Mission Statement

We partner with individuals of all abilities to reach their

fullest potential, protecting their rights and promoting their

independence and inclusion in our community.

Vision Statement

Striving for Excellence

Supporting Partnerships

Creating Solutions

Fulfilling Dreams

Corporate Compliance

The Community Services Corporate Compliance plan is a

system designed to detect and prevent violations of law,

and unethical activity by those associated with the agency.

The Corporate Compliance Plan has outlined the broad

principles of legal and ethical business conduct embraced by

Community Services for Every1, Inc.

It is not a complete list of legal or ethical questions you might

face, so it must be used in conjunction with common sense

and good judgment.

Confidentiality

All records, including those stored in electronic format, must becarefully handled and properly secured.

Personnel records and clinical records are considered highly sensitiveinformation. Names and/or other identifying information such associal security numbers and health information should never be leftunattended nor posted.

Employees should never disclose confidential information obtainedduring the course of employment, work (paid or unpaid) or receipt ofreports, to unauthorized individuals.

When sending confidential information to those who have a right toknow, the employee must take measures to ensure that it issafeguarded. Information sent via email outside of the agency shouldnot include names nor other identifying or sensitive information.Information sent via fax should either be sent to one of the agencyconfidential fax numbers or the sender needs to be certain that therecipient is at the other end to receive it.

ConfidentialityHIV or AIDS related information comes with additional requirements.Before releasing such information be sure to review the agency policyrelated the disclosure of confidential HIV/AIDS information and/orspeak to your supervisor.

Failure to safeguard information on the people being served may beconsidered a HIPAA violation.

Supervisors do not have access to their employee’s personnel files norhave a right to know their confidential health information.

Confidential records should never be disposed of unless properlydestroyed. Before disposing of any records employees should reviewthe records retention and destruction policy or speak to theirsupervisor.

Agency Assets Agency property, such as office supplies, office equipment,

and property, may not be used for personal reasons.

Any misuse or misappropriations of agency funds, information, equipment, facilities or other assets may be considered criminal behavior and can bring severe employment and legal consequences

Examples of Agency Assets Fax Machines

Computers/Network Accounts

Office Supplies i.e. copy paper, etc…

Residential Supplies i.e. cleaning supplies…

Gas Card

Credit Card

Agency Vehicles

Property Maintenance Supplies i.e. tools and equipment

Do not use Agency Mail boxes to distribute personal information

Cell phones

Computers and Network Accounts

The computer network is the property of the Agencyand is to be used for legitimate business purposes

Use of agency computers and network accounts,including email and internet is monitored.

All Users have a responsibility to use the Agency’scomputer resources and the Internet in a professional,lawful and ethical manner. Abuse of the computernetwork or the Internet, may result in disciplinaryaction, including termination, civil, and/or criminalliability. Internet access has been established for limitedemployment purposes.

Computer Use “DON’TS” Do not use your agency email for personal use.

Do not access your personal email on work time.

Do not send chain email letters.

Do not sign up for non-work related memberships using the agencynetwork.

Do not send or view inappropriate nor sexually explicit materials.

Do not share your password.

Your network account is your responsibility. If you share your email

information with family and friends you will be held accountable for

the information you receive.

Use of the agency email and network account is monitored.

Maintain Corporate Image The agency’s reputation and identity are among its

most valuable assets. All agency representatives areexpected to conduct themselves in a manner thatreflects positively on the agency’s image and identity,both internal and external.

No one should act in a way that adversely affects thereputation or image of the agency with employees,volunteers, people being served or with thecommunity at large.

GossipGossip in the workplace is unacceptable

unprofessional behavior and must beavoided.

Gossip may take the form of sharinginformation that is work related or personal,but is often lacking factual information andfrequently not the business of those who are

sharing the information.

