1. The State of New York adopted a false claims act NY False Claims Act (State Finance Law, §§187-194) that contains provisions similar to those under the federal False Claims Act. New York also adopted a Medicaid anti-fraud statute making it unlawful for a person to submit false and fraudulent claims to the New York Medicaid program. Violations of the statute are both civil and criminal in nature, punishable by imprisonment or significant monetary penalties. The NY False Claims Act closely tracts the federal False Claims Act. It imposes penalties and fines on individuals and entities that file false or fraudulent claims for payment from any state or local government, including health care programs such as Medicaid. The penalty for filing a false claim is $6,000 -$12,000 per claim and the recoverable damages are between two and three times the value of the amount falsely received.
   
   

2. Under the Social Services Law §145-b False Statements, it is a violation to knowingly obtain or attempt to obtain payment for items or services furnished under any Social Services program, including Medicaid, by use of a false statement, deliberate concealment or other fraudulent scheme or device. The State or the local Social Services district may recover three times the amount incorrectly paid. In addition, the Department of Health may impose a civil penalty of up to $2,000 per violation. If repeat violations occur within 5 years, a penalty up to $7,500 per violation may be imposed if they involve more serious violations of Medicaid rules, billing for services not rendered or providing excessive services.

It is Choices Women’s Medical Center policy to consistently and fully comply with The Health Insurance Portability and Accountability Act of 1996, Title II, Preventing Fraud and Abuse and its implementing regulations.

Employees are held accountable for knowing or believing that information contained in a claim submitted on behalf of Choices Women’s Medical Center is accurate. Employees cannot deliberately or carelessly ignore questionable information contained in claims made to a Public Health Program. Consistent with other Choices Women’s Medical Center policy and our Code of Conduct, employees are responsible for reporting concerns related to a Public Health Program claims to supervisors, Choices Women’s Medical Center Compliance Officer or the Compliance Hotline. Choices Women’s Medical Center takes reports of suspected fraud and abuse seriously and conducts periodic audits to detect and prevent false claims. Employees that lawfully and in good faith report false claims are protected from retaliation by Choices Women’s Medical Center policy and federal and state law.

NOTE: This policy also applies to Choices Women’s Medical Center business arrangements with physicians, contractors, vendors, and other agents impacted by federal or state laws relating to Public Health Program claims.

Choices Women’s Medical Center has adopted this Code of Ethical Conduct as a demonstration of our unwavering commitment to honor all laws and regulations that govern the healthcare industry. The elements of this Code of Ethical Conduct include our Vision, Mission, Values, Basic Principles of Conduct, Standards of Service Excellence and Standards of Professional and Business Conduct and are incorporated into Choices Women’s Medical Center Compliance Program. This Code of Ethical Conduct serves to enhance and continually develop a culture that values compliance from the top-down and fosters compliance from the bottom-up throughout Choices Women’s Medical Center and among all workforce members.

This Code of Ethical Conduct is designed to provide overall guidance; however, it is not possible to address every situation. Guidance that is more specific may be provided in Choices Women’s Medical Center Policies and Procedures or in Choices Women’s Medical Center Employee Handbook. If there is no specific policy, this Code of Ethical Conduct becomes the policy. (If a policy and a Code of Ethical Conduct provision conflict, the policy governs.) This Code of Ethical Conduct is a “living document” meaning that it will be updated periodically to respond to changing conditions. Questions regarding this Code of Ethical Conduct, or any issue, should first be raised by an employee to his or her immediate supervisor, then through the chain of authority up to, and including, the Compliance Officer, or the Director of Human Resources at Choices Women’s Medical Center. Alternatively, issues may be reported confidentially and anonymously to the Compliance Officer.

As we meet and exceed the expectations of our community, we lay the foundation of Customer Service through our Standards of Service Excellence. We work diligently and consistently to build a organization-wide culture of service excellence wherein every employee is responsible and accountable for upholding the following Standards of Service Excellence:
We believe in making positive first impressions our first priority.

Apply the ten-foot rule. Initiate interaction with patients, guests or other employees within ten feet of you with a smile and warm hello. Help the facilities be and look their best. Create a sense of trust and respect with everyone, first impressions set the tone.
We believe in treating others as guests.

Apply the golden rule. Treat others as you wish to be treated. Be friendly and outgoing, show an interest in our patients and coworkers; help them feel welcome and important.

We believe in developing service recovery.

Be a problem solver. Take the initiative to find a solution or someone who can. Another important component of service recovery is to acknowledge, apologize and amend. Finally, turn negative into positive experiences.

