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Compliance Program

Commitment to Compliance

Consistent with the long tradition of ethical and responsible conduct of VNS Health, VNS Health Health Plans is committed to serving its members, providers and everyone with whom it does business pursuant to the highest ethical, business and legal standards.

To that end, VNS Health has implemented a comprehensive Compliance Program to ensure that legal and ethical conduct is an integral part of our organization’s culture and operations.

Compliance Program guidelines last updated: June 2022.

Code of Conduct

The VNS Health Code of Conduct is a statement of ethical and compliance principles that guide the daily operations of VNS Health, its subsidiaries and affiliates, including VNS Health Health Plans. The Code of Conduct establishes key ethical principles that we require all directors, officers, employees, contractors, agents, First Tier, Downstream and Related Entities (“FDRs”) and others associated with VNS Health and its FDRs to follow, as well as standards to help ensure compliance with applicable laws and company policies.

The Code of Conduct requires VNS Health Health Plan’s employees, Board members, administrators, physicians, volunteers, and those with whom we do business to report any action(s) that may be unlawful, inappropriate, or in violation of the Code of Conduct, applicable policies and procedures, or applicable laws, rules, and regulations. Be assured, there will be no intimidation of, or retaliation against, anyone who in good faith reports a compliance concern.

Code of conduct last updated: June 2022.

Compliance Policies and Procedures

VNS Health has adopted and implemented numerous compliance policies and procedures that further support our commitment to compliance, as embodied in the Compliance Program and Code of Conduct, and ensure that the Program is operating effectively and with integrity. These policies and procedures include, without limitation:

Nondiscrimination Notice

VNS Health Policy on Non-Retaliation and Non-Intimidation

VNS Health Plans Fraud, Waste, and Abuse Detection Manual

The Detection and Prevention of Fraud, Waste and Abuse and Applicable Federal and State Laws (DRA Policy) 

Sanction Checks

Policy How to Report a Compliance Concern

Anonymous Hotlines and Online Reporting Tool

VNS Health Compliance Hotline: (888) 634-1558

VNS Health Online Reporting Tool: www.vnshealth.ethicspoint.com

Through our Hotline and Online Reporting Tool, individuals can report a compliance concern, including fraud, waste and abuse, or seek guidance about compliance questions:

Any individual may make a report. All reports will be taken seriously and, if warranted, investigated by Compliance or the Special Investigations Unit.

When making a report, please provide as much detail as possible, such as names, dates, and a description of the issue. Unless you prefer to remain anonymous, please include your name and telephone number so that we may contact you if we have any questions during our investigation.

Fraud, Waste, and Abuse Detection and Prevention

VNS Health has established a comprehensive Fraud, Waste, and Abuse Prevention Program to prevent, detect, and correct fraud, waste, and abuse by employees, members, providers, agents, contractors and FDRs of VNS Health Health Plans. For more information, please see the Fraud, Waste and Abuse Detection and Prevention page.

Compliance Leadership

Individuals can always contact VNS Health Compliance directly with any compliance concerns or questions.

VNS Health Chief Compliance and Privacy Officer
Annie Miyazaki-Grant
SVP, Chief Compliance & Privacy Officer
(212) 609-7470
[email protected]

VNS Health Compliance Officer
Doug Goggin-Callahan
VP, Compliance & Regulatory Affairs
(201) 779-2584
[email protected]

Other Ways to Contact Compliance

Individuals can also send materials to the VNS Health Compliance Department by fax or mail:

Attn:
VNS Health
Compliance Department
220 East 42nd Street, 3rd Floor
New York, NY 10017
(646) 459-7730 (fax)

VNS Health Hotline: (888) 634-1558

VNS Health Online Reporting Tool: www.vnshealth.ethicspoint.com

Helpful Links:

CMS Compliance Program Policy and Guidance – Information on Centers for Medicare and Medicaid Services (CMS) Compliance Program requirements and links to compliance training.

NYS OMIG Compliance – New York State Office of the Medicaid Inspector (NYS OMIG) General Bureau of Compliance page, with links to the Compliance Library.

HHS Office of Civil Rights – HIPAA – U.S. Department of Health and Human Service Office of Civil Rights website offers information on health information privacy and security.

New York State Department of Health – Information about New York State Department of Health, as well as Model Contracts for VNS Health Health Plan’s Medicaid Managed Long Term Care (MLTC) and Medicaid Managed Care Special Needs Plan (SNP) can be accessed here.