South East Consortium for Special Services, Inc.
The Corporate Compliance Program
The Corporate Compliance Program has been created to establish a set of business practices and principles which allow the South East Consortium to be in legal conformance with Federal Government guidelines for Medicaid reimbursement of programs and services. The South East Consortium defines corporate compliance as a long-term commitment to conduct business in a manner that promotes compliance with laws and regulations; that continually monitors itself for compliance and has created systems to allow the agency to respond to changes in the regulatory environment. All procedures will adhere to guidelines established by the New York State Office for People with Developmental Disabilities under Section 624 of New York State Regulations for service providers. These include rules pertaining to: eligibility, serious reportable incidents/reportable incidents, abuse prevention and confidentiality.
• Eligibility: This includes securing documentation to establish a participant's IQ score, relative psychological measurements, social security number, birth date, tab number, Medicaid number, DDP1 forms, Non-IRA forms and Individual Service Plans.
• Serious Reportable Incidents/Reportable Incidents: This ensures any such incident is reported with 24 hours as required under Section 624 of New York State Regulations. A follow up investigation will be done as soon as possible in an effort to prevent any similar issues for recurring.
SEC Incident Management Policy can be viewed here.
• Abuse Prevention: This includes staff training and supervision and program supervision to identify and report any form of abuse as defined in 14 NYCRR Part 624.4(b) 1-10 and mandated reporting requirements under Social Service Law Section 412.
• Confidentiality: This is defined in accordance with OPWDD Law 633.19, Federal and New York State Law and policies as mandated by the South East Consortium.
The Eight Elements of the South East Consortium Compliance Program:
1. Element I: Written Policies and Procedures
2. Element II: Program Structure and Oversight Responsibilities
3. Element Ill: Due Care in Assignment of Responsibilities/Background Checks
4. Element IV: Education and In-Service Training
5. Element V: Auditing and Reporting
6. Element VI: Disciplinary Action and Incentives
7. Element VII: Detection and Response
8. Code of Conduct
Additional Procedures Regarding Medicaid Compliance Practices:
1. Medicaid billing requires eligibility, registration and attendance recordkeeping. Procedures have been created to ensure accuracy, including recording of start/end times so billing will conform with the fulll/4 hour requirement. Each participant's hourly respite document will be signed within 48 hours of service delivery by the appropriate direct care employees. Recording procedures are designed to eliminate errors and are checked by a supervisor for accuracy. Submission on the secure billing website is monitored by the Executive Director and is carried out by qualified staff.
2. Billing for payments will be done after each full month for service is completed for each participant. Submission reports for each month will be printed and when payment is received will be filed.
3. All potential participants will undergo an in-take interview to evaluate and determine the participant's eligibility and the agency's ability to fulfill one's needs. Additional information and data will be requested if needed to assist in this determination.
4. The South East Consortium is a not-for-profit 501 ©(3) organization created specifically to provide therapeutic recreation programs and services to nine component municipalities comprising the consortium. The Board of Directors is responsible for establishing policy and governance mandates for the agency. The Executive Director and full time employees are responsible for the day-to day operation of the agency.
5. All South East Consortium employees are mandated reporters as defined by New York State and Westchester County. Each employee will be trained to recognize abuse as defined by OMWDD regulations.
6. All employees will receive appropriate training in the area of CPR, first-aid, adaptive programming and report writing to ensure a professional and effective approach to doing business.
7. In order to minimize risks and legal liability exposure, the South East Consortium will utilize a staffing ratio deemed appropriate based on the nature and scope of some of its programs.
This summary is an adjunct to the full Corporate Compliance Plan. It is expected that all employees, executives, board members and other individuals associated with South East Consortium will have read the full plan in its entirety.