Department of

Quality Assurance/Corporate Compliance

CORPORATE COMPLIANCE

TRAINING

2019

ISSNY is required to have a compliance

program under New York State Social

Services Law (SSL) § 363-d and 18 NYCRR

Part 521 because ISSNY is a “required

provider” as defined in 18 NYCRR §

521.2(a).

At Independent Support Services, Inc. it is our goal to instill a strong sense of personal

ethics and professional responsibility in our staff members. Through this training

program we intend to motivate all staff to adhere to a code of conduct that includes

corporate values such as honesty, respect and fairness, both in and outside of the

office. This training effort seeks to help employees learn what constitutes unethical

conduct so they can identify and report such conduct when seen. This training

program requires that staff persons affirm that they are not engaging in fraud, waste,

or abuse and recognize personal accountability for safeguarding Independent Support

Services, Inc. integrity.

Corporate Compliance Training

8 Elements of a Compliance Program

In order to have an effective compliance program ISS must incorporate:

1. Written Policies and Procedure – Code of Conduct and Ethics

2. Designation of Compliance Officer

3. Training and Education

4. Communication (hotline!)

5. Disciplinary Policies

6. Compliance Policies and Procedures Identification of Risk Areas and

Noncompliance

7. Response to Compliance Issues

8. Policy of Non-intimidation and Non-retaliation (whistleblower protection).

No person who works for or on behalf of Independent Support Services, Inc. (ISS) has the authority to act

contrary to:

a) The Rule of Law

b) Payer Regulations

c) The ISS Corporate Compliance Program

d) The ISS Policies and Procedures

e) Interests and concerns of Independent Support Services participants and their Circle of

Support.

No Person who works for or on behalf of Independent Support Services, Inc. has the power to :

a) Authorize violations of the Independent Support Services Compliance Program

b) Direct violations of the Independent Support Services Compliance Program

c) Condone violations of the Independent Support Services Compliance Program

Persons with knowledge of behavior that violates the law, policies and procedures are obligated to report to

Johanna Arteaga, MPA, CHC, Corporate Compliance Officer within twenty four (24) hours of the incident.

Accountability and Enforcement:

1. Independent Support Services maintains zero tolerance towards illegal and unethical conduct.

2. Improper or illegal conduct is not for Independent Support Services benefit and is strictly

prohibited.

3. Any and All parties who act contrary to the Corporate Compliance Program will be held

accountable for violations of said program.

4. Those who fail to report wrong-doing shall face disciplinary action as defined within the

Corporate Compliance Program.

All parties are directed to contact the Corporate Compliance Officer in the event of detecting a Corporate

Compliance Issue to the Compliance Officer:

Johanna Arteaga, MPA, CHC

390 Rabro Drive

Hauppauge, NY 11788

631-864-2536 ext. 422

jarteaga@issny.org;

QA/CC Department email: qualityassurance@issny.org;

Confidential Hotline: (833) -477-7287

All are encouraged to disclose their identity as the Corporate Compliance Officer will maintain all

disclosures in the strictest confidence. In accordance with Independent Support Services Whistleblower

policy, any staff member who lodges a compliance report will be protected from retaliation. Staff who

prefer to anonymously report may do so by either mailing a detailed letter to the Corporate Compliance

Officer at the above address or by placing a call to the agency’s confidential hotline.

The Corporate Compliance Program applies to:

1. Direct Service Providers including, but not limited to, the following position titles: Community

Integration Specialist, Community Habilitation Specialist, Life Skills Coach, Life Skills Trainer, In Home

Habilitation Specialist, Residential Skills Trainer, Job Coach, Job Developer, Living Skills Coach,

Employment Habilitator, etc.

2. Clinical / Medical Staff members including, but not limited to the following position titles: Support

Brokers, Case Managers, Medicaid Service Coordinators, CSS Program Managers, Social Workers, Nurses,

Behaviorists, Psychologists, Physical Therapists, Massage Therapists, Occupational Therapists, Speech

Therapists, Music Therapists, Dance Therapists, Doctors, etc.

