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Schoharie County ARC CORPORATE COMPLIANCE PLAN
As a not-for-profit health and human resources organization dedicated to improving the everyday lives of people with developmental disabilities, the Schoharie County ARC 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”) and the New York State Office for Mental Retardation and Developmental Disabilities (“OMRDD”). The Schoharie County ARC seeks to provide a work environment where high standards of ethical and legal behavior are recognized and practiced.
In developing this Corporate Compliance Plan, we have relied upon a number of resources including NYSARC’s Corporate Compliance Plan and numerous government issuances. To demonstrate that we have developed an effective compliance program, 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 auditory and monetary compliance 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; and (7) taken reasonable steps to respond and prevent future violations.
The Corporate Compliance Plan was instituted by the Board of Directors on February 25, 2003 and November 28, 2006. Our Corporate Compliance Plan also supports and complies with the NYSARC Board of Governors’ policy requiring that each chapter of NYSARC implement an effective Corporate Compliance Plan.
The Schoharie County ARC 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. It is expected that all aspects of consumer care and business conduct will be performed in compliance with this Corporate Compliance Plan, professional standards and applicable governmental laws, rules and regulations.
CONFLICT OF INTEREST POLICY
NYSARC, Inc., through its Chapter Staff, has a commitment to its members and the public at large, and strives to maintain the highest ethical standards in the delivery of programmatic services through the design, implementation and adherence to clearly articulated policies and procedures in an effort to avoid either the actual or appearance of improper or undisclosed conflicts of interest.
A Conflict of Interest may arise where or when an employee has both a duty to protect the Chapter’s interest(s) and/or those interests of individuals served by the Chapter and a simultaneous opportunity to realize a personal gain or benefit for themselves or a family member.
An impermissible conflict of interest is a conflict of interest where the Interested Person cannot place the interest of the organization or the interest of the individuals we serve ahead of their personal interests.
Reporting a Corporate Compliance Concern
Anyone may report their compliance concern(s) confidentially to the Schoharie County ARC’s Compliance Ethics Line. The Compliance Ethics telephone number is 518-295-8125. Callers to the Compliance Hotline may make reports anonymously.
If a caller has revealed his or her identity, confidentiality will be maintained to the extent practicable and allowed by law. Callers should be aware, however, that it may not be possible to preserve anonymity if they identify themselves, provide other information which identifies them, the investigation reveals their identity or they inform people that they have called the Compliance Ethics Line. Callers should also be aware that the Schoharie County ARC is legally required to report certain types of crimes or potential crimes and infractions to external governmental agencies.
Stephen Ramos, Corporate Compliance Officer
Ethics Line 518-295-8125
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