Starbridge is committed to conducting business in a manner that promotes compliance with laws and regulations, continually monitors for compliance, and creates systems that allow Starbridge to be responsive to identified risk areas and changes in the regulatory environment. Starbridge has a Corporate Compliance Plan, and we are dedicated to managing and operating our services in keeping with the highest of quality, business, ethical and moral principles. Our Board of Directors, Employees, Interns, Volunteers and Contractors contribute to achieving these principles by conducting business activities for the agency with integrity and high ethical standards.

In accordance with State and Federal laws and regulations, our Compliance Plan assists in the prevention and detection of fraud, waste and abuse. Our Corporate Compliance Plan is applicable to all business dealings with service recipients, contractors, vendors, employees, board members, funding agencies and the general public.

Starbridge recognizes that a critical aspect of our compliance program is the establishment of a culture that promotes prevention, detection, and resolution of instances of conduct that do not conform to federal and state requirements, as well as our Code of Conduct.

To promote this culture, Starbridge established a compliance reporting process and a strict non-intimidation and non-retaliation policy to protect all individuals who, in good faith, report problems and concerns, participate in an investigation, evaluation, audit and/or remedial actions.  Any form of intimidation and/or retaliation should be reported to the Corporate Compliance Officer or other reporting mechanism immediately.

If interested in reporting a compliance concern, please contact the Compliance Officer at 585-224-7242 or email at QualityandComplianceDirector@starbridgeinc.org.

If interested in reporting compliance concerns anonymously, call the Compliance Hotline by dialing *67, then 585-224-7202.

We want to hear from you!

If you have any comments or suggestions on how to improve our Compliance Plan, please contact the Quality Improvement and Corporate Compliance Director at 585-224-7242 or email at QualityandComplianceDirector@starbridgeinc.org.

You can access copies of these standards/policies and procedures by contacting the Quality Improvement and Corporate Compliance Director at 585-224-7242 or email at QualityandComplianceDirector@starbridgeinc.org.

Corporate Compliance documents available for review

Corporate Compliance Plan Index

Quality and Compliance Director Job Description

Organizational Chart

Billing Verification and Storage Standard

IRA Residential Habilitation Billing Standard

Medicaid Service Coordination Billing Standard

Supported Employment Billing Standard

Community Habilitation Billing Standard

Financial Management Services Billing Standard / Consolidated Supports & Services

Medicaid Service Coordination Billing Standard Supervised IRA (D/c’d 10/2011)

Day Habilitation

Education

Bridges to Health

Youth and Family Partnership

Gift Policy

Board, Employee, Volunteer, Intern, Contractor Code of Conduct

Board, Employee, Volunteer, Intern Conflict of Interest

Agents of LDA Compliance Training

Enforcement of Compliance Standards

Internal Auditing and Monitoring

Investigation of Compliance Issues

Reporting Compliance Concerns – Non‐Intimidation / Non‐Retaliation

Reimbursement Practices and Billing Errors

Role and Responsibility of Audit/Finance/Corporate Compliance Committee

LDA Compliance Committee

Whistleblower Policy

Exclusion Screening for Agents of LDA

Liability for Service

Potential Compliance Issue

Glossary

Forms

1. Acknowledgement Form (Board)

2. Acknowledgement Form (Contractor)

3. Acknowledgement Form (Employee, Volunteer, Intern)

4. Acknowledgement Form – Billing Standards (Employee)

5. Billing Documentation Storage Request Form

6. Billing Documentation Storage Access Tracker

7. Conflict of Interest (Employee, Volunteer, Intern)

8. Potential Compliance Issue Form

9. Reporting Reference List

10. Service Adjustment Form

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