3. Supervisors, Managers, Directors and support staff including those who are responsible for monitoring

and implementing services, carrying out administrative duties and administering agency policies and

procedures as well as those. Those responsible for intake, ensuring participants’ access to services,

eligibility determination, billing movement and discharge. Titles covered include, but are not limited to;

Senior Billing Specialist, Administrative Assistant, MIS Coordinator, CSS Program Director, Quality

Assurance Coordinator, Executive Director,Office File Clerk and Billing Specialist.

4. Fiscal Personnel: Those involved in billing for services, tracking and accounting for agency funds,

supplies and equipment. Also, those involved in purchasing, managing agency vehicle(s), equipment and

supplies, contracting for services, etc. Titles include, but are not limited to: Controller and senior

Bookkeeper.

5. Human Resources Personnel: Those involved in screening, credential verification, discipline and

personnel records, etc. Titles include, but are not limited to: Director of Human Resources, Senior

Human Resources Specialist, Senior Payroll Specialist and Payroll Specialist.

Basically the Corporate Compliance

Program Applies to Everyone!

This Means YOU!

Billing Document and Document

Retention Requirements

Documents required when submitting claims for services rendered to Medicaid for

payment:

1. Monthly Summary Notes

2. Employee Timesheets

3. Invoice / Service Records / Contracted Vendors

4. ISP, addenda and updates

Other documents that, while not necessary for Medicaid billing, must be retained for at least six years:

1. Mileage Reimbursement Forms

2. Account Balance Information by Participant

3. Y-T-D Expense Report (CSS-06)

4. Spending Detail Report (CSS-07)

5. Advance Payment and Repayment Agreement (CSS-08)

6. CSS Billing (CSS-09)

7. New York State Standard Voucher (AC92)

8. CSS Extenuating Circumstances Payment Authorization (CSS-09EXT)

9. Annual & Semi Annual Review Record (CSS-10)

10. CSS Plan Amendment & Summary Sheet (CSS-11)

11. MOU for the Provision of SD / CSS (CSS-13)

12. MOU between the FEA and Provider Agency (CSS-14)

13. CSS Expense Allocation (must be retained for at least six years)

14. IEP (if part of the initial self-direction application – must be retained for at least six years)

Mandatory Corporate

Compliance Guidelines for

Required Documentation

1. CSS Monthly Summary Note (CSS-01)

a. Every month, this form must be completed by the participant (or designee) and sent it to

the ISS by the tenth of the following month.

2. Time Sheet / Daily Service Records (CSS-02a, CSS-02b)

a. The employee must initial and date each day and time a plan service is provided

b. The employee must indicate if the service was provided as a face to face service.

c. At the end of each pay period, the completed timesheet(s) are signed and dated by the staff

person who performed the service

d. Timesheets must also be countersigned by the CSS Participant or their designee to verify that

the services indicated on the timesheet occurred and that the staff, as a result of the hours

worked, should be paid for services rendered.

e. The document must indicate what service was provided.

f. The duration of the service.

g. Description of:

i. Progress toward goal.

ii. Participant’s efforts at completing goal.

iii. Provider’s efforts at providing services.

iv. Signature and title of service provider.

v. Actual date note was written.

3. Invoice / Service Records for Contracted Vendors (CSS-03)

a. The contractor / vendor must initial and date each day and time a contracted service is provided

b. The contractor / vendor must indicate if the service was provided as a face to face service.

c. At the end of each pay period, the timesheets are signed and dated by the contractor / vendor who

performed the service

d. Timesheets must also be countersigned by the CSS Participant or their designee to verify that the

services occurred and that the staff should be paid for services rendered.

e. The document must indicate what service was provided.

f. The duration of the service.

g. Description of:

i. Progress toward goal.

ii. Participant’s efforts at completing goal.

iii. Provider’s efforts at providing services.

iv. Signature and title of service provider.

v. Actual date note was written.

To bill for a full month of Self-Direction service:

1. ISS must have, in hand and on-site, documentation which verifies that the participant received at least

four (4) face-to-face countable services, each provided on a separate day during the month. A

countable face-to-face service is a service or action that is delivered and documented by staff person /

contractor / vendor based on the participant’s needs as defined in his / her SD Plan.

2. The four (4) face-to-face countable services must be documented on the SD Employee Time Sheet /

Daily Service Record, and / or the SD Invoice / Service Record for Contractor / Vendor Services. These

service documentation records must be signed and dated contemporaneously with service delivery by

the staff person or vendor who provided the service. The record of service must also be countersigned

by the participant or by his / her designee.

