Compliance & Ethics

Introduction 

IRI is dedicated to maintaining the highest ethical standards in business operations and community interactions, ensuring strict compliance with all relevant laws and regulations. IRI is firmly committed to preventing, detecting, reporting, and correcting any behavior that deviates from these high ethical standards. To support this mission, IRI has established a comprehensive Compliance Program, which aligns with the seven mandated elements outlined in OMIG’s 1/31/23 Guidance on Compliance Programs, Social Services Law Section 363-d (SOS § 363-d) and Title 18 NYCRR SubPart 521-1 (SubPart 521-1).  Below is a summary of our Compliance Plan.

Seven Elements of Compliance:

  • Written Policies and Procedures: IRI’s policies align with legal standards and are reviewed annually.

  • Compliance Officer: The Compliance Officer (Susan McGrath) ensures program oversight and reports directly to the CEO and board.

  • Compliance Committee: Oversees compliance activities, meets quarterly, and reports annually to the board.

  • Training and Education: Regular compliance training is mandatory for all staff and associates.

  • Disciplinary Standards: Clear consequences are set for non-compliance, ensuring uniform enforcement.

  • Auditing and Monitoring: Regular internal audits and external evaluations identify compliance risks and ensure effectiveness.

  • Responding to Issues: Prompt investigations and corrective actions are implemented to address identified compliance issues.

Code of Conduct and Rules of Conduct: Employees, Board Members, Contractors, etc. must adhere to high ethical standards, including accurate billing, conflict of interest avoidance, and HIPAA compliance.

Professional Conduct: Expected behaviors are outlined, and violence, harassment, substance misuse, and conflicts of interest are prohibited.

Whistleblower Policy: Protections for reporting compliance concerns are emphasized, with a strict non-retaliation policy for good-faith reports. IRI’s anonymous hotline

Exclusion Checks and Credential Verification: Monthly exclusion checks ensure IRI does not employ or contract excluded individuals or entities. Credential checks for licensed professionals are routinely conducted.

Record Retention and False Claims Act: Records are maintained and destroyed as required by law, and strict procedures are followed to avoid fraudulent claims.

Enforcement and Disciplinary Actions: Disciplinary actions are enforced for policy violations, with uniform standards applied.

Conflict of Interest Policies: Strict guidelines prevent conflicts involving board members, employees, and contractors, ensuring business decisions are not influenced by personal interests.

For more information about IRI’s Compliance Program, please contact:

Susan McGrath, Chief Compliance Officer

susan.mcgrath@iriny.org

929-641-0115

To make a confidential and anonymous report, feel free to call our compliance hotline at 516-285-1439