Corporate Compliance

This summary is an adjunct to Cerebral Palsy of Westchester’s (CPW’s) full Corporate Compliance Plan. It is expected that all employees, executives, board members and other individuals associated with CPW (hereafter referred to as “Affected Individuals“) will have read the full Corporate Compliance Plan in its entirety.

Adherence to the Corporate Compliance Plan is a condition of employment. CPW’s business affiliates are also required to comply with the Corporate Compliance Plan.

To underscore CPW’s commitment to a strong and ethical corporate culture, CPW established a Corporate Compliance Program which encompasses the “Seven Elements of an Effective Compliance Program,” as identified by the New York State Office of the Medicaid Inspector General (“OMIG”).

Seven Elements

1. Written Policies and Procedures, and Standards of Conduct: CPW is required to develop written Corporate Compliance policies and procedures which correspond to its Standards of Conduct. These policies are reviewed at least annually, and revised if necessary. They are provided to all new hires at orientation. A copy of CPW’s Corporate Compliance Plan is available upon request, and at the link above.

CPW is committed to maintaining high quality care and services as well as integrity in its financial and business operations. Therefore, and in accordance with state regulation, CPW will conduct monthly exclusion checks of Affected Individuals, to determine if they have been sanctioned by a Federal or State law enforcement, regulatory or licensing agency.

2. Designation of Corporate Compliance Officer and Compliance Committee: The Corporate Compliance Officer has a direct line to the Executive Director and the Board of Directors. The Corporate Compliance Officer oversees the Corporate Compliance Program, supervises and conducts training and educational programs, oversees and writes the policies and procedures related to compliance, and audits programs and departments for compliance. In addition, the Corporate Compliance Officer is responsible for the handling of all complaints or allegations of fraud, waste or abuse (whistleblowing) made under the Corporate Compliance Program.

The Corporate Compliance Officer for CPW is Lisa Fisher-Wheatley, who may be contacted at: lisa.fisher@cpwestchester.org / (914) 937-3800 Ext 721.

The Compliance Committee meets quarterly, and is responsible for oversight of CPW’s Compliance Program.

3. Training and Education: New hires receive training related to CPW’s Corporate Compliance Program during orientation. All Affected Individuals will receive mandatory compliance training on an annual basis.

4. Lines of Communication:  All Affected Individuals have an affirmative duty and responsibility to report any known or suspected misconduct related to the Corporate Compliance Program, including possible violations of the Standards of Conduct. CPW maintains an “open door” policy to encourage the reporting of any problems or concerns. CPW also maintains a Compliance Hotline where any Affected Individual can report their compliance concerns to the Corporate Compliance Officer by leaving a voice message. The telephone number for the Compliance Hotline is (914) 937-3800 Ext. 210. Information may be offered anonymously over the hotline. For more ways to report, please see the Compliance Plan or Standards of Conduct.

• Policy of Non-Retaliation for Good Faith Reporting: Whistleblowers are protected. In accordance with CPW’s policies and procedures, all Affected Individuals are strictly prohibited from engaging in any act or conduct which results in, or is intended to result in, retaliation or retribution against any individual who reports a possible violation of the Corporate Compliance Standards of Conduct.

5. Enforcement and Disciplinary Policies: CPW applies progressive discipline that is consistent with the severity of the compliance violation. Such discipline can include either suspension or termination.

6. Routine Monitoring and Auditing: Conducted by the Corporate Compliance Officer to identify and monitor areas of risk. Findings from such audits are reported to the Compliance Committee, Executive Director, and the Board of Directors.

7. Responding to Compliance Issues: Compliance issues are discovered through reporting, auditing and monitoring. An investigative process may follow, in accordance with CPW’s ‘Investigation of Compliance Issues’ policy. Once a violation of the Standards of Conduct is substantiated through the investigative process, CPW shall (1) initiate immediate corrective action, which may include prompt restitution of any overpayment amount, notifying the appropriate governmental agency, and the institution of proper disciplinary action if warranted; and (2) implement systemic changes to prevent a reoccurrence of a similar violation in the future.