Corporate Compliance Reporting
It is the responsibility of all employees to report suspected fraud, abuse or other improper activity relating to the operation of Clubhouse of Suffolk Inc. [d/b/a Association for Mental Health and Wellness (MHAW)], whether committed by agency employees, vendors, clients, or others.
Fraud means any type of intentional deception carried out or misrepresentation made by a person with the knowledge that the deception or misrepresentation could result in the receipt of an unauthorized benefit by such person, or another individual or entity.
Abuse means activities that are inconsistent with sound fiscal, business or medical practices and result in i) an unnecessary cost to the state or federal government or Clubhouse of Suffolk [d/b/a Association for Mental Health and Wellness] or ii) the reimbursement of services that are not medically necessary or fail to meet professionally recognized standards of care.
Employees have several options for reporting fraudulent, abusive or other improper conduct. Employees may file reports with their supervisor or department director, the Compliance Officer, or any other member of the Compliance Committee with whom the employee feels comfortable.
All reports of fraudulent, abusive or other improper conduct will be promptly forwarded to the Compliance Officer for review. The Compliance Officer, in consultation with other Clubhouse of Suffolk [d/b/a Association for Mental Health and Wellness] staff and legal counsel as appropriate, will determine whether the report warrants an investigation. The Compliance Officer will use best efforts to make this determination within 10 days of the receipt of the report.
Clubhouse of Suffolk [d/b/a Association for Mental Health and Wellness] has established an e-mail address through which employees may file reports anonymously. Employees are protected from retaliation for filing reports of suspected fraud, abuse or improper conduct under Clubhouse of Suffolk’s [d/b/a Association for Mental Health and Wellness] Non-Retaliation Policy.