Section: 4.14
Issued: 12.31.2005
Updated: 03.20.2023
Reviewed:04.02.2024
Reviewed: 02.28.2025
Purpose
The purpose of this policy is to provide information on AHRC NYC’s Corporate Compliance investigative process.
Policy Overview
AHRC NYC will respond to reports or reasonable indications of suspected noncompliance by commencing a prompt investigation of the allegations to determine whether a violation has, in fact, occurred.
Scope
This policy applies to compliance related investigati0ns conducted to evaluate possible violations of laws or regulations or of the Compliance policies and procedures within AHRC NYC.
Procedure
The Chief Compliance Officer/VP Corporate Compliance will promptly initiate an investigation into any allegations of non compliance with expected practices and protocols related to federal and state funding. They oversee internal compliance investigations and have the authority to engage counsel or other consultants, as needed. The Chief Compliance Officer/VP Corporate Compliance will consider whether an investigation should be conducted under privilege. Senior leadership may bring suspected infractions of regulations or policies beyond the scope of federal or state funding to the attention of the CCO/VP who will evaluate whether corporate compliance resources can be utilized.
Depending upon the type of possible compliance infraction, the Chief Compliance Officer/VP Corporate Compliance will determine which agency employees possess the requisite skill sets to examine the particular issue(s) and will assemble a team of investigators as needed. The Chief Compliance Officer/VP Corporate Compliance will decide whether AHRC NYC has sufficient internal resources to conduct the investigation, or whether external resources are also needed.
If appropriate, the Chief Compliance Officer/VP Corporate Compliance will recommend the cessation of internal activities that may be the cause of the possible non-compliance.
The Chief Compliance Officer/VP Corporate Compliance will work with the investigation team to develop a strategy for reviewing and examining the facts surrounding the possible violation, which may include, but not be limited to, an audit of billing practices and interviews. Interviews should include the “Who, What, When, Where, and Why” of the circumstances. All interview notes and notes from the documents reviewed must be kept as part of the investigation file.
Post-Investigation
Upon receipt of the results from the investigation, depending on the scope and severity of any identified violations, the Chief Compliance Officer/VP Corporate Compliance may consult with counsel, the Chief Executive Officer and/or the internal and Board Compliance and Ethics Committees in order to determine:
- The results of the investigation and the adequacy of recommendations for corrective actions
- The completeness, objectivity and adequacy of the results and findings, and/or
- Further actions to be taken as necessary and appropriate.
Documentation
At the conclusion of the investigation, the Chief Compliance Officer/VP Corporate Compliance will organize the information in a manner that enables AHRC NYC to determine whether an infraction did, in fact, occur.
Reporting
The Chief Compliance Officer/VP Corporate Compliance will be responsible for reporting all investigations to the Chief Executive Officer and the Board of Directors, as appropriate.