Conflicts of InterestsEach employee has a primary business responsibility tothe agency and is expected to avoid any activity thatmay interfere or have the appearance of interferingwith their performance. A conflict of interest exists ifan employee’s outside business or other interests mayaffect adversely, or have the potential to affectadversely, his or her motivation, objectivity, loyalty orperformance.

Examples of Possible Conflicts of Interest

Supervising a family member Romantic relations between a supervisor and a

subordinate Accepting a gift of value from a vendor/person

served/individual’s family member Employment of a family member as a

contractor/vendor. An exempt employee who works for another agency

during hours that he/she is getting paid for at Community Services.

Relationships that interfere with the ability to do your job effectively or negatively effects the workplace.

Fraud

A Fraudulent Act is defined as “a deceptiondeliberately practiced to secure unfair or unlawfulgain.” Fraudulent acts may include, but are notlimited to:

Falsifying timesheets, travel reimbursement, etc… Billing for services not rendered Forgery False statements regarding injuries in order to

obtain compensation Providing false information regarding

certifications, credentials, employment history

False Claims Act

Is a National Law that was created to fight fraud.

States that it is a crime to “knowingly” submit a false claim to thegovernment for payment for services, property or other items.

“Knowingly” means

- Knows the record or claim is false

- Is asking for payment and is deliberately ignoring whether therecord or claim is false

- Is asking for payment and does not care if the record of claim isfalse.

Protects employees against any form of retaliation for filing alawsuit in good faith.

Someone can file a lawsuit in Federal Court on behalf of thegovernment and possibly receive a financial award.

False Claims Act

There are several laws both state and federal

that address False Claims. Additional information onthe False Claims Act can be located in your PersonnelPolicy and Procedure Manual or as a link on thewebsite.

Submit Accurate Billings and Financial Reports

Employee’s should never knowingly make or present improper, false, fictitious or fraudulent claims, i.e.:

Misrepresentation of services

Duplicate Billing

Billing two sources of funding for the same services

Falsifying Dates on a Claim

Submit Accurate Billing and Financial Reports, cont.

Dates of service submitted for billing need to coincide withthe date the service was provided. For example, MSC canonly be billed 1x/month and the service must be providedduring the month it was billed. If the worker was unable tosee the person face to face or provide two qualifyingservices during the month then he or she CANNOT bill.

Services that are billed in increments of time, i.e. 15minutes or an hour, must accurately reflect the amount oftime spent. It is NOT acceptable to round up. If billingoccurs in 15 minute increments and you only provided 42minutes of service then the agency can ONLY bill for 30minutes.

Accurate Record Keeping

Service documentation needs to be an accuratereflection of the amount of time spent providingservices. Timesheets, mileage, and sign-in and sign-out sheets may be checked against service records. Ifan employee documents that they provided servicesuntil 5:00 pm, but their timesheet indicates that theyended their day at 4:30 pm, the evidence supports thatthe service records were falsified and the employeecommitted a fraudulent act.

Crime Does Not Pay All billing and claims generated must accurately reflect that services

rendered are supported by relevant documentation. Having a person sign for services that were not rendered is not only fraud,

but abuse as well. It is crime to bill the government for services that were NOT rendered. Should the agency have evidence to support that crime has been

committed we will pursue legal action. This might include contacting oneor more of the following: local law enforcement, the NYS AttorneyGeneral, the Office of the Medicaid Inspector General, the DistrictAttorney.

Theft

Use of agency accounts, i.e. grocery and fuel forpersonal use is considered theft.

Taking agency items or goods, i.e. groceries, officesupplies, janitorial supplies for personal use isconsidered theft.

Use of agency petty cash and/or individual’s funds forpersonal use is considered theft.

The agency will not hesitate to press chargesagainst any employee who steals from theagency or people being served.

Refrain from AbuseAgency representatives shall not engage in any activities that constitute abuse of persons receiving services as defined in the regulations of the Commissioner of OPWDD.

Maintain a Safe & Healthful Workplace

Dispose of Medical Waste and Sharps in appropriate receptacles.

