HealthCare Access Maryland (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 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:
Chief Compliance Officer
1 N. Charles Street, Suite 900
Baltimore, MD 21201
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.