3. ISS bills eMedNY (Medicaid) and / or OPWDD for a month of SD participant-specific plan services based

on receipt of the completed and authorized SD Employee Time Sheet / Daily Service Record and SD

Billing Sheet / or the SD Invoice / Service Record for Contractor / Vendor Services. These documents

must individually or collectively document that the participant received at least four (4) countable

face-to-face services, each provided on a separate day of the month.

4. The CSS Monthly Summary Note must be prepared and submitted every month by the participant

and/or his or her designee. ISS must receive and retain, for each month when service is billed, this CSS

Monthly Summary Note written, signed and dated by the CSS participant and/or his or her chosen

designee.

Documentation of each service required for monthly billing must include the following

daily service elements:

1. The participant’s name and Medicaid number (CIN). (The CIN does not need to be included in daily documentation; it

can appear in the person’s Self Direction Services Plan.)

2. Identification of category of waiver service provided (i.e.…Self Direction Services.)

3. The date the SD service was provided.

4. Daily service description, defined as a description of the individualized service provided by SD staff, based on the

person’s SD Plan. The service description must demonstrate an action by the SD staff.

5. General location of the service provided, i.e., at home and/or in the community.

6. Verification of service provision by the SD staff person delivering the service. That is, the SD staff person who delivered

the service must sign, provide his / her work title and include the date the service note was written, thus verifying that the

service was delivered. The date the note was written must be contemporaneous to the date the SD service was provided.

7. In addition, the SD participant or his / her designee must sign the completed form to verify that the service was provided.

The completed and appropriately signed service documentation records must be submitted to ISS for billing. Service

documentation records submitted without the contemporaneous signature of the staff person or vendor who provided the

service will result in nonpayment.

(Reminder: The above 7 elements must be included in each of the required daily service notes that substantiate a SD claim.)

In addition to the requirements listed on the previous slide;

At least once a month in the Monthly Summary Note, the

participant must describe his/her activities, progress achieved

in meeting the expectations specified in his/her SD Plan and

address any special issues or concerns that he/she may have. The

participant may be assisted in preparing the monthly summary note

by the designee of his or her choice.

General Documentation Requirements:

ISS must maintain the following documentation:

1. A copy of the person’s Individualized Service Plan, covering the time period of the payment

claim. The ISP must include the following elements:

a. The category of waiver service provided is Self Direction and identifies ISS as the Fiscal

Employer Agent.

b. Valued outcomes of the person receiving services. These are congruent to the outcomes

identified in the Self Direction Plan.

c. The ISP must specify that the frequency of SD Services is “monthly” and specify that the

duration is “ongoing.”

d. The effective date for SD services (i.e., the date the person was enrolled in SD services).

This date must be on or before the first date of service.

2. The CSS Plan that was developed with the participant and his / her circle of support, developed in

conformance with ADM 2003-03, Habilitation Plan Requirements. The plan must cover the time period of

the payment claim. The following elements must be included in the CSS Plan:

a. The person’s (a) name and (b) Medicaid Identification Number (CIN).

b. The category of waiver service provided is Self Direction Services identifies ISS as the Fiscal

Employer Agent.

c. Valued Outcomes of the person receiving services. These are the same as the outcomes

identified in the ISP.

d. The date on which the plan was last reviewed.

e. Location where service will be provided

f. Description of the individualized SD service

g. The contemporaneous signature and title of the ISS representative, the date signed, and the

signature of the participant and the date signed.

h. For each required six month review of the SD Plan, evidence that the review was conducted,

including the signature and title of an ISS staff person who participated in the review, and the date

of the review and any changes in the SD Plan.

i. A “CSS (SD) Plan Amendment and Summary Sheet” is completed if the participant wants to

change his / her plan.