Remove articles/items that block exits and/or pose a safety hazard.

Keep walkways clear and free from debris, snow, ice…

Smoking is not allowed on any Community Services property, nor agency vehicles.

Practice safe lifting techniques. If something is too heavy to lift, ask for help.

Do not use your cell phone while driving an agency vehicle.

Do not text and drive.

DRIVE SAFELY AND OBEY TRAFFIC RULES WHEN USING AGENCY VEHICLES AND/OR TRANSPORTING THE PEOPLE WE SERVE.

Follow Regulations Regarding Control of Medication

Employees should not use medications intended for people being served. This includes over-the-counter medications.

ONLY medication certified staff are allowed to dispense medications.

Medications must be stored and disposed of in accordance with agency policy

& procedures.

Embrace Diversity

Cultural diversity affects organizations in severalways including the recruitment/retention of staff,management styles, decision making processes,and relationships within organizations.

Organizations can become more inclusive byaltering aspects of their culture in each of thesecategories.

Display Ethical Personal Conduct

Ethical personal conduct on the job means treatingoneself and others with respect and fairness.

All employees are expected to refrain from any formsof workplace harassment and avoid any type of activitythat could be considered promoting a hostile workenvironment.

Refrain from Substance Abuse and Unsafe Workplace Behavior

Manufacturing, selling, purchasing, transferring, or using illegal drugs, narcotics, or other unlawful substances or materials while conducting agency business.

Prescription and over-the-counter medication that interferes with the employee’s ability to perform his or her job duties.

Reporting to work impaired by the use of alcohol. Manufacturing, selling, purchasing, transferring or

possessing on the agency’s premises firearms, weapons, intoxicating beverages, drug paraphernalia, or medically authorized drugs used improperly or unsafely.

Substance Use Testing Employees may be asked to be tested for substance use atrandom, or for cause. The refusal of an employee toconsent to testing either when there is reason to suspectthat the employee is under the influence ofdrugs/alcohol, or when a random test is ordered willresult in the employee’s discharge. Any attempt tohinder collection procedures or to substitute a samplewill result in the disqualification of an applicant anddisciplinary measures for an employee.

Comply with Fundraising Standards Only Agency sponsored fundraising activities are allowable

on agency property.

All fundraising activities must be approved by the President& CEO or designee.

Funds received must be promptly submitted to the BusinessOffice and recorded as such.

Anyone depositing funds with the Business Office needs toobtain a receipt. The receipt should indicate how much wasdeposited and from what fundraising event.

Funds raised must be used for the purpose they wereintended for.

Whistleblower Protection Questions or concerns about any ethical or legal issue may be raised

without concern for disciplinary action as long as they are made in goodfaith.

Agency representatives will not be subject to reprisals for reporting orsupplying information about potential violations, except in cases wherethose employees are responsible for the violation or when deliberate falsereporting has occurred.

Any allegations that prove not to be substantiated and that prove to havebeen made maliciously or knowingly to be false will be viewed as a seriousdisciplinary offense

Any employee who retaliates or harasses someone who has reported aviolation in good faith is subject to disciplinary action up to and includingtermination of employment.

It is expected that all Community Services representatives will fullycooperate with any investigation of potential violation.

Failure to report could lead to disciplinary measures.

Zero Tolerance Statement

Community Services continues to vigorously strive for the highest standardsat all times. We are committed to maintaining a pleasant work environmentthat is desirable and creates a rewarding experience for agencyrepresentatives. It is the responsibility of ALL agency representatives tomaintain the highest standards of conduct for themselves. Every person has aresponsibility to comply with and support our Zero Tolerance Statement andto behave in a manner that is respectable.

The intent of this policy is to set the expectation for those behaviors thatCommunity Services has deemed as severe and unacceptable resulting intermination. When enforcing the zero tolerance standards the followingshould be considered: the intent of the offender, the effect of thetransgression on others (both those directly and indirectly involved), and,finally the impact on the agency. The punishment should fit the "crime."

