Vendor, Contractor & Affected Individual Compliance

Summit Home Health Care requires all vendors, contractors, subcontractors, and affected individuals to comply with our compliance program to the extent it relates to their role and responsibilities. This page provides the information required under the Deficit Reduction Act (DRA) and New York Social Services Law § 363-d.

 

Your Obligations Under Our Compliance Program

 

As a vendor, contractor, or affected individual doing business with Summit Home Health Care, you are subject to our compliance program as it relates to the services you provide. This includes understanding and complying with the applicable federal and state laws that govern health care operations, and supporting Summit Home Health Care’s efforts to prevent, detect, and correct fraud, waste, and abuse.

 

Compliance Officer & Compliance Committee

 

Summit Home Health Care has designated a Compliance Officer responsible for the day-to-day operation of the compliance program. Our Compliance Committee meets regularly and oversees program effectiveness.

Compliance Officer: Arthur Hagler
Phone: 917-398-0529
Email: [email protected]

 

How to Report Compliance Concerns

 

All vendors, contractors, and affected individuals are encouraged to report compliance concerns, potential violations, or suspected fraud, waste, or abuse. Reports may be made through any of the following channels:

 

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

 

Federal and State False Claims Acts

 

The Federal False Claims Act (31 U.S.C. §§ 3729–3733) prohibits knowingly submitting false or fraudulent claims for payment to the government. Penalties include significant civil penalties per false claim (adjusted annually for inflation), plus three times the amount of damages. The law includes qui tam (whistleblower) provisions allowing private individuals to file lawsuits on behalf of the government.

The New York State False Claims Act (State Finance Law §§ 187–194) mirrors the federal law and applies to Medicaid fraud. Penalties include $6,000 to $12,000 per violation, plus three times the amount of damages. The law also includes qui tam provisions.

New York State criminal laws (Social Services Law § 145-b, Penal Law Articles 155, 175, 176, 177) impose additional penalties including fines, imprisonment, and exclusion from health care programs for Medicaid fraud and related offenses.

 

Whistleblower Protections

 

Federal and state law prohibit retaliation against anyone who reports fraud, waste, or abuse in good faith:

• Federal FCA (31 U.S.C. § 3730(h)): protection from retaliation for reporting violations

• NYS FCA (State Finance Law § 191): state-level whistleblower protections

• NYS Labor Law § 740: protection for employees who report violations

• NYS Labor Law § 741: protection for health care workers who report patient care concerns

 

Retaliation is strictly prohibited. If retaliation is experienced for reporting in good faith, it should be reported immediately to the Compliance Officer or directly to:

• U.S. Department of Health and Human Services OIG Hotline: 1-800-HHS-TIPS

• NYS OMIG Fraud Hotline: 1-877-87-FRAUD

 

 

Exclusion Screening

 

Federal and state law prohibit health care providers from employing or engaging with individuals or entities excluded from participation in federal or state health care programs. Summit Home Health Care screens all employees, contractors, and vendors against:

• HHS-OIG List of Excluded Individuals/Entities (LEIE)

• System for Award Management (SAM.gov)

• NYS Medicaid Disqualified Provider List

• NYS-OMH/OASAS/OPWDD exclusion lists

 

All vendors and contractors must certify that neither their organization nor any of their employees or agents providing services to Summit Home Health Care are currently excluded, debarred, or otherwise ineligible. If any individual becomes excluded or receives notice of potential exclusion, Summit Home Health Care must be notified immediately.

 

Disciplinary Standards & Termination

 

Failure to comply with applicable laws, regulations, or Summit Home Health Care’s compliance policies may result in disciplinary action, up to and including termination of the business relationship. Summit Home Health Care reserves the right to terminate services with any contractor, vendor, or affected individual for cause, including but not limited to: failure to comply with federal or state health care laws, exclusion from health care programs, failure to cooperate with compliance investigations, or violation of compliance policies.

 

Regulatory Oversight

 

As participants in the Medicaid supply chain, vendors, contractors, and affected individuals may be subject to review by federal and state regulatory authorities, including:

• Office of Medicaid Inspector General (OMIG)

• Medicaid Fraud Control Unit (MFCU)

• U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG)

 

Summit Home Health Care expects all vendors and contractors to cooperate with any government compliance investigations that relate to services provided to or on behalf of Summit Home Health Care.

 

Annual Acknowledgment

 

Summit Home Health Care requires all vendors and contractors to complete an annual compliance training acknowledgment. To complete your acknowledgment for the current year, please contact Arthur Hagler at [email protected] or 917-398-0529.

 

Additional Information

 

Vendors, contractors, and affected individuals may request access to Summit Home Health Care’s complete written compliance policies and procedures at any time. If accommodations are needed (language assistance, accessibility, alternative formats), please contact the Compliance Officer.

For more information about Summit Home Health Care’s compliance program, visit our [Corporate Compliance page](/corporate-compliance) or [Fraud, Waste, and Abuse page](/fraud-waste-abuse).

