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Class A Contractor Compliance
Madison County is committed to providing the highest quality services and conducting our business with honesty and integrity and in conformance with all Federal and State laws, regulations, interpretations thereof, and the County’s Code of Conduct. We expect that the people who do business with our organization will support these efforts as well.
Certain types of contractors, subcontractors, independent contractors or agencies fall into the County's "Class A Contractor" category, and are considered "Affected Individuals". Class A Contractors are defined as any contractor, subcontractor, independent contractor or agent who, on behalf of the County (1) furnishes or otherwise authorizes the furnishing of Medicare and/or Medicaid health care items or services; (2) performs billing or coding functions; or (3) provides administrative or consultative services, goods, or services that are significant and material, are directly related to a health care provision, and/or are included in, or are a necessary component of, providing items or services of Medicaid-funded programs; or (4) is involved in the monitoring of health care services provided by the County; or (5) is determined by Madison County to be affected by any of its compliance risk areas as identified in NYCRR § 521-1.3(d) and set forth in Attachment 4 of the Corporate Compliance Plan.
In order to enhance our Class A Contractors' understanding and appreciation of Madison County’s Corporate Compliance Program, we have established this page to provide you with necessary information. We encourage you to familiarize yourself with these materials and ask for your cooperation in ensuring that this information is reviewed by, and made available to your Compliance Officer or appropriate senior management in your organization.
ç Links to our Compliance Training and Conflict of Interest Disclosure Statement can be found on the sidebar to the left.
More detailed information regarding the components of our Corporate Compliance Program can be found below ê
- Federal and State Laws
- Enforcement and Discipline
- Investigation and Resolution
- Reporting and Non-Retaliation
- Exclusion Screening
- Conflicts of Interest
- Training & Education
Federal and State Laws Relating to False Statements and False Claims
The federal False Claims Act, the federal Program Fraud Civil Remedies Act and certain other New York State laws can subject individuals and organizations to significant fines and penalties if they commit fraud against either the federal or the state government. Under the federal False Claims Act (31 U.S.C. §§ 3729-3733), false claims include knowingly submitting false or fraudulent claims to the government for payment, making or using a false record or statement in connection with the submission of such claims, or obtaining money from the government to which one is not entitled and then using false statements or records to retain the money.
View our False Claims Act and Whistleblower Provisions Policy here.
Enforcement and Discipline of Compliance Standards
Madison County has established disciplinary procedures and protocols to ensure that employees and independent contractors adhere to the County's Compliance Standards. Our disciplinary procedures enforce our commitment to the principles contained therein. Madison County will discipline any individuals or organizations whose conduct violates any of Madison County's Compliance Standards.
Investigation and Resolution of Compliance Issues
Madison County has established communication channels for all Affected Individuals to report problems and concerns. Anyone is encouraged to report issues via the traditional chain of command, their program supervisor, Compliance Hotline, or directly to the Corporate Compliance Officer. Ultimately, all of such reports are to be communicated to the Corporate Compliance Officer, who, in turn, is responsible for responding to the issues reported. This Policy is designed to establish a framework for responding to potential violations of the Compliance Program and managing investigations with respect thereto.
View our Investigation and Resolution of Compliance Issues Policy Here
Reporting of Compliance Concerns and Non-Retaliation
Madison County has established a compliance reporting process and a strict non-retaliation policy to protect Affected Individuals and others who report problems and concerns in good faith from retaliation. Any form of retaliation or retribution can undermine the compliance resolution process and result in a failure of communication channels in the organization. All employees, board members or contractors have an affirmative duty to report any known or suspected misconduct related to laws, regulations, policies, procedures, Madison County's Compliance Program, Corporate Compliance Plan, or Code of Conduct.
View our Reporting of Compliance Concerns, Non-Intimidation and Non-Retaliation Policy Here
Exclusion Screening
The County conducts exclusion list screening prior to the hiring of, or affiliation with, Affected Individuals, including prospective employees, board members and Class A Contractors, and on a monthly basis thereafter. The County will not employ, contract with, or conduct business or otherwise affiliate with any individual or entity that has been convicted of a criminal offense related to health care or is listed by OMIG, OIG, or the General Services Administration (GSA) as debarred, excluded, or otherwise ineligible for participation in state or federal health care programs (“Ineligible Person or Entity”). The County also requires its Class A Contractors to comply with these exclusion screening requirements.
Conflicts of Interest
Madison County's Conflict of Interest Policy includes a provision setting forth the standards of conduct expected and required of its Class A Contractors (independent contractors that provide direct health and medical services) to disclose all interest which could result in a conflict. The disclosure requirements are intended to provide the Board with a systematic and ongoing method of disclosing and ethically resolving potential conflicts of interest.
View our Conflict of Interest Policy here.
To complete a Conflict of Interest Disclosure Statement: Click Here
Compliance Training & Education
Regular and effective training is essential to the maintenance of a culture of compliance. Our training and education programs are designed to apprise all affected individuals of applicable federal, state, and local laws and regulations. Madison County makes available a Training Video for its Independent Contractors/Vendors (Class A Contractors) that provides an overview of the County's Compliance Program.
To view our training materials: Click Here.
If you have any questions about these policies or any other concern, please contact Christina Kennedy, Corporate Compliance Officer, at 315-366-2832 or christina.kennedy@madisoncounty.ny.gov. You may also report any concerns anonymously through the County's toll-free, 24/7 anonymous Hotline at 1-855-83-FRAUD (1-855-855-7283). In addition, the Office of Medicaid Inspector General (OMIG) has a website with a toll free hotline that makes it easy for whistleblowers to file a complaint.