“Zero Tolerance essentially means that no intentional behavior will betolerated that is deliberately perpetrated with the purpose of harming othersor the agency, for personal gain or vengeance. Transgressions include but arenot limited to: workplace violence, fraud, vandalism, theft of any kind, the useof any object as a weapon and/or conducting any type of illegal activity.”

My Supervisor is Harassing Me!

Unfortunately, employees will sometimesincorrectly use the terms “discrimination” or“harassment” to describe what they may beexperiencing in the workplace. While wewant all of our employees to be treated fairlyand respectfully, behavior such asdiscrimination and harassment are legalterms with serious consequences, therefore itis important to understand what it means.

DiscriminationOccurs when an employee suffers unfavorable or unfairtreatment due to:

Race

Religion

National origin

Disabled or veteran status

Other legally protected characteristics

HarassmentWork place Harassment is a form of discrimination thatoccurs when an employer, supervisor or co-worker harasses aperson because of their:

Race

Color

Creed

Ancestry

National origin

Age (40 and up)

Disability

Sex

Marital Status

Sexual Orientation

Membership in the Military Reserve

Sexual HarassmentSexual Harassment is any deliberate or repeatedunsolicited verbal comment, gesture, joke orphysical contact of a sexual nature. Unwelcomesexual advances, requests for sexual favors andother verbal or physical conduct of a sexualnature when such conduct: Is made explicitly a term or condition of employment; or,

Is used as a basis for employment decisions; or,

Has the purpose or effect of unreasonably interfering with workperformance or creating an otherwise hostile workingenvironment.

Hostile Work Environment vs.

Hostile Work Conditions

A hostile work environment occurswhen unwelcome comments orconduct based on: Sex Race Legally protected characteristics

The behavior unreasonably interferes with an employee’s work performance or creates an intimidating, hostile or offensive work environment.

Hostile work conditions includebehaviors that are inappropriate andunacceptable in the workplace,including: Demeaning, harassing, belittling

others; name calling Emotional tirades, tantrums, and

displays of anger Humiliating, intimidating,

threatening others Gossiping, spreading rumors about

and damaging a co-worker’s reputation

Refusing to follow authority without very good reasons

Being argumentative with no good reason except for trying to start a fight

Swearing or using obscene language in public places without regard to the reactions of others.

Sexual Hostile Work Environment

Examples of behavior that may create a Sexual Hostile Work Environment include:

Leering, i.e. staring in a sexually suggestive manner

Making offensive remarks about looks, clothing, body parts

Touching in a way that may make an employee feel uncomfortable, such as patting, pinching or intentional brushing against another’s body

Telling sexual or lewd jokes, hanging sexual posters, making sexual gestures

Sending, forwarding or soliciting sexually suggestive letters, notes, emails or images

What you should do when you feel discriminated against or harassed.

If you feel comfortable, tell the person to stop doing the offensive behavior. This can make and immediate difference.

After the situation occurs contact Employee Relations Coordinator to file a formal complaint.

Complete the form - Complaint of Alleged Discrimination as indicated in the instructions. (This form can be found in the Personnel Policy and Procedure Manual)

Once HR is aware of your concern the situation will be thoroughly investigated. The length of time for the process will depend upon the complexity and

particular circumstances of each complaint.

The complaining party and the accused party will be notified of the outcome of the investigation in writing

Refer to Personnel Policy and Procedure Manual for a complete description of the process. Policy against Harassment and Discrimination

Policy against Sex Discrimination and Sexual harassment.

Workplace Retaliation

Workplace Retaliation occurs when anemployer takes adverse or negative actionagainst an employee who complains aboutalleged discrimination or another unlawfulpractice, or participates in court oradministrative investigation, hearing orlitigation relating to workplace conduct byfiling a charge or acting as a witness. Even ifthe underlying complaint is found to bewithout merit, the employee who raised aconcern in good faith is protected from anyform of Retaliation.