Documentation Retention:

All documentation specified above must be retained for a period of at least six years from the date of the CSS

service billed to either eMedNY (Medicaid) or OMRDD, including the:

1. ISP

2. SD Plan

3. SD Employee Time Sheet/Daily Service Record

4. SD Billing Sheet

5. SD Invoice/Service Record for Contracted/Vendor Services

6. SD Monthly Summary Note.

Audit of Revenue and Expenditures:

The fiscal audit of ISS requires that all personal service expenditures are supported by and adequately

documented with SD Employee Time Sheet/Daily Service Records/ SD Billing Sheet and/or the CSS

Invoice/Service Records for Contracted/Vendor Services. Non-personal service expenditures must be supported

by receipts, invoices, and/or bills, as well as related proof of payment. Expenditures lacking adequate

supporting documentation may be subject to recovery from ISS. All expenditures are subject to the

requirements contained in the “Consolidated Fiscal Reporting and Claiming Manual.” It is necessary to keep

such documentation on file for a minimum of six years as a fiscal audit can review service documentation from

a period of six years prior to the date of the audit.

Documents required when submitting bills to Medicaid for

services:

1. Current Client Authorization for Services (Intake)

2. Level of Care / Physician Authorizations

3. Intake packet

4. Individualized Service Plans (Initial and Current)/ Life Plan

5. Monthly Notes

Specific to Care Management:

1. Date

2. Goal / Outcome – should be observable

3. Objectives: what the participant will do to achieve the outcome / goal; frequency;

duration, etc.

4. Target Date: anticipated dated that the goal will be accomplished

5. Identifies

a. Needs and strengths

b. Types of services

c. Names of providers

d. Addresses

e. Phone numbers

f. Frequency of service

g. Duration of Service

h. Target Date

i. Effective Date

j. Evidence of Team Participation (Dated Signatures)

Elements of effective Service Plans that support billing:

1. Notes are legible or typed

2. Notes are in ink if hand written

3. No Liquid Ink / Liquid Paper / White-out used

4. The date of Contact

5. Purpose and Outcome of Contact

6. Location of Service Meeting

7. Description of:

a. Progress toward goal.

b. Participant’s efforts at completing goal.

c. Provider’s efforts at providing services.

8. Signature and title of service provider.

9. Actual date note was written.

Elements of effective Notes that support billing:

BE ADVISED that all individuals covered by the Corporate Compliance Plan are subject to the

provisions of the Federal False Claims Act as noted below:

1. The False Claims Act: A false claim is a bill submitted for payment that is: false, incorrect, untrue,

inaccurate, fabricated, made-up, etc. This act says that such bills may not be submitted to

Medicaid or others for payment. (A person can be liable even if there was no intention to defraud

the government).

For Example:

a. Falsifying time records

b. Backdating notes and documents

c. Documenting services not provided

d. Writing or approving false bills

e. Failure to routinely monitor documents for errors / omissions.

f. Inaccurate documentation of information

g. Failure to comply with documentation training requirements

h. Insufficient knowledge of how to complete documents used for billing

Federal False Claims Act (Continued)

2. Anti Kickback: Employees are prohibited from accepting cash / gifts for referrals

and / or services. (example: kickback- as a support staff you know a friend that

provides classes that would be of interest to your participant and you take that

participant and other participants to the class and get a referral fee from your friend

when their enrollment increased.)

3. Conflict of Interest: Business dealings should NOT result in personal gain.

a. All must disclose actual or potential conflicts of interest;

b. If you have another job, besides working for ISS, your responsibilities

at that job may not interfere with your ability to perform duties in

relation to your work with ISS.

As a result, billing, coding and claims, MUST:

1) Be accurate.

2) Represent Services actually provided.

3) Service must be necessary and supportive documentation must be in the participant’s record.

4) Service must comply with regulations established by Medicaid and all other government

entities and payers.

As a result, participant’s records MUST:

1) Include all documents that support billing.

2) Be Secured: Should be double locked with access only by authorized personnel.

Other areas to reduce / mitigate: FRAUD, WASTE AND ABUSE

1) Ensure that agency vehicles are used for agency business (gas, toll and mileage)

2) Monitor agency supplies.

