OVERVIEW

This Compliance Plan & Code of Conduct sets forth standards of conduct that all personnel employed by or associated with Hospice of Westchester (“Hospice”) are expected to follow. The program is designed to be a guide and resource to help all personnel ensure that their behavior is in compliance with all laws and regulations that affect all of their business dealings. The program also describes the procedures that will be followed in enforcing these standards and ensuring that the Hospice stays in compliance with all applicable laws.
All personnel will be expected to read and understand this document and to review it as necessary in order to be alert to situations which could create a conflict of interest or otherwise be contrary to the established policies of the Hospice. All personnel must, upon receiving a copy of this program or the brief summary of the Compliance Program’s Code of Conduct and Compliance Procedures, sign and date an Acknowledgment of Receipt and return that Acknowledgement to the Compliance Officer.

The Importance of the Compliance Program:

The implementation of an effective compliance program is important for several reasons. First and foremost, it is essential that we ensure that we are operating pursuant to the highest ethical standards and in conformity with all applicable legal rules. This is not only the right thing to do, but is also important for our continuing reputation for honesty and integrity in all of our business and medical dealings with others. That reputation has been achieved and maintained through the integrity of our officers and employees, and it is one of our greatest assets: our success depends in large measure on the trust patients, government regulators, and the public place on us. A compliance program will help ensure that we are living up to this reputation and continue to deserve that trust.

Since 1992, Hospice has taken pride in offering high quality services to individuals and families in Westchester County. To preserve and enhance our well-deserved reputation, everyone associated with Hospice must share a commitment not only to our patients and our work but also to compliance with the numerous laws, regulations, and policies that govern our conduct.

This Plan was authorized by the Board of Directors who will oversee the implementation and review of the Compliance Program. The Code of Conduct briefly summarizes the provisions that govern various legal and ethical requirements we must meet. The Code is expected to serve as a useful guide to assist us and you in identifying and addressing those instances where there may not be compliance with the law, federal or state regulations, or with Hospice’s policy.

The failure to follow existing law can damage our reputation and threaten our ability to carry out our mission. Unlawful behavior also may result in criminal liability and civil fines and penalties. Individuals who knowingly violate or recklessly disregard this Compliance Plan, the Code of Conduct, or the laws, regulations and policies which govern Hospice will face severe consequences including termination.

We recognize that our ability to achieve compliance with the law depends upon our ability to recognize, avoid, and remedy existing problems. Our compliance, therefore, depends not only upon a choice to “follow the rules” but also our obligation to our mission, our agency, each other, and all those who serve Hospice of Westchester in any capacity, to comply with the laws and to bring all issues of potential concern to the attention of a supervisor or to a Hospice of Westchester Compliance Officer or a member of Compliance Committee member (see “Discharging Your Obligations”, below). In return, you have our commitment that the issues you raise will be promptly and properly reviewed and that appropriate corrective action will be taken where necessary. Most importantly, you will not in any way be subject to any adverse consequences for making good faith reports; to the contrary, we view the failure to bring appropriate concerns to our attention to be a serious breach of your obligations that could lead to disciplinary action.

In short, we commend and will support strongly those who make the proper choices at Hospice of Westchester, and will hold accountable those persons who make inappropriate choices or those who turn a blind eye toward improper conduct. Through our collective efforts we are confident that we can and will enhance our existing reputation for excellence.

COMPLIANCE COMMITTEE MEMBERS

Mary Spengler
914-682-1484, ext. 112
Executive Director, Hospice of Westchester

Carol Townsend-Ross
914-682-1484, ext. 135
Director of Clinical Services, Hospice of Westchester

Julia Lake
914-682-1484, ext. 143
Executive Assistant/Office Manager, Hospice of Westchester

Daniel Beltran
914-682-1484, ext 150
Director of Counseling, Hospice of Westchester

Tim Riordan
914-682-1484, ext. 113
Director of Finance, Hospice of Westchester
COMPLIANCE OFFICER