Code of Conduct/ Fraud, Waste & Abuse New River Valley Community Services Orientation and Annual Training

Why does NRVCS need a Code of Conduct? We are a business and want to maintain ethical business practices. We want an environment that is free from any criminal conduct, fraud, and abuse. We want our staff at all levels to demonstrate the highest level of ethical standards in all that we do and for the clients we serve. We have an obligation to the taxpayers to use our resources wisely and protect the resources that have been entrusted to us.

What is Corporate Compliance? A set of standards, policies, procedures, internal controls and risk management strategies that are reasonably designed, implemented, and enforced to be effective in preventing and detecting criminal conduct, as well as civil fraud and abuse as defined by the applicable state and federal standards, in the provision of, and billing for, the services offered by New River Valley Community Services.

A part of Corporate Compliance requires prevention and detection of illegal or unethical activity and/or fraud, waste and abuse in the provision of services by New River Valley Community Services.

What is fraud and abuse? Fraud is an intentional deception or misrepresentation that someone makes, knowing it is false, that could result in unauthorized payment. It is important to remember that the attempt itself is fraud, whether successful or not. Abuse involves actions that are inconsistent with accepted, sound medical, business, or fiscal practices. Abuse directly or indirectly results in unnecessary costs to the program through improper payments. The main difference between fraud and abuse is the person’s intent.

Employees have a duty to report suspected or perceived misconduct on the part of any NRVCS staff. Failure to report a suspected violation could be the basis for disciplinary action against an employee.

Retaliation or reprisal against employees who report a perceived problem as they understand it to be true, without fabrication, is strictly prohibited.

An employee who commits or condones any form of retaliation may be subjected to disciplinary action.

Employees are not exempt from the consequences of their own misconduct as the result of self-reporting. However, self-reporting is looked at favorably.

Reports alleging illegal or unethical activity are investigated by the Corporate Compliance Manager. All employees are required to cooperate in the investigation of alleged violations.

Investigation of a suspected violation shall not occur without consultation with and direction from the Corporate Compliance Manager.

Reports of perceived problems related to Corporate Compliance are confidential and may be made anonymously to the Corporate Compliance Manager which includes but is not limited to interoffice mail.

The Corporate Compliance Manager reports findings and makes recommendations regarding investigations of reported misconduct.

The Corporate Compliance Manager has an open line of communication with the Board of Directors, the Executive Director, and the Administrative Team for purposes of reporting on investigations of alleged violations.

What should you do if you’re faced with a questionable situation? Rely upon your good judgment and common sense every day to solve problems and situations. Ask yourself the following questions: Is this action legal? Am I being honest? How could my actions affect NRVCS and the clients it serves? How would I advise a friend or family member under these circumstances? How will I feel about myself afterwards? How would it look on television or in the newspaper? Give examples of potential fraud, abuse or ethics violations.

Our goal is to foster a work environment where we all can feel proud of the work we do and the resources we are responsible for allowing us to provide the best service to the clients of NRVCS.

Reporting If you have questions regarding compliance issues, need to report discrepancies in providing and billing for services or other fraud, waste or abuse of agency or client property or resources, please contact: Compliance@nrvcs.org or Call Leslie Sharp, NRVCS Corporate Compliance Manager At 540-961-8355

Important Reminders Always feel free to talk with your immediate supervisor first if you feel comfortable in doing so. Human Rights issues should always be reported to the NRVCS Client Rights Advocate. Equal Employment, Harassment and personnel issues should be directed to Human Resources.