3) Monitor and Ensure that Participants monies are managed appropriately.

a)Verify timesheets, including time worked is recorded and accurate. Signatures are present and

employee paid. Retain timesheets

b)Documentation of service billing must be checked before billed. Staff must sign all billing.

c)Maintain all supporting documentation for billing.

d)Review, verify and retain all billing documentation.

e)Ensure staff and contractors have the required training, experience and licensing required.

f) Follow agency, state, and federal regulations, policies and procedures.

g)Any Corporate compliance breech must be reported, corrective actions must be put in place

including disciplinary actions. Corrective action must also adequately address the issue.

h)All documentation must be ready and available to be reviewed upon request.

i) Report all breeches to the Corporate Compliance Officer and or the Executive Director.

j) Licensed professionals who violate the program may be reported to their licensing body at the

discretion of the Compliance Officer and Executive Director.

Preventing FRAUD WASTE and ABUSE: Role of Supervisory level staff persons

EVERYONE has a responsibility to report:

1. Each individual covered by the Corporate Compliance Plan has a direct

responsibility to report suspected fraud, waste and/or abuse.

You do not have to know for sure if someone has done something

improper.

If you are concerned report it.

2. Each individual covered by the Corporate Compliance Plan must ensure that

incidents of suspected fraud, waste and / or abuse are reported.

3. Each individual covered by the Corporate Compliance Plan, who is involved in a

reported investigation, must actively participate in the investigative process.

4. Each individual covered by the Corporate Compliance Plan who is involved in a

reported investigation, must, as relevant, comply with recommendations and

follow-up activities.

Compliance with Corrective Action of Internal and External

Audits:

The Director / Supervisor:

1) Must implement corrective action and document the results of the corrective

actions undertaken to address compliance issue(s).

2) Must implement administrative measures (as appropriate) for any and all failure

of appropriate staff to complete accurate and appropriate records to support

billing or failure to monitor and detect billing problem.

Staff Members and/or Consultants/Vendors who have been found, after

investigation, to have violated the Corporate Compliance Plan:

1) Will be reported to the Executive Director and Human Resources and a letter

will be placed in the persons file.

2) Licensed professionals who violate the program may be reported to their

licensing body at the discretion of the Executive Director, Program

Supervisor and Financial Officer.

What is your responsibility?

1) Understand ISS’s Corporate Compliance Program

2) Understand your role in the success of the Corporate Compliance Program

3) Adhere to ISS’s Policies and Procedures

4) Avoid any situation that appears improper or has the possibility of being perceived as improper

5) Report known or suspected Compliance issues

6) Participate in investigations

7) DO NOT BACKDATE OR CREATE RECEIPTS, REPORTS RECORDS OR DOCUMENTS

8) DO NOT REQUEST THAT OTHERS ENGAGE IN FALSIFYING RECORDS OR DOCUMENTS.

9) DO NOT SIGN SOMEONE ELSES SIGNATURE

10) DO NOT SIGN SOMETHING YOU KNOW IS UNTRUE OR INACCURATE

11) White out is not permissible on timesheets and invoices

What happens if specifications are not met?

1) Billing is not permissible

2) If billing has occurred, monies must be returned and penalties may be assessed: this could cost

the agency a significant amount of money

3) Staff members who do not complete required documentation accurately will not be paid.

4) Staff will be disciplined for failure to complete accurate and appropriate records to support

billing.

5) Supervisory level / Administration will be disciplined for failures to detect billing problems.

6) Discipline will be progressive, up to and including termination.

Our Continued success at Independent Support Services Inc. depends on your continued

vigilance in complying with the Corporate Compliance standards delineated in this training. If

you have any questions, please contact the Corporate Compliance Officer.

Johanna Arteaga, MPA, CHC

390 Rabro Drive

Hauppauge, New York 11788

631-864-2536 ext. 422

jarteaga@issny.org;

(833)- 477-7287 (Confidential Reporting Hotline)

Independent Support Services, Inc.

ATTESTATION TO CORPORATE COMPLIANCE TRAINING*this training is subject to amendments by the QA/CC Department when necessary.

Sign, date and return this form to hr@issny.org;

I have read and understand the Corporate Compliance elements

I know who the ISSNY Corporate Compliance Officer is and how to reach the Corporate Compliance Officer.

Failure to notify ISSNY of any potential fraud, waste, or abuse can result in termination and further action as deemed appropriate.

If I have any questions regarding this training, I will contact the Compliance Officer.

I will not sign a document in which I know is untrue or sign another person’s name.

Signature: ____________________________ Date: ____________

Print Name:___________________________