We believe in communicating effectively.

Listen to understand. Listen with empathy and always communicate on someone’s level. Give your undivided attention and use appropriate words and tone, remember body language is 55% of the message you communicate.

We believe in serving others from a team-centered approach.

Be accountable for team effort and success. Be a mentor to those needing encouragement and direction. Make patient satisfaction a team effort.

We believe in projecting a positive attitude.

Always speak positively. Remember attitude sets the stage for success or failure. Positive attitude, ambition and enthusiasm are contagious.

We believe in making excellence the goal in everything we do.

Never settle for second best; expect the best from yourself and others. Exceed the expectations of others.

We believe in serving others from a team-centered approach.

Be accountable for team effort and success. Be a mentor to those needing encouragement and direction. Make patient satisfaction a team effort.

We believe in projecting a positive attitude.

We believe in projecting a positive attitude.

Always speak positively. Remember attitude sets the stage for success or failure. Positive attitude, ambition and enthusiasm are contagious.

We believe in making excellence the goal in everything we do.

Never settle for second best; expect the best from yourself and others. Exceed the expectations of others.

Choices Women’s Medical Center and Comprehensive Women’s Medical Care, P.C. (CWMC) Compliance Program is a comprehensive self-governing program designed to proactively minimize the chances that a violation of law or government regulation occurs within CWMC. It is modeled on the eight basic elements proposed by the federal government’s Office of Inspector General (OMIG) for developing effective Compliance Programs, and includes: (1) Policies and Procedures, (2) Compliance Officer, (3) Training and Education, (4) Open Lines of Communication, (5) Enforcing Disciplinary Standards, (6) Risk Management, and (7) Responding to Detected Deficiencies, and (8) Non-Intimidation and Non-Retaliation Policies. The Compliance Officer reports directly to the Chief Executive Officer of Choices Women’s Medical Center and Vice President of Comprehensive Women’s Medical Care, P.C. and the Compliance Advisory Committee and is responsible for the administration of Choices Women’s Medical Center Compliance Program as well as the day-to-day operation of Choices Women’s Medical Center Compliance Program. Choices Women’s Medical Center Compliance Program is responsible for regulatory, privacy, monitoring and auditing issues, and training.

The Compliance Officer also chairs the Compliance Advisory Committee – a complement of multidisciplinary CWMC leaders. This committee has oversight responsibilities to ensure organization-wide compliance with the fundamental elements of CWMC Compliance Program. In general, the committee addresses various compliance related issues and other applicable projects including but not limited to regulatory developments, internal and external audits and legal issues. Most importantly, the committee seeks to ensure that all compliance objectives are advanced according to expectations and properly executed. In furthering organization-wide compliance, the Compliance Advisory Committee determines the scope of issues that warrant further review by the Committee of Departmental Directors and makes recommendations accordingly. The Compliance Officer, on behalf of the Compliance Advisory Committee, presents regular compliance reports to the Chief Executive Officer of Choices Women’s Medical Center and Vice President of Comprehensive Women’s Medical Care, P.C. and the Compliance Advisory Committee. The Compliance Officer also makes reports directly to the Committee of Departmental Directors from time to time.

Choices Women’s Medical Center Compliance Program has a dedicated team that is responsible for internal monitoring and auditing of documentation, coding, and billing patterns across Choices Women’s Medical Center physician offices and facilities. Coding Assurance audits focus on ensuring that all applicable state and federal laws and regulations are being followed; that underpayments and overpayments are identified early; payments are refunded appropriately when needed; and action plans are developed to mitigate against further occurrences. Additionally, each year the Compliance Advisory Committee develops and executes an internal audit plan derived from the federal government’s annual OIG Annual Work Plan, internal issues of concern, and from various other issues within the healthcare industry. This audit plan is also utilized as an internal risk assessment tool.

CWMC Compliance Program provides initial orientation and continuing compliance education for all new and existing employees. In addition, all employees are required to complete annual compliance training. The Compliance Program utilizes in-person training. In-person training includes lunch and learns, attending staff meetings, and periodic rounding throughout Choices Women’s Medical Center. In addition, the Compliance Advisory Committee provides education and training when needed throughout Choices Women’s Medical Center. Education is also provided from outside healthcare consultants when applicable.

Choices Women’s Medical Center believes each of its employees has an individual responsibility and duty to report their good faith belief of any violation of this Code of Conduct, Choices Women’s Medical Center policies or applicable law to his or her immediate supervisor, Choices Women’s Medical Center Compliance Program, or the Compliance Hotline and encourages each employee to do so.