To provide employees with a means to communicate needs, concerns and/or any other problematic issue to the Chief Executive Officer (CEO) or the Compliance Officer as deemed necessary.
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 (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 and has established 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.
Fred Erlich, CEO, (518) 218-0000 ext #4317
Joe Morelli, Compliance Officer, (518) 867-8811
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 & insight – thus creating opportunity 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 voice mail or by mail.
- Living Resources
Attention: Joe Morelli
300 Washington Avenue Extension
Albany, New York 12203
- (518) 867-8811
It is important to understand that unless detailed information is provided, anonymous reporting may result with the Compliance Officer’s inability to follow- up in a thorough manner. The content of all reports made through an anonymous manner will still be reported to the CEO, who will assure that it remains confidential and anonymous. However, the identity of the caller will not be disclosed to anyone without the direct consent of the caller.
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.
Living Resources Corporation