PPNCNY Annual Reports, Corporate Compliance & Manuals

To contact our Corporate Compliance Officer for any corporate compliance complaints, please email [email protected]. Please note this address is for fraud, waste and abuse NOT general patient questions.

Policy Statement:

This policy applies to Planned Parenthood of the North Country New York, Inc. and its subsidiaries (collectively “PPNCNY”) and the employees, CEO, senior administrators, independent contractors, managers, and governing body of such entities as well as those acting for or on behalf of such entities (collectively, “Affected Individuals”).

All Affected Individuals and other representatives have an obligation to observe and follow PPNCNY’s policies and procedures and abide by the Standards of Conduct. If an individual’s behavior interferes with the orderly and efficient operation of the Agency’s business; disciplinary actions will be taken.  All individuals are to support the Agency’s vision, mission, and values in a respectful, responsible, and ethical manner and refuse to participate in unethical or illegal conduct.

PPNCNY is committed to complying with all federal and state laws, standards, and regulations.  As part of this commitment, PPNCNY established a Compliance Program and policies for preventing and detecting fraud, waste, and abuse.

1. Compliance with Laws, Regulations, and Contracts

PPNCNY is committed to conducting all its activities in compliance with applicable laws, regulations, and contractual obligations. PPNCNY requires that all Affected individuals and other representatives comply fully with all applicable laws, regulations, and other contractual obligations. If there is any doubt as to whether an activity is legal or proper, the individual must contact PPNCNY’s Compliance Officer.

2. Professional Ethics

PPNCNY is committed to the highest standards of business ethics and integrity. PPNCNY will fairly and accurately represent itself in all business relationships and will not engage in any activity or scheme intended to defraud anyone of money, property, or services. PPNCNY’s Compliance Program and related policies and procedures help ensure that the business activities reflect these high standards. PPNCNY expects All Affected Individuals, other representatives and related entities to refrain from conduct that may violate the fraud and abuse policies and related laws. Any independent contractors, vendors, interns, volunteers, agents, and other representatives that have questions related to a billing practice or the legitimacy of a certain transaction should contact the Compliance Officer.

3. Confidentiality

PPNCNY will protect all confidential information received in a manner consistent with applicable legal and ethical standards. PPNCNY will comply with applicable federal and state laws protecting the privacy and security of members’ health information (i.e., HIPAA) All Affected Individuals are expected to respect the proprietary and confidential information of all patients/members.

4. Sanctioned Individuals

PPNCNY will not knowingly employ any individual, or contract with any person or entity, who has been convicted of a criminal offense related to health care or who is listed by a Federal or State agency as debarred, excluded, or otherwise ineligible for participation in a government-funded health care program.

Upon hire, PPNCNY will conduct a primary source verification by querying and verifying Office of Inspector General (OIG), System for Award Management/Excluded Parties List System (GSA/SAM), OIG Most Wanted Fugitives, OFAC Specially Designated Nationals, New York State Office of the Medicaid Inspector General (NYOMIG), and National Practitioner Data Bank Proactive Disclosure Service (NPDB PDS) to ensure Entities or Individuals have not been excluded from participating in federal programs. Licensed Medical Staff will have additional NCQA standards verified. Persons and Contracted Entities will be terminated if an Individual or Entity with which PPNCNY does business has been excluded. Monthly monitoring and sanction screening will be performed for Licensed Medical Staff to include New York State License via the National Practitioner Data Bank Proactive Disclosure Service (NPDB PDS), Office of Inspector General (OIG) via the National Practitioner Data Bank Proactive Disclosure Service (NPDB PDS), New York State Medicaid Exclusion List (NYOMIG), and System for Award Management/ Excluded Parties List System (GSA/SAM). All other Affected Individuals will have monthly queries through Office of Inspector General (OIG) and New York State Office of the Medicaid Inspector General (NYOMIG).

5. Accurate Records

All individuals are responsible for ensuring that all financial reports, accounting records, expense accounts, timesheets, and other documents are accurate and clearly represent the relevant facts or the true nature of a transaction. Individuals should never make false or misleading entries in reports or other records. Business records will be kept in an accurate, true, and complete manner. In order to secure the accuracy and reliability of financial records and reports, PPNCNY has internal control standards and procedures. Accurate business records are important for the legal, financial, and other reporting obligations of PPNCNY. Fraudulent accounting or documentation is a violation of PPNCNY’s policies and applicable laws.

6. Medical Necessity: Reasonable and Necessary Services

All Affected Individuals shall ensure that claims are submitted to a payer only for services that are medically necessary and that were ordered by a provider or other appropriately licensed individual. All documentation must support the medical necessity of a service that was provided. If the patient requests or consents to a service that is not covered by insurance, the patient must be informed the service is not covered prior to the furnishing of such service.

7. Claims Development and Submission

All Affected Individuals involved in the billing functions, including providers, shall have experience and knowledge. Billing personnel shall be appropriately trained to perform all billing functions in accordance with Federal, state and local law.

8. Disciplinary Action

All Affected Individuals are responsible to ensure that their behavior and activities are consistent with the Standards of Conduct.  Individuals will be subject to discipline for violating the principles outlined in this Standards of Conduct, Compliance Program, and policies and procedures. Failure to comply may result in disciplinary action, including oral or written warnings or reprimands, suspensions, or termination of their employment and/or contract with PPNCNY.

9. Non-Intimidation/Non-Retaliation

All Affected Individuals play an essential part in compliance and must report any known or suspected violations of the Standards of Conduct, fraud, waste and abuse, misuse of funds, and/or falsification of internal records to our Compliance Officer without fear of retaliation or intimidation.