Section: 4.16
Issued: 03.09.2010
Updated: 04.02.2024
Updated: 04.01.2025
Purpose
The purpose of this policy is to define non-compliant behavior and the corresponding disciplinary action which are fair, consistent and apply to all levels of personnel across the agency.
Policy Overview
In accordance with the requirements of city and state regulators, AHRC NYC has developed the following guidelines for discipline of infractions under our various policies which prescribe compliance standards.
Infraction
Penalty
Deliberate falsification of records
Immediate dismissal
Inducing or directing others to non-compliant behavior
Immediate dismissal
Failure to attend annual Compliance training
Written warning; progressive disciplinary action up to and including dismissal
Failure to follow instructions re: compliance-related matters including failure to report suspected problems
Up to and including dismissal, based on severity
Mistakes which are determined to be due to misunderstanding procedures
Retraining and/or a written warning
Theft of agency resources
Immediate dismissal, possible referral for criminal prosecution
Conspiracy to commit violation of compliance policy
Immediate dismissal
Deliberate unauthorized release of Protected Health Information (PHI)
Immediate dismissal, possible referral for criminal prosecution
Deliberately misleading or false statements to auditor or investigator
Immediate dismissal
Willful disregard of non-compliant behavior
Immediate dismissal
Intimidation of another employee, volunteer, contractor or other agent of AHRC NYC for the purpose of them not reporting in good faith, a potential compliance concern to any government entity
Immediate dismissal
Retaliation of any kind, including but not limited to threats and actions both documented, verbal or demonstrated toward another employee, volunteer, contractor or other agent of AHRC NYC who in good faith reported a compliance concern to any government entity
Immediate dismissal