Fraud, Waste, Abuse, and Financial Impropriety Prevention Policy
It is the policy of HealthCare Access Maryland to safeguard and protect all of HCAM’s resources. HCAM’s Administration Department and Executive Team are primarily responsible for safeguarding resources by establishing and maintaining sound internal controls designed to deter and detect potential misuse of resources, by taking action to minimize financial loss when misuse occurs, and by correcting abuse. All employees and board members are responsible for reporting improprieties they observe.
Any member of the staff or member of the board of directors who has information about known or suspected financial improprieties, misuse of the organization’s resources, or other ethical problems is encouraged to report their concerns to the Corporate Compliance Officer (CCO), who will then investigate. In the event that the allegations involve the CCO, the individual may report their concerns directly to the HCAM’S CEO. In the event that the allegations involve the CEO of HCAM, the individual may report their concerns directly to HCAM’s Board President. The sources of reports about financial improprieties and misuse of the organization’s resources will be held in confidence unless the individual who reports the situation agrees to reveal his/her identity or the report leads to legal actions and a court order is issued for information regarding the case.
HCAM will investigate any possible impropriety or fraudulent or dishonest use or misuse of HCAM’s resources or property by board members or staff. Anyone found to have engaged in an impropriety or fraudulent activity is subject to disciplinary action by HCAM up to and including termination or dismissal and civil or criminal prosecution, when warranted.
Examples of fraudulent conduct or impropriety include but are not limited to the following:
- Misappropriation or misuse of the organization’s resources, such as funds, supplies, or other assets
- Authorizing or receiving compensation for goods not received, services not performed, or hours not worked
- Forgery or alteration of documents belonging to HCAM and/or its partners
- Pursuit of a benefit or advantage in violation of HCAM’s conflict of interest policy
- Abuse or inappropriate activity with a program participant
- Fraudulent financial reporting
- Fraudulent reporting of work completed (e.g., number of clients seen, etc.)
Criteria used to determine whether certain activities or behavior constitute misuse of resources include state and federal laws and HCAM’s internal policies and procedures.
Reporting Fraud, Waste, Abuse, and Financial Impropriety
HCAM is committed to enforcing the Fraud, Waste, Abuse, and Financial Impropriety Prevention Policy in accordance with HCAM’s Corporate Compliance Program. Any HCAM employee, client, or board member who suspects fraud is encouraged to report the suspected violation to the appropriate officer, as noted in the Fraud, Waste, Abuse, and Financial Impropriety Policy located above and in the employee handbook. In the event the allegations involve the CCO, the individual may report their concerns directly to the CEO of HCAM. In the event that the allegations involve the CEO of HCAM, the individual may report their concerns directly to HCAM’s Board President.
All reported or suspected violations will be investigated in accordance with the Fraud, Waste, Abuse, and Financial Impropriety Policy. Any person reporting a suspected violation will be protected by HCAM’s Non-Retaliation Policy, which protects any reporting person from retaliation for participating in an investigation, for good faith reporting, or for objecting to any activity by another employee that they reasonably believe is unlawful, unethical, or in violation of HCAM’s Code of Conduct and/or Corporate Compliance Policy.
Compliance violations and complaints should be addressed to:Corporate Compliance Officer 1 N Charles Street, Suite 900 Baltimore, MD 21201 410-949-2883
All reports shall be documented, reviewed, and evaluated, and the CCO shall safeguard the confidentiality of all reports and investigations. The CCO shall also institute necessary policies to prohibit any form of retaliation against any person who makes a report. The CCO may recommend that the company retain such consultants or auditors as may be necessary to conduct a proper investigation and consult with any outside counsel as may be retained for such purpose. In conducting an investigation, the CCO shall have access to all corporate documents, including e-mail, and authority to interview any employee. After concluding an investigation, the CCO shall make a report and submit it to the CEO with recommendations for appropriate disciplinary action.
All reporting parties are required to fully cooperate with the CCO in administering the investigation of any alleged violation.