CODAC Management Manual

CORPORATE COMPLIANCE PLAN

CODAC has establish a policy and plan around corporate compliance to provide services that fully comply with all federal, state, and local regulations, applicable laws and contractual obligations, and to adhere to explicit ethical standards throughout all facets of the organization’s operations (Policy Admin-311). CODAC will ensure these conditions of operation are met through an organized and ongoing comprehensive Corporate Compliance Program (described fully in CODAC’s Corporate Compliance Plan). Dr. Amy Munoz is CODAC’s Corporate Compliance Officer and is responsible for the oversight of CODAC’s Corporate Compliance Program. CODAC personnel are required to report any suspected cases of fraud, waste and/or abuse, as well as any violations to applicable local, state, and federal laws. CODAC provides a mechanism to assist personnel and/or agents in reporting suspected violations of possible criminal conduct by persons within the organization or complaints relating to services provided to a patient, without fear of retribution. • Internal reporting: Reporting mechanisms include internal reporting to Supervisor or other Management personnel, who must then report directly to agency’s designated Corporate Compliance Officer. • Anonymous reporting via Lighthouse Services, Inc.: personnel may also report violations, complaints, or unethical or improper behavior to the anonymous Lighthouse Compliance and Ethics Hotline via the website: http://www.lighthouse-services.com/codac, via email to reports@lighthouse-services.com, and via telephone: 1-800-401-8004 (English speaking) and 1-800-216-1288 (Spanish speaking). • External reporting: Personnel may report externally via email at reportfraud@azdhs.gov. or using the OIG AHCCCS online reporting form available at: https://azahcccs.gov/Fraud/ReportFraud/, or via AHCCCS Fraud and Abuse hotline 888-487-6686. EMPLOYEE TRAINING AND SKILL DEVELOPMENT REQUIREMENTS CODAC is CARF accredited in several areas, most notably as a Health Home and Outpatient Treatment Program. As such, CODAC is informed by and adheres to CARF standards of care, as well as requirements from other regulatory agencies, which are reflected in staff training during new hire and throughout CODAC employment. • New Hire Orientation (NHO) – all new hires is primarily an overview to CODAC and takes approximately 1.5 days reviewing general CODAC policies and procedures. • Clinical Orientation - follows NHO, new clinical staff attend Clinical Fridays for several weeks, whole days dedicated to a more in-depth look at clinical services and processes at CODAC. • Relias (web-based) - the bulk of Relias training occurs during the first month of a new hire’s time at CODAC, particularly if the new staff member is new to Arizona or new to the field. Relias provides foundational knowledge and training about the AHCCCS (Medicaid) healthcare system in Arizona and expectations for service delivery for behavioral health recipients and Health Home members within that system. There are several topics within Relias that are vital, it’s important to encourage staff to take this seriously. • Direct Service Employees - For clinical staff, CODAC utilizes a 12-week structured training guide that can be modified to fit site or position specific needs. Supervisors take a lead role in training newly hired staff once they complete the initial New Hire Orientation. Within 3 months of hire, most training

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