Corporate Compliance Plan
JCCA complies with the requirements of New York Social Services Law Section 363-d and 18 N.Y.C.R.R. Part 521, as well as Section 6032 of the 2005 Federal Deficit Reduction Act, and seeks to prevent and detect any fraud, waste, or abuse in its operations. To this end, the Agency maintains a Corporate Compliance Plan (“Plan”), the elements of which are documented in this manual. JCCA strives to educate its workforce on fraud and abuse laws, including the importance of submitting accurate claims and reports to the Federal and State governments.
This Plan not only applies to the Agency’s Medicaid programs, but also covers broader compliance obligations throughout the Agency, from our hiring policies to the management of our finances. JCCA is committed to full compliance with all legal obligations, and to requiring high ethical conduct of all JCCA Representatives (as defined below in Section II.C).
This Plan has been approved by the JCCA Board of Directors, JCCA’s Quality Management and Compliance Committee and JCCA’s Compliance Officer. The Compliance Committee meets monthly to review compliance-related activities and issues. The Compliance Officer periodically reports to the Quality Management and Compliance Committee and to the Board. The Quality Improvement Department, meanwhile, keeps the entire board informed of its activities and findings at regular Board of Directors meetings. The Compliance Officer also prepares annual reports summarizing compliance efforts undertaken during the year and any changes identified as necessary for improving the Plan and Agency effectiveness. The Board of Directors reviews the annual report and gives direction to the Compliance Officer for any necessary actions.
JCCA has instituted various procedures, which are outlined in this Plan, to ensure compliance with Federal and State laws and to assist the Agency in preventing fraud, waste, and abuse in all its programs, including Federally-funded health care programs. To comply with the Deficit Reduction Act and to further the Agency’s Compliance Program, JCCA disseminates this Compliance Plan to all Employees and Agents. This is done to ensure that they are aware of relevant Federal and State laws, of their obligation to participate in the Compliance Program, and that submission of a false claim can result in significant administrative, civil, and criminal penalties under the Federal False Claims Act and other State laws. The policies and procedures listed below were established according to local, state, and federal laws, the regulations of government regulatory agencies, and professional and ethical standards and can be found in the Appendices:
- Background Checks Policy
- Client Confidentiality Policy
- Conflict of Interest Policy
- Documentation Policy Records
- Retention Policy
- Case Review Procedure
- Whistleblower Policy
- Ethical Fundraising Procedures
- Research Policies and Procedures
- Research Standards
- Non-Discrimination and Anti-Harassment Policy
- Nepotism Policy
- Vacancy Coverage Policy
- Charity Care and Transition Policy