Section: 4.08
Issued: 12.31.2005
Updated: 03.20.2023
Purpose
The purpose of this policy is to delineate into AHRC NYC’s auditing and Compliance review structure and process.
Policy Overview
Auditing and monitoring are required elements of an effective compliance program; therefore, AHRC NYC will conduct audits and review all areas of the organization to ensure compliance with federal, state, local and organizational standards by which the AHRC NYC is governed and with AHRC NYC’s policies and procedures.
Scope
This policy applies to the compliance activities of AHRC NYC.
Procedure
Oversight of Compliance Reviews and Monitoring
Compliance Reviews:
On an annual basis, the vice president of Corporate Compliance will assess compliance risks.
On an annual basis, the vice president of Corporate Compliance will determine the scope and format of routine compliance reviews of AHRC NYC operations.
Compliance Audits:
The vice president of Corporate Compliance oversees compliance reviews of all departments by central compliance reviewers. These reviewers examine Medicaid documentation and compliance with other government requirements.
Engagement of Inside Counsel or Outside Counsel
The vice president of Corporate Compliance has the authority to seek outside counsel as needed for guidance on compliance issues and may also authorize and implement audits by outside consultants, including outside counsel, if the need arises. Audit activities will be undertaken under the supervision of the outside counsel with the expectation that audit findings will be privileged and confidential.
Documentation of Compliance Activities
The vice president of Corporate Compliance will maintain a record of all compliance and monitoring activities, including records pulled for review, audit/review results and corrective action documents in the Compliance Department’s or other departmental files.
Reports to the Board
The vice president of Corporate Compliance will provide an annual report to the Board of Directors, describing the conclusion of audits and an assessment of any compliance risks.