Corporate Compliance

Summit Home Health Care is dedicated to providing high-quality home care services that enhance the lives of our clients and their families. We are committed to conducting our business in compliance with all applicable federal and New York State laws, rules, and regulations, and in accordance with the highest ethical standards. Summit Home Health Care expects the same from all affected individuals. We do not tolerate any form of unlawful or unethical behavior by anyone associated with our organization.

In accordance with New York Social Services Law § 363-d and 18 NYCRR Part 521, Summit Home Health Care has established an effective compliance program to prevent, detect, and correct fraud, waste, and abuse. Our program is structured around seven core elements required by the New York State Office of the Medicaid Inspector General (OMIG) and is designed for continuous improvement.

Element 1: Written Policies and Procedures

We believe that clear, well-documented standards are the foundation of ethical care. Summit Home Health Care maintains comprehensive written policies, procedures, and standards of conduct that guide how we operate every day. These documents are living resources, reviewed at least annually and updated to reflect current laws, industry best practices, and the lessons we learn from our own experience.

Standards of Conduct

Our Standards of Conduct set forth the ethical expectations for everyone associated with Summit Home Health Care, including employees, management, contractors, vendors, and all other affected individuals. They reflect our commitment to honesty, integrity, and full compliance with applicable laws and regulations. All affected individuals receive the Standards of Conduct upon hire and annually thereafter, and are expected to understand and follow them in carrying out their responsibilities.

Our Standards of Conduct address, among other areas:

• Ethical business conduct: acting honestly, in good faith, and in the best interest of our clients

• Accurate documentation and billing: ensuring all records, claims, and reports are truthful, complete, and compliant with applicable requirements

• Prevention of fraud, waste, and abuse: prohibiting false claims, improper billing, and misuse of program resources

• Conflicts of interest: avoiding situations where personal interests may conflict with professional obligations

• Confidentiality: protecting patient information in accordance with HIPAA and applicable privacy laws

• Anti-kickback and referral integrity: prohibiting financial inducements or payments in exchange for referrals

• Obligation to report: requiring all affected individuals to report known or suspected violations of law, regulation, or organizational policy

Read our Code of Conduct: [Code of Conduct Policy XIII-B / Standards of Conduct](/code-of-conduct)

Element 2: Compliance Officer and Compliance Committee

Accountability starts at the top. Summit Home Health Care has designated a Compliance Officer who serves as the focal point for our compliance program and is responsible for its day-to-day operation. Our Compliance Committee, composed of leadership across the organization, works alongside the Compliance Officer to identify risks, guide policy decisions, and ensure that compliance is woven into every level of our operations.

Element 3: Training and Education

Compliance is only effective when every team member understands their role in upholding it. All employees receive compliance training at hire, with comprehensive annual training and additional education as laws, regulations, or organizational needs evolve. We invest in our people because we know that an informed workforce is our strongest safeguard against fraud, waste, and abuse.

Element 4: Effective Lines of Communication

We believe that open communication is essential to a culture of integrity. Summit Home Health Care maintains multiple accessible channels for all affected individuals, including employees, contractors, vendors, and the communities we serve, to ask questions, raise concerns, and report potential compliance issues. Contact information for our Compliance Officer is readily available to everyone, including Medicaid recipients.

Questions or concerns relating to compliance may be reported through any of the following methods:

• Contact the Compliance Officer directly: 917-398-0529 / [email protected]

• Anonymous Voicemail Drop Box: 917-444-7701

• Mail: Summit Home Health Care Attn: Compliance Officer 1791 Coney Island Ave, Brooklyn, NY 11230 (anonymous)

• Online: https://www.trustsummit.com/report-an-issue/ (anonymous)

• Languages supported: English, Spanish

Reports can be made to the Compliance Officer Arthur Hagler by phone at 917-398-0529, email at [email protected], or via hotline voicemail drop box at 917-444-7701.

Reports may be made anonymously. The identity of all reporters will be kept confidential to the extent permitted by law.

Element 5: Disciplinary Standards

We hold ourselves to a high standard, and we hold each other accountable. Summit Home Health Care maintains clear, well-publicized disciplinary guidelines to address compliance violations and reinforce the expectation that every person associated with our organization acts with integrity. These standards are applied fairly and consistently, regardless of position or tenure.

Element 6: Internal Monitoring and Auditing

We don’t wait for problems to find us. Summit Home Health Care proactively monitors compliance through routine internal audits, risk assessments, and ongoing evaluation of our operations. We conduct an annual review of our entire compliance program, screen all affected individuals against federal and state exclusion lists, and use what we learn to continuously strengthen our practices.

Element 7: Response to Detected Offenses

When issues arise, we act. Summit Home Health Care has established clear procedures for promptly investigating compliance concerns identified through reporting, auditing, or day-to-day operations. We implement corrective actions swiftly and tailor them to prevent recurrence, because our commitment to compliance is not just about meeting requirements but about protecting the people we serve.

Non-Retaliation

Summit Home Care prohibits intimidation and retaliation against any person who, in good faith, reports a compliance concern, participates in a compliance investigation, or reports suspected fraud, waste, or abuse to any federal or state agency.

Review and Response

All reported concerns are taken seriously and reviewed promptly through Summit Home Care’s compliance process. The Compliance Officer investigates reports thoroughly, takes appropriate corrective action, and ensures follow-up. The identity of reporters is protected to the extent permitted by law.

Contact

For compliance-related questions, please contact Arthur Hagler at [email protected] or 917-398-0529.