Page 4: Code of Conduct (publish at /code-of-conduct on the agency site)

Code of Conduct

 

Purpose

 

Summit Home Health Care is committed to conducting its affairs in accordance with all applicable federal, state, and local laws, rules, regulations, program requirements, professional standards, and internal policies. Summit Home Health Care expects all affected individuals to act with honesty, fairness, integrity, respect, and sound judgment in every aspect of patient care, documentation, billing, operations, and business conduct. These Standards of Conduct are intended to promote lawful and ethical behavior, prevent fraud, waste, and abuse, support quality of care, and provide practical guidance for identifying and addressing compliance concerns.

 

Scope

 

These Standards of Conduct apply to all affected individuals, including Summit Home Health Care’s governing body members, officers, managers, supervisors, employees, temporary staff, contractors, agents, subcontractors, independent contractors, consultants, and, where applicable, vendors and other persons acting on behalf of Summit Home Health Care. Every affected individual has a personal duty to read, understand, and comply with these Standards of Conduct and all related Summit Home Health Care policies and procedures. No supervisor, manager, or other individual has authority to require, pressure, or permit anyone to violate the law, payer requirements, or Summit Home Health Care policy.

 

Guiding Principles

 

All affected individuals are expected to perform their responsibilities in good faith and in a manner reasonably believed to be in the best interests of Summit Home Health Care, its patients, and the Medicaid program. These Standards of Conduct are intended to provide general guidance and are not a complete statement of every legal or ethical obligation that may arise. When a question exists about the proper course of action, guidance must be sought promptly from a supervisor, department leader, Human Resources, the Compliance Officer, or legal counsel through established channels before action is taken.

 

Standards of Conduct

 

 

1. Quality of Care and Patient Dignity

 

Summit Home Health Care is committed to delivering high-quality, medically appropriate, safe, and compassionate care consistent with professional standards and all applicable legal and regulatory requirements. Patients must be treated with dignity, courtesy, compassion, respect, and without discrimination, harassment, abuse, neglect, exploitation, or coercion. Affected individuals must follow care plans, physician or authorized practitioner orders, scope-of-practice requirements, infection control rules, safety standards, and all patient rights requirements applicable to their role.

No affected individual may falsify clinical information, omit material facts, document care that was not provided, backdate entries, alter records improperly, or otherwise create a misleading patient record. Patient care concerns, quality issues, reportable incidents, suspected abuse or neglect, and unsafe conditions must be reported immediately through appropriate clinical and compliance channels.

 

2. Accurate Documentation, Billing, and Claims Submission

 

All books, records, reports, timesheets, visit records, clinical documentation, payroll records, claims data, and cost-related documentation must be complete, timely, accurate, and truthful. Claims submitted to Medicaid, Medicare, managed care organizations, and other payers must be supported by appropriate documentation, reflect only services actually rendered, and comply with all applicable billing, coding, coverage, authorization, and medical necessity requirements.

Summit Home Health Care strictly prohibits billing for services not rendered, duplicate billing, upcoding, inflating units of service, mischaracterizing services, billing for medically unnecessary services, falsifying visit information, submitting unsupported claims, or retaining overpayments improperly. No employee, contractor, or consultant may be offered incentives to improperly increase revenue or submit inaccurate claims.

 

3. Honest Business Practices

 

Affected individuals must accurately and honestly represent Summit Home Health Care in all communications and business dealings and may not engage in any deceptive, misleading, fraudulent, or improper act. Business decisions must be based on legitimate operational, clinical, quality, and financial considerations and never on improper influence or personal gain.

Summit Home Health Care prohibits bribes, kickbacks, payoffs, secret rebates, unlawful inducements, or anything of value offered, requested, or accepted to influence referrals, purchasing decisions, contract awards, patient admissions, service utilization, claims decisions, or any government-related action. Any arrangement involving referral sources, vendors, contractors, marketing representatives, or business partners must be structured and documented in a lawful manner.

 

4. Conflicts of Interest

 

Affected individuals must avoid actual conflicts of interest and situations that create the appearance that personal interests are interfering with their duties to Summit Home Health Care or its patients. A conflict may arise when an individual has a personal, financial, family, or outside business interest that could influence—or appear to influence—judgment or decision-making on behalf of Summit Home Health Care.

Potential or actual conflicts of interest must be disclosed promptly in accordance with Summit Home Health Care policy so they may be reviewed, managed, or eliminated. No affected individual may use their position, Summit Home Health Care information, or Summit Home Health Care property for improper personal benefit.

 

5. Confidentiality, Privacy, and Information Security

 

Patient information, employee information, financial information, proprietary business information, and compliance-related information must be protected from unauthorized access, use, or disclosure. Confidential information may be accessed, discussed, transmitted, copied, or disclosed only for legitimate business or patient care purposes and only by individuals authorized to receive it.

Affected individuals must comply with all applicable privacy, confidentiality, security, and record protection requirements, including HIPAA and related state requirements, as well as Summit Home Health Care’s internal confidentiality and information security policies. Unauthorized viewing, sharing, photographing, downloading, removing, or destruction of confidential information is prohibited.

