HeartShare Mission and Compliance Commitment
HeartShare Human Services, HeartShare St. Vincent’s, HeartShare Education center, and HeartShare Wellness (hereafter referred to as “HeartShare”) is dedicated to fulfilling all legal and ethical obligations while delivering the highest quality care to enhance the health and well-being of our communities. We are committed to conducting our business in full compliance with all applicable laws, rules, regulations, and directives from federal, state, and local governments and agencies. Our goal is to uphold the highest standards of professionalism, with a strong focus on transparency and quality care.
To support this mission, HeartShare has implemented a comprehensive Compliance Program that establishes clear policies, procedures, and standards of conduct. This program is designed to guide all agents, subcontractors, independent contractors, officers, and corporate leaders (collectively referred to as “Affected Individuals”) in their responsibilities to HeartShare. We expect every Affected Individual to fully commit to the principles and practices outlined in our Compliance Program.
The Compliance Program is focused on identifying and addressing any instances of fraud, waste, or abuse within our organization. It encompasses continuous education and training for all Affected Individuals, the maintenance of effective prevention systems, and a robust response framework for handling claims of fraud, waste, and abuse.
Through this program, HeartShare demonstrates its strong commitment to the following:
- Ethical Conduct: Promoting honest and responsible behavior among providers.
- Quality of Care: Enhancing patient care by improving documentation practices.
- Accurate Billing: Minimizing billing errors to ensure proper claim payments.
- Compliance and Audits: Reducing the likelihood of negative audit outcomes.
- Legal Adherence: Minimizing the risk of violations related to state and federal laws, including anti-kickback statutes, self-referral laws, the Federal False Claims Act, the Program Fraud Civil Remedies Act, the New York False Claims Act, and New York Health Care Fraud laws.
- Integrity Culture: Fostering a culture of integrity and implementing reporting procedures that encourage Affected Individuals to report potential issues.
- Prompt Action: Detecting and reporting potential or actual violations swiftly, initiating immediate corrective actions to mitigate HeartShare’s exposure to administrative actions, civil damages, penalties, and criminal sanctions, and reducing government losses from overpayments.
Written Policies and Procedures (including by not limited to)
Compliance Program & Designated Officer
The Chief Compliance Officer is responsible for the day to day operations, implementing and ensuring the effectiveness of all components within the compliance program. The Chief Compliance Officer reports directly to the President and CEO and the governing body on compliance activities. The Compliance committee shall be comprised of employees from various entities and departments within the agency. The committee is responsible for coordinating with the Chief Compliance Officer to ensure that HeartShare is conducting its business in an ethical and responsible manner, consistent with its Compliance Program.
Compliance Training Program
The initial compliance training will be conducted during new hire orientation for all employees and within 30 days of appointment for Board members, with annual refresher sessions thereafter. The training will cover the Code of Conduct specific to individual roles and responsibilities, the Health Information Privacy and Accountability Act (HIPAA) Policy, Conflict of Interest, Compliance Reporting and Investigations, Non-Retaliation Policy, an introduction to the Compliance Officer and team, and details about the Anonymous Compliance Reporting Hotline. All other affected individuals will be informed about the compliance program through a notification letter and a website link.
Access to Compliance Team and Open Lines of Communication
HeartShare recognizes that open lines of communication are important to the successful implementation of its Compliance Program and its goals of reducing the potential for fraud, abuse, and waste. All Affected Individuals are required to communicate and report any suspected fraud or abuse or other violation of the Compliance Program. Reporting can be accomplished through a written statement or directly to a supervisor or the Chief Compliance Officer. In addition, compliance related concerns may be reported directly to the Chief Compliance Officer through a “Compliance Hotline” at (718) 422-3344 that has been set up for anonymous and confidential reporting.
- Hayley Cowitt, Chief Compliance Officer, (718)-422-4202, compliance@heartshare.org
- Anonymous Compliance Hotline – (718)-422-3344
Any concern may be raised anonymously, if the reporting individual so chooses, and will be held in the strictest confidence possible, consistent with the need to investigate any allegations of wrongdoing. To the extent possible, the Chief Compliance Officer or anyone else receiving a report will not reveal the identity of anyone who reports a suspected violation of the Law or who takes part in an investigation. There will be no retaliatory action taken against individuals who report compliance issues in good faith.
HeartShare strictly prohibits intimidation and retaliation in any form against an individual or entity who in good faith reports possible unethical or illegal conduct and/or who participates in the Compliance Program, including but not limited to, reporting and investigating potential issues, conducting self-evaluations, audits, and remedial actions, and reporting to appropriate officials. Any action of intimidation or retaliation is itself a serious violation of the Compliance Program.
Auditing and Monitoring
Routine auditing and monitoring of the compliance program will be conducted to ensure compliance and adherence to governing entities rules and regulations through the use of a compliance work plan. Compliance audits will be conducted by independent internal or external auditors and will be overseen by the Chief Compliance Officer. The compliance committee reviews and is informed of all governing body audits and monitoring activities.
Investigation and Corrective Action
HeartShare is committed to investigating all reported concerns promptly and confidentially to the extent possible. The Chief Compliance Officer and/or legal counsel may solicit the support of internal or external auditors, and internal and external resources as applicable. All persons and entities involved in an investigation shall function under the direction of the Chief Compliance Officer or legal counsel and shall be required to submit relevant evidence, notes, findings, and conclusions to either the Chief Compliance Officer or legal counsel. All resolutions and recommendations are transparent and reported to the compliance committee and Board of Directors.
Discipline and Corrective Action
All Affected Individuals are expected to adhere to HeartShare’s Compliance Program. If the recommendations to violations instituted by the Chief Compliance Officer are inadequate to a correct a pattern of non-compliance, and if the Chief Compliance Officer concludes that a violation of the Compliance Program has occurred, appropriate discipline and/or corrective action, including termination or exclusion from HeartShare may be imposed.
This page was last updated: 11.4.2024