If I file a complaint because I believe someone isdoing something wrong and it is determinedthat they were not what will happen to me?Will I get in trouble?

Community Services has a “No Retaliation Policy”

That means questions or complaints may be raised withoutconcern for disciplinary action as long as they are made in goodfaith and there are reasonable grounds for believing theinformation disclosed is accurate.

Agency representatives will not be subject to any form ofpunishment for reporting or supplying information aboutpotential violations of the Code of Business Conduct & Ethics,except in cases where those agency representatives are responsiblefor the violation or when deliberate false reporting has occurred.

What type of concerns should be presented to the Corporate Compliance Officer?

Please Note: This is not an all inclusive list

Misuse of Agency funds, property, and/or equipment, which may be considered criminal and/or unethical i.e. theft of agency funds or equipment, agency equipment removed from agency property for personal use, theft of office supplies.

Identified conflicts of interests i.e. directly supervising a family member and/or romantic relationship with a subordinate.

OSHA Violations i.e. hazardous workplace environment

Evidence of falsification of agency documents (case notes, time sheets, travel reimbursement, billing records, financial reports.)

Misuse of the Agency Tax Exempt form i.e. use for personal purchases.

Accepting or offering money or anything of value to any individual where it could appear that the purpose of the exchange is to influence the relationship.

Allegations of discrimination and/or other claims of unfair treatment or hiring practices.

Allegations of workplace harassment and/or unethical conduct i.e. offensive comments.

Breach of employee privacy. Allegations of substance abuse and/or

reporting to work impaired as a result of alcohol, illegal drug, prescription medication, and/or non-prescription medication usage.

Violation of any agency policy or procedures which could potentially have a significant negative impact on the agency i.e. failure to conduct a background check, failure to obtain the necessary approvals for purchases using agency funds.

Misuse of Agency Network Account, E-mail Account and/or Internet.

Other Violations of Law or Regulations that could pose a significant risk to agency operations.

ReportingYou can contact the Corporate Compliance

Officer in the following ways:

Speaking to your supervisor.

Contacting the Corporate Compliance Officer, Kelly Kinderman directly at 883-8888 box 174.

Leaving a message on the Corporate Compliance Hotline 883-8888 box 707.

Forwarding a writing message to the Corporate Compliance Officer,(V.P. of Program Support & Development) at 180 Oak.

Responsibility to Report If you feel that an employee or Agency Representative

has violated laws, rules or regulations that Community Services is governed by, you are requiredto report it!

Community Services has a Corporate Compliance Hotline that you can call to report a violation. Should you call the Hotline number please leave a detailed message and a thorough investigation will be conducted based on your concerns.

Employees who fail to report a violation may be subject to disciplinary action.

What to ReportWhen reporting a violation, please leave the

following information:

Your Name and Contact Information

Incident Details (when, where)

While the Agency will accept and investigateanonymous calls, if we do not receive theneeded information, we may not be able tosubstantiate the allegation.

Corporate Compliance PlanThe Corporate Compliance Plan has been prepared to outline thebroad principles of legal and ethical business conduct embraced byCommunity Services for Every1, Inc. It is not a complete list of legal orethical questions you might face in the course of business, andtherefore this plan must be used together with your common sense andgood judgment.

The entire Corporate Compliance Plan is available on Home Plate andthe agency web site at www.csevery1.com.

You can also contact your supervisor of the Corporate ComplianceOffice if you would like a hard copy.

The following documents are available on the agency website adjacent to the Corporate Compliance Training.

Corporate Compliance Plan

Code of Business Conduct and Ethics

False Claims Recovery Document

Confidentiality Agreement

Falsification of Documentation Statement

Zero Tolerance Statement

Please click the link below to complete this training.

Corporate Compliance Test