Section: 4.12
Issued: 12.31.2005
Updated: 03.27.2023
Purpose:
The purpose of this policy is to provide information about the AHRC NYC compliance training and education program.
Policy Overview:
AHRC NYC sets as a goal that, at the conclusion of all initial training, any employee of the organization that is approached can provide essential information regarding the compliance program, e.g., the names of compliance staff, reporting mechanisms, familiarity with the Code of Conduct, and can provide detailed information regarding their specific job responsibilities.
Scope:
This policy applies to all AHRC NYC Board members and staff. Attendance at training sessions is mandatory and is a condition of continued employment or contracting. Training includes initial orientation as well as ongoing education at regular intervals.
Procedure:
New Employees:
As part of their initial orientation, all new employees will receive a training session within the first 30 days of employment which will discuss the goals and objectives of Compliance.
Existing Employees:
All existing employees will receive a training session at least once a year with respect to Compliance and the Code of Conduct as well as a review of Compliance basics.
At the direction of the Board of Directors, the Compliance Committee, the vice president of Corporate Compliance or the CEO, additional training sessions may be held as the need arises to address changes in Compliance, state or federal laws and regulations or any issues of interest.
Each employee must attend compliance training annually. Participation is mandatory.
Acknowledgement Forms:
All employees will be asked to sign attendance sheets at each training session. The person conducting the training will be responsible for taking attendance at all training sessions and will maintain a record of course attendance at any training session which is part of the Compliance program.
Reports:
The vice president of Corporate Compliance will ensure that Organizational Learning maintains a record of all compliance-related training conducted.
Development of Training Programs and Material:
The vice president of Corporate Compliance and the Compliance Committee are responsible for monitoring, developing, and conducting ongoing compliance training and orientation sessions.
The trainers who offer compliance training must be appropriately knowledgeable about compliance and related policies and procedures, including the Code of Conduct, if addressed in the training, and those federal and state laws that are the topic being discussed. Trainers who are asked a question that they are unable to answer must arrange for appropriate follow-up to be conducted.
In addition to traditional forms of training, AHRC NYC may use periodic newsletters and emails to update employees on compliance related issues, as appropriate, to remind employees that they need to be cognizant of compliance issues.
Topics Covered in Training Programs:
Compliance education programs, at a minimum, will include information on the following aspects of the Corporate Compliance Program:
- The Code of Conduct.
- Internal communication channels, e.g., access to the vice president of Corporate Compliance, the Hotline.
- Organizational expectations for reporting problems and concerns.
- The False Claims Act.
- The non-retaliation policy for reporting made in good faith, i.e., whistleblower protection.
- Requirements for billing and documentation of services, including but not limited to a prohibition against signing for the work of another person and alterations to records. It is imperative that staff only document work that they completed themselves.
- State and federal confidentiality laws.
Enforcement:
Employees are informed during training sessions that strict compliance with Compliance and the Code of Conduct is a condition of employment and that compliance with the compliance rules and the Code of Conduct is one criterion upon which employees will be evaluated.