Delphi Rise is committed to complying with all applicable federal and state laws, regulations and standards that govern its operations. In furtherance of this, Delphi Rise maintains a Corporate Compliance Plan that outlines legal and ethical expectations and the elements of our Compliance Program. The Compliance Program is applicable to all persons affected by Delphi Rise’s risk areas, including its employees, contractors, agents, subcontractors, independent contractors, governing body and corporate officers (herein referred to as “staff”).
The Compliance Program includes:
1. Written Policies, Procedures, and Code of Conduct
a. Policies and Procedures have been developed to articulate the expectations and steps that staff must follow to carry out the functions of the program. These policies emphasize our dedication to complying with the governing laws and conducting operations in a manner that ensures high quality service provision while adhering to ethical and legal standards. Policies and procedures are made available and accessible to all persons affected by Delphi Rise’s Compliance Program through a variety of methods, such as access to our intranet or through e-mail. Compliance policies and procedures are also linked below.
b. The Code of Conduct serves as a foundational document. It describes the principles, mission and values of Delphi Rise, and asserts the organization’s commitment to compliance with federal/state legal and ethical standards. All staff are expected not only to abide by the Code of Conduct, but also to promote ethical behavior.
2. Compliance Program Oversight
a. Compliance Officer – Delphi Rise has designated Mary LaDuca, Chief Operating Officer, as the organization’s Compliance Officer. Mary is responsible for the day-to-day operations of the compliance program with responsibilities that include but are not limited to: drafting/revising compliance policies, creating and updating an annual work plan, and investigating compliance concerns.
b. Compliance Committee – The Compliance Committee coordinates with the Compliance Officer to ensure Delphi Rise continues to conduct business in a responsible and ethical manner. The Committee meets at least quarterly and is chaired by the Compliance Officer. This Committee ensures that the organization has effective systems in place to identify and correct compliance program risks and overpayments.
3. Education and Training – All staff are provided with Compliance Program training initially within their first 30 days and annually thereafter. Participation in the training is a condition of continued employment/association with Delphi Rise.
4. Effective Lines of Communication – Staff, clients and others can ask compliance questions or report compliance issues to the Compliance Officer directly by calling our hotline at (585) 450-0241. Compliance concerns may also be reported by writing to: Attention: Compliance Officer, Delphi Rise, 72 Hinchey Road, Rochester, NY 14624. Should the reporter wish to omit their identity, these methods are considered anonymous reporting options. Reporters may leave identifying information if they wish to. The confidentiality of the individual reporting a compliance issue is maintained unless the matter is subject to a disciplinary proceeding, referred to/under investigation by the Medicaid Fraud Control Unit, Office of Medicaid Inspector General, or law enforcement; or, if disclosure is required during a legal proceeding. All reports made in good faith are protected under Delphi Rise’s Non-Retaliation policy.
5. Disciplinary Standards – Disciplinary action in response to a compliance violation is enforced in a fair and consistent manner with the same disciplinary action applying to all levels of personnel. Intentional or reckless behavior is subject to more significant consequences, such as immediate termination of employment/association with Delphi Rise. Delphi Rise trains its staff on the disciplinary process. Employees are provided with the disciplinary standards in the policies and procedures found on the intranet. The Board receives a copy of the bylaws that outline the disciplinary procedures for board members. Termination provisions are in agreements with contractors.
6. Auditing and Monitoring – Delphi Rise has an auditing process in place to detect non-compliance. Audits are focused on the risk areas, as outlined in the Compliance Plan. Corrective actions are implemented promptly following detection of a compliance issue/risk. Audit results and corrective measures are shared with the Compliance Committee and the Board.
7. Investigations and Response – The Compliance Officer, in consultation with legal counsel, will ensure a thorough investigation takes place when suspected compliance violations are reported. All individuals pertinent to the investigation will be interviewed and any evidence will be reviewed and collected for the investigative file. All staff must cooperate with investigations as a condition of continued employment/association with the organization. Corrective actions will be implemented based on the findings from the investigation. If an overpayment is identified in an audit or investigation, the funds must be promptly reported, returned and explained to the payor in accordance with the applicable payor’s established protocols.
8. Non-Retaliation and Whistleblower Protections – Delphi Rise strictly prohibits any form of retaliation or intimidation for good faith participation in the compliance program. This includes but is not limited to: reporting potential compliance issues to appropriate personnel, participating in a compliance investigation or audit, remedial actions, reporting instances of intimidation or retaliation; and reporting potential fraud, waste or abuse to the appropriate State or Federal entities.
