Elmira CitySchool District

Family, School, Community:Together We Succeed

Medicaid Compliance Program Overview

The Elmira City School District, hereafter referred to as "District", prides itself on its history of upholding the highest quality standards in its programs. The District strives to develop and maintain best practices in all areas.

Consistent with this commitment to quality, the District has established this Medicaid Compliance Program ("Program"). This Program is designed to provide a framework for ensuring effective regulatory compliance and to demonstrate and document the District's commitment to the highest level of professional integrity and ethics in all Medicaid compliance. The Medicaid Compliance Program has as its centerpiece a Code of Conduct detailing the District's ethical standards to be applied to all Medicaid-related activities.

This Medicaid Compliance Program is established to promote Medicaid compliance throughout the entire District. This Program is intended to benefit not only the District and the community it serves, but also relevant governmental authorities, private parties doing business with the District, and the general public. This Program shall be routinely reviewed and revised as appropriate.

This Program provides for the appointment of a Medicaid Compliance Officer by the Superintendent of the District, which person shall be responsible for general oversight and implementation of the Program and of the District's other Medicaid compliance policies and procedures. The Medicaid Compliance Officer shall appoint and supervise and shall be assisted by Medicaid Coordinators responsible for those discrete programs or departments within the District engaged in Medicaidrelated activities.

The Superintendent shall directly supervise the Medicaid Compliance Officer and, in appropriate cases, perform certain Medicaid compliance functions when such functions are unable to be performed by such officer.

Overseeing the entire Program shall be a Medicaid Compliance Committee of the Board of Education which shall have primary responsibility for reviewing and setting Medicaid compliance policy for the District and for reviewing the performance of the Medicaid Compliance Program. This committee shall, in appropriate cases, assume responsibility for directing the performance of certain compliance functions when such functions are unable to be performed by either the Superintendent or the Medicaid Compliance Officer.

The District's Medicaid Compliance Program focuses on 7 key elements which serve as the underpinnings for detecting and preventing fraud, waste, and abuse.

1. Code of Conduct

Outlines the general principles of conduct and ethics to be followed by persons engaged in Medicaid-related work for or on behalf of the District.

2. Medicaid Compliance Team

Consisting of the Medicaid Compliance Officer, the Medicaid Compliance Committee, the Superintendent, and various Medicaid Coordinators, the District's Medicaid Compliance Team is a team of persons bearing direct responsibility for and having authority over the implementation, monitoring, and management of the District's Medicaid Compliance Program.

3. Education on and Reinforcement of Compliance Principles

The District's Medicaid Compliance Team shall ensure that the District's Program and periodic updates and amendments to such Program are regularly, adequately, and clearly communicated to persons to whom the Program pertains to ensure that compliance standards and expectations are applied in a timely, correct, and consistent fashion.

4. Promotion of an Environment that Supports Participation in the Compliance Program

Through the enforcement of substantive disciplinary policies that clearly articulate expectations for reporting suspected violations of the Medicaid Compliance Program and other Medicaid compliance policies and guidelines, the District intends to promote an atmosphere of participation and compliance by all relevant persons. Moreover, all persons reporting suspected compliance violations are assured protection from intimidation, retaliation, and any manner of discrimination in terms or conditions of employment as a result of their reporting of such suspected violations.

5. Open Communication and Access to Responsible District Officials

A system for confidentially and anonymously reporting suspected compliance violations to the Medicaid Compliance Officer encourages the transmission of information relevant to the District's monitoring and assurance of the integrity and efficacy of its Medicaid Compliance Program. A system that permits persons to report compliance violations "up the ladder" to the Superintendent and to the Medicaid Compliance Committee in appropriate cases helps guarantee that the involvement of individual members of the Medicaid Compliance Team in compliance violations or risks will not jeopardize the flow of essential information on Medicaid compliance.

6. Identification and Monitoring of Compliance Risk Areas

An annual District-wide compliance assessment and routine compliance audits by individual programs and departments help the District quickly and efficiently identify areas of compliance risk, monitor corrective action, and focus its audit and assessment schedule and Program reviews.

7. Response to Identified Compliance Violations

Prompt identification of and response to compliance violations and the timely making of all reports required to be made to governmental and other authorities having jurisdiction over the District's Medicaid-related activities facilitates the accomplishment of the goals of each of the above-mentioned Program components.

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Confidential Disclosure Policy

Anonymous and Confidential Compliance Violation Reporting

Director of Student Services
Derek Almy
EMAIL: dalmy [@] elmiracityschools.com
PH: 607.735.3019

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CONFIDENTIAL DISCLOSURE POLICY | For School and Preschool Supportive Health Services

This document describes the Elmira City School District's ("District') Confidential Disclosure Policy ("Policy'') pertaining to the reporting of suspected Medicaid compliance violations related to the reimbursement of School or Preschool Supportive Health Services. This document is intended as a summary only and should be read together with the District's Medicaid Compliance Program and other Medicaid compliance policies and materials maintained by the District.
Reporting Suspected Violations Directly to the New York State Compliance Officer

Any employee who believes that any practice or billing procedure related to Medicaid reimbursement of School or Preschool Supportive Health Services is inappropriate may send information concerning such practice or billing procedure to the New York State Compliance Officer ("State Compliance Officer") by U.S. mail, courier service, e-mail, or fax. The contact information for the State Compliance Officer is as follows:

The State Compliance Officer will send any disclosures received to relevant state agencies and to the District. If the Compliance Officer is aware of the reporting employee's identity, he or she shall not reveal it to any other person without the employee's written consent.

District Review of Violations Reported to the State Compliance Officer

Upon the District's receipt of notice from the State Compliance Officer of any alleged inappropriate practice or billing procedure, the District will undertake a review of the relevant practice or billing procedure to determine (a) whether the allegations are credible, (b) whether any relevant federal or state statute, regulation, or policy has been violated, and (c) the scope of any such violation. If a violation is determined to have occurred, the District will prepare and implement an appropriate remedial plan to address the violation. Within ninety (90) days of its receipt of notice from the State Compliance Officer, the District will provide the State Compliance Officer with a written report on its review, remedial plan, and actions taken pursuant to lts remedial plan, which report shall identify the individual(s) responsible for approving the review, the plan, and all actions taken pursuant to the plan. If the District determines that an employee's allegations are not credible, the District shall describe its basis for such determination in its report.

If the State Compliance Officer is not satisfied with the District's review of or response to an alleged inappropriate practice or billing procedure, he or she may discuss the matter with the District to address his or her concerns and may, in appropriate cases, request that the Audit Unit of the New York State Department of Health's Division of Administration audit the District's review of and response to the allegations.

No Retaliation Against Reporting Employees

If the District discovers the identity of any employee who has made a report to the State Compliance Officer pursuant to this Policy, the District shall take no adverse employment action of any type against said employee because he or she provided information to the State Compliance Officer or to any other person reviewing the alleged inappropriate practices or billing procedures.