significant portion of Arc GLOW’s operating budget, we are under ongoing scrutiny to ensure that our services are appropriate, timely and properly reimbursed. As Medicaid providers, we are subject to the federal and state laws that govern this program.
In developing this Corporate Compliance Plan, we have relied upon a number of resources including The Arc New York’s Corporate Compliance Plan and numerous government issuances. In summary, in order to demonstrate that we have developed an effective compliance program, we must demonstrate that we have (1) developed standards and procedures in order to reduce the prospect of improper conduct; (2) designated a high-level individual to oversee compliance; (3) not delegated authority to individuals who have exhibited a propensity for misconduct; (4) taken steps to communicate the standards to our employees and agents; (5) engaged in auditing and monitoring activities and established a reporting system in which employees can report potential misconduct without fear of retribution; (6) taken appropriate disciplinary measures against individuals found to have violated the Corporate Compliance Plan or related policies and procedures; (7) taken reasonable steps to respond and prevent future violations; and (8) ensure a culture of non-intimidation and non-retaliation in regards to reporting compliance issues.
The Corporate Compliance Plan was instituted by the Board of Directors on June 26, 2002, with updates and Board of Directors’ approval on an annual basis. Our Corporate Compliance Plan also supports and complies with The Arc New York Board of Governors’ policy requiring that each chapter of NYSARC, Inc. implement an effective Corporate Compliance program.
Arc GLOW developed this Corporate Compliance Plan, including our Code of Conduct and a wide array of policies and procedures that address key risk areas, to guide our best efforts to operate under ethical and legal standards. Arc GLOW expects that all aspects of customer care and business conduct will be performed in compliance with this Corporate Compliance Plan, professional standards, and applicable governmental laws, rules and regulations. The plan is applicable to all employees, volunteers, students, interns, and Board of Directors members, as well as independent contractors (e.g., vendor, consultant, agent/appointee) that contribute to Arc GLOW’s entitlement to payment under the Medical Assistance Program (affected individuals).
A complete list of policies is available in the Corporate Compliance Plan Table of Contents and with Element I below. The content of these policies covers all elements of this compliance plan and gives further guidance for implementing our compliance program.