 

6. Government Inquiries, Audits, and Investigations

 

Summit Home Health Care will respond to government inquiries, audits, investigations, subpoenas, and requests for information in a timely, truthful, organized, and lawful manner. No affected individual may conceal records, destroy documents, provide false information, obstruct an audit, interfere with an investigation, or attempt to mislead a government representative, auditor, investigator, or reviewer.

Any contact from a government agency concerning Summit Home Health Care business, records, billing, compliance, or patient care must be reported promptly in accordance with Summit Home Health Care policy so that the response can be coordinated appropriately. All affected individuals are expected to cooperate fully and honestly with authorized internal and external reviews.

 

7. Workplace Conduct and Respect

 

Summit Home Health Care expects all affected individuals to maintain a professional, respectful, and lawful workplace and to refrain from threatening, intimidating, discriminatory, harassing, abusive, or violent conduct. Conduct that undermines patient safety, team functioning, or the integrity of operations is inconsistent with these Standards of Conduct.

Summit Home Health Care prohibits discrimination and harassment against employees, applicants, patients, and others on any basis protected by applicable law. Retaliatory, intimidating, or bullying conduct is prohibited whether directed toward a coworker, subordinate, supervisor, patient, family member, or any person who raises a concern.

 

8. Protection of Company Assets and Resources

 

Summit Home Health Care assets, including funds, equipment, supplies, information systems, credentials, devices, records, and work time, must be used responsibly and only for authorized business purposes. Theft, misuse, careless handling, unauthorized removal, or personal use of Summit Home Health Care assets beyond what policy permits is prohibited.

Affected individuals must safeguard passwords, devices, electronic systems, and physical records against loss, misuse, theft, and unauthorized disclosure. Any suspected loss, theft, damage, security incident, or improper use of assets must be reported promptly.

 

9. Excluded, Ineligible, or Unqualified Persons

 

Summit Home Health Care will not knowingly employ, contract with, credential, or retain any person or entity that is excluded, suspended, debarred, or otherwise ineligible to participate in federal health care programs or state health care programs where such participation would violate legal or program requirements. Affected individuals must disclose any sanction, exclusion, licensure action, criminal charge, or other event that may affect their eligibility to perform services for Summit Home Health Care.

No individual may perform services outside the scope of their training, certification, licensure, authorization, or assigned responsibilities. Managers are responsible for ensuring appropriate oversight, credentials, and role-based assignments.

 

10. Duty to Report and Seek Guidance

 

Every affected individual has an affirmative duty to report suspected violations of law, regulation, payer rules, these Standards of Conduct, or Summit Home Health Care policy, including suspected fraud, waste, abuse, overpayments, privacy incidents, conflicts of interest, retaliation, unsafe care, record falsification, or misconduct. Reports may be made to a supervisor, manager, Human Resources, the Compliance Officer, a designated hotline, or through any other reporting avenue established by Summit Home Health Care.

Questions are encouraged and should be raised without hesitation whenever an individual is uncertain about the legality or propriety of a proposed action. Prompt and forthright reporting of mistakes, concerns, or possible violations supports correction, learning, and compliance and is expected as part of every affected individual’s responsibilities.

 

11. Non-Intimidation and Non-Retaliation

 

Summit Home Health Care strictly prohibits intimidation, retaliation, retribution, coercion, discrimination, harassment, or any other adverse action against a person who, in good faith, reports a concern, asks a compliance question, participates in an investigation, assists with an audit, or refuses to engage in conduct the individual reasonably believes to be unlawful or unethical. This protection applies regardless of whether the reported concern is ultimately substantiated, provided the report was made in good faith.

Any person who engages in retaliation or intimidation, or who attempts to discourage reporting, cooperation, or truthful participation in compliance activities, will be subject to disciplinary action up to and including termination of employment or contract. Managers and supervisors have a heightened responsibility to foster open communication and a culture in which concerns may be raised without fear.

 

12. Training, Acknowledgment, and Cooperation

 

All affected individuals must complete required orientation, training, education, attestations, and acknowledgments related to the compliance program and these Standards of Conduct. A signed acknowledgment of receipt and understanding shall be maintained in the appropriate personnel, credentialing, vendor, or compliance file.

Affected individuals are expected to participate fully in required compliance training and to apply that training in the performance of their responsibilities. Failure to attend required training, sign required acknowledgments, cooperate in compliance activities, or follow corrective action plans may result in disciplinary action.

 

13. Consequences of Violations

 

Violations of these Standards of Conduct, Summit Home Health Care policy, legal requirements, payer rules, or compliance directives may result in corrective action, disciplinary action, termination of employment, termination of contract, repayment obligations, reporting to government authorities, or other action permitted by law and policy. Progressive discipline is not required where the seriousness of the conduct warrants more immediate action.

Failure to report known misconduct, failure by supervisors to exercise reasonable oversight, interference with an investigation, or encouragement of improper conduct may also constitute a violation of these Standards of Conduct. Summit Home Health Care may revise these Standards of Conduct from time to time to reflect changes in law, regulation, operational needs, and identified risk areas.

 

Questions and Reporting

 

Questions regarding these Standards of Conduct or any compliance-related concern should be directed to Arthur Hagler at 917-398-0529 or [email protected], or through any other reporting channel designated by Summit Home Health Care.