Compliance
& Ethics
Opengate Inc. recognizes our moral and ethical responsibility to maintain the highest level of legal and professional standards. We continue the tradition of quality care through our Compliance and Ethics programs which ensure and promote honest, responsible and transparent provisions of service. The Compliance Program is aimed at detecting/remediating any fraud, waste and/or abuse within the agency. Programs included in the compliance plan includes ensuring continued education and training of all shareholders, maintaining effective prevention systems and responding to claims of fraud, waste and abuse.
The Opengate Compliance Plan is in adherence with Social Services Law 363-d and Title 18 NYCRR Part 521 and includes the following elements;
Written Policies and Procedures
Our Employee Handbook and Code of Ethics outlines and identifies Opengate’s expectations of our employees, contractors and Board members conduct when engaging and interacting with families, individuals we support, other businesses, government entities and co-workers.
Opengate’s Current Policies and Procedures Include but is not limited to;
Conflicts of Interest
Compliance Reporting
False Claims and Whistleblower
Incident Reporting
Electronic Record Documentation
Billing for Services including self-disclosure and reimbursement practices
Compliance Officer and Compliance Committee (Designated Employee)
The Chief Compliance Officer is responsible for implementing and ensuring the effectiveness of all components within Opengate’s compliance plan. The Compliance committee shall be comprised of employees from different disciplines within the agency and a member of the Board of Directors. The committee is responsible for governing the policy review subcommittee, developing standards of conduct, analyzing external and internal factors, monitoring implementation of agency policies, reviewing/evaluating strategies for ongoing compliance and monitoring the effectiveness of the compliance plan.
Compliance Training and Education
The initial compliance training will occur within the first 30 days of the start date of service for all employees and Board members. Additionally annual refresher trainings will be completed thereafter for Opengate staff. Compliance trainings will include Code of Ethics specific to individual functions/responsibilities, the False Claims Act, the Health Information Privacy and Accountability Act, Employee Code of Conduct, “Affected Individuals” responsibilities to report, Compliance Reporting and Investigations, Non Retaliation Policy, introduction of Compliance Officer, disclosure of Conflicts of Interest and the Anonymous Compliance Reporting Hotline.
Communication Lines and Access to Compliance Team
Opengate is dedicated to ensuring open access and communication at all levels within the agency. Are you an employee, vendor or contractor who has identified or believes there may be an indication of abuse, fraud or waste? Please report all occurrences witnessed and/or known to a member of the Human Resources Department, or to:
Monica Healey, Chief Compliance Officer, (914)-277-5350 ext. 1112, monicah@opengateinc.org
Opengate’s Anonymous Compliance Hotline – (914)-351-0043
No attempt will be made to identify an individual who requests anonymity. Additionally, if you choose to reveal your identity, this information will not be revealed unless required by law or usual circumstances. Persons who makes a report in good faith will not be retaliated against; Opengate has a strictly enforced Non Retaliation and Intimidation policy. The agency is committed to responding promptly and appropriately.
Disciplinary Practices
All employees and affiliates are expected to follow Opengate’s code of conduct any and all violations of the code of conduct and Opengate’s Policies and Procedures are subject to disciplinary actions up to and including termination.
Auditing and Routine Monitoring
Opengate performs routine auditing and monitoring of its programs to ensure compliance and adherence to governing entities rules and regulations. We also actively participate in all governing body audits and monitoring activities.
Responding to Compliance Issues
The Opengate Compliance Team is charged with ensuring that all reports/incidents of suspected waste, fraud and abuse and/or any violation to Opengate’s Code of Conduct are investigated thoroughly, effectively and timely. All resolutions and recommendations are transparent and reported to the executive team and Board of Directors.