The YAI Network is committed to providing the highest quality services and conducting our business with honesty and integrity and in compliance with all applicable laws and regulations. We expect that the people who conduct business with our organization will support these efforts as well.
In accordance with the Deficit Reduction Act of 2005 (DRA) we provide our vendors and contractors with detailed information about the federal and state False Claim Acts and YAI’s policies regarding the prevention and detection of fraud, waste and abuse.
In order to facilitate your understanding of YAI’s Compliance and Ethics Program and our DRA compliance efforts we have posted the following materials which can be accessed using the links below.
We encourage you to familiarize yourself with these materials and ask for your cooperation in ensuring that this information is reviewed by, and made available to, your Compliance Officer or appropriate senior management in your organization.
If you have any questions about these materials or any concern about YAI’s business practices, please contact Marie Cavallo, Chief Quality, Compliance, & Ethics Officer, at 212.273.6241or Marie.Cavallo [at] yai.org. You may also report any concerns anonymously through YAI’s anonymous and confidential hotline at 212.273.6100, ext. 2527 or email compliance.hotline [at] yai.org.
YAI’s Code of Conduct
YAI is committed to complying with all federal and state laws and regulations and ensuring that its billing to the Medicare program, the New York State Medicaid program and any other federal and state health care programs is accurate and in full conformity with applicable laws. In furtherance of its commitment to promote the highest ethical standards, YAI has an active Compliance and Ethics Program. At the heart of this program is YAI’s written Code of Conduct, which sets forth its commitment to integrity and responsibility and provides compliance-related guidance to employees, vendors and contractors.
The federal False Claims Act, the federal Program Fraud Civil Remedies Act and certain other New York State laws can subject individuals and organizations to significant fines and penalties if they commit fraud against either the federal or the state government. Under the federal False Claims Act (31 U.S.C. §§ 3729-3733), false claims include knowingly submitting false or fraudulent claims to the government for payment, making or using a false record or statement in connection with the submission of such claims, or obtaining money from the government to which one is not entitled and then using false statements or records to retain the money.
This policy has been adopted to establish disciplinary procedures and protocols to ensure that employees and independent contractors of the agency adhere to the YAI Compliance Standards outlined in the policy. YAI has developed disciplinary procedures to enforce the agency’s commitment to these principles. In accordance with such procedures, YAI will discipline any individuals or organizations whose conduct violates any of YAI’s Compliance Standards.
YAI has established communication channels for employees, independent contractors, and officers of YAI to report problems and concerns. These individuals are encouraged to report issues via the traditional chain of command, their program supervisor, Human Resources, Compliance Hotline, or directly to the Chief Quality, Compliance, & Ethics Officer. Ultimately, all of such reports are to be communicated to the Chief Quality, Compliance, & Ethics Officer, who, in turn, is responsible for responding to the issues reported. This Policy is designed to establish a framework for responding to potential violations of the Compliance and Ethics Program and managing investigations with respect thereto. This Policy applies to all Agency employees and contractors who report compliance issues.
YAI has established a process to identify and address potential violations of law and compliance issues and to self-disclose to appropriate governmental agencies any events or issues that require the return of prior payments made by government agencies, such as Medicaid or Medicare, and other events or compliance issues listed in Section 4.3.1 of this Policy (“Reportable Events”). This Policy applies to all Agency employees or contractors who encounter billing or reimbursement issues that may require the return of Overpayments or who may encounter one or more Reportable Events (“Responsible Employees”).
YAI has established a compliance reporting process and a strict non-retaliation policy to protect employees and others who report problems and concerns in good faith from retaliation. Any form of retaliation or retribution can undermine the compliance resolution process and result in a failure of communication channels in the organization. This Policy applies to all Agency employees or contractors who have an affirmative duty to report any known or suspected misconduct related to laws, regulations, policies, procedures, YAI’s Compliance Plan, or YAI’s Code of Conduct.
YAI is committed to maintaining high quality care and service as well as integrity in its financial and business operations. Therefore, YAI will conduct appropriate screening to ensure that it is not employing, retaining or doing business with individuals or entities that are deemed to be “Ineligible Persons”. External providers who order services provided by YAI will also be included in the screening process.