Compliance

Siddharth Services maintains zero tolerance for fraud, waste and abuse involving Medicaid, Medicare, agency resources or the services provided to individuals.

Fraud is an intentional act of deception or misrepresentation intended to obtain an unauthorized payment, benefit or advantage.

Waste is the careless, inefficient or unnecessary use of government or agency resources, even when there is no intent to deceive.

Abuse includes practices that are inconsistent with appropriate fiscal, business, service or professional standards and that result in unnecessary costs or misuse of resources.

Examples may include:

• Billing for services not rendered
• Providing or billing for unnecessary services
• Submitting inaccurate or altered service documentation
• Improperly coding or representing a service
• Duplicate billing
• Misusing agency or government-funded resources
• Concealing a billing error or overpayment
• Employing or contracting with an individual excluded from participation in a government-funded healthcare program

Prevention is everyone’s responsibility. Employees, contractors, vendors and providers are expected to:

• Maintain complete, accurate and timely records
• Follow all service authorization and billing requirements
• Use agency and public resources responsibly
• Complete required compliance training
• Cooperate with monitoring, audits and investigations
• Immediately report suspected fraud, waste, abuse or other misconduct

Siddharth Services reviews reported concerns and takes appropriate corrective action when necessary. Corrective measures may include additional training, improved internal controls, repayment of improperly received funds, disciplinary action, contract termination or referral to the appropriate authorities.

Reporting Concerns and Protection from Retaliation

Employees and contractors are expected to promptly report suspected violations to their supervisor, Human Resources, executive management or the Compliance Officer. Individuals making reports are not responsible for investigating the matter or determining whether a violation occurred. Investigations are coordinated by authorized compliance and management personnel.

Good-faith reports are handled as confidentially as practical and permitted by law. Siddharth Services prohibits retaliation against anyone who raises a legitimate concern, participates in an investigation or assists with a compliance review. Retaliation may include termination, demotion, reduced compensation, unfavorable assignments, threats, harassment or discrimination.

The federal False Claims Act protects government-funded programs, including Medicaid and Medicare, from fraudulent or inaccurate claims. Siddharth Services strictly prohibits knowingly submitting, causing the submission of, or using false information to support a claim for payment. Reckless disregard for the accuracy of a claim or its supporting records may also violate the law.

All services billed to a government-funded program must be authorized, medically or programmatically appropriate, delivered as documented and supported by complete, timely and accurate records. Examples of prohibited practices include:

• Billing for services that were not provided
• Billing for the same service more than once
• Falsifying attendance, service notes or other documentation
• Misrepresenting the type, duration or provider of a service
• Altering records to support payment
• Billing for services that are not properly authorized or documented
• Knowingly retaining an identified overpayment

Employees must use only their own signature when certifying documentation and may not falsify, copy or reuse another person’s signature. Electronic signatures must be used only with appropriate authorization and through approved, secure methods.

Siddharth Services maintains billing controls, documentation standards, training and review processes to promote the accuracy and completeness of claims. False claims may result in repayment obligations, civil or criminal penalties, exclusion from government healthcare programs, disciplinary action or termination of employment or contract.

Siddharth Services respects the privacy, dignity and confidentiality of every individual and family we serve. We follow the Health Insurance Portability and Accountability Act and other applicable privacy requirements when creating, accessing, storing, using or sharing protected health information.

Protected health information includes information that identifies an individual and relates to their health, services or care, including:

• Names, addresses and dates of birth
• Medical histories and diagnoses
• Treatment and medication information
• Service agreements and assessments
• Behavioral and safety plans
• Financial or benefit information
• Communications with healthcare professionals
• Information about an individual’s services or support needs

Employees may access or share confidential information only when authorized and necessary to perform their assigned responsibilities. When information must be shared, only the minimum information necessary for the authorized purpose should be disclosed.

Before sharing information with healthcare professionals, behaviorists, case managers, pharmacies, community organizations or other outside parties, employees must verify that a valid authorization or release of information is on file and covers the intended recipient and purpose.

Employees are expected to:

• Store paper and electronic records securely
• Lock computers and log out of systems when unattended
• Use strong passwords and never share login credentials
• Verify recipients before sending confidential information
• Password-protect documents containing client information
• Send document passwords separately from the documents
• Keep paper records locked and out of public view
• Properly shred or destroy sensitive documents
• Discuss client information only in private settings
• Report suspected privacy breaches immediately

Employees may not discuss individuals in hallways, kitchens, public areas or other locations where unauthorized people may overhear the conversation. Confidential information must not be left unattended, sent to an unauthorized recipient or disclosed through personal email, text messages or unapproved communication systems.

Social Media, Photographs and Recordings

Photographs or videos involving an individual may be taken or shared only when the appropriate client or guardian authorization is current and on file. Any use must remain within the specific purpose covered by that authorization.

Even when consent has been provided, employees must protect the individual’s dignity and privacy. Posts must not contain confidential, identifying, medical, behavioral or other sensitive information. Recordings used for documentation or training must be stored securely and destroyed when they are no longer required.

Unauthorized disclosure of protected or confidential information, including disclosure through social media, may result in disciplinary action, termination, legal penalties or other corrective measures.

Reporting a Privacy Concern

Any suspected HIPAA violation, loss of confidential information or unauthorized disclosure must be reported immediately. Examples include sending information to the wrong recipient, sharing information without a valid authorization, discussing an individual in a public area, posting protected information online or leaving records or computer systems unsecured.

Prompt reporting allows Siddharth Services to protect the affected individual, evaluate the incident, comply with applicable notification requirements and take steps to prevent recurrence.

Siddharth Services is committed to providing a safe and healthy environment for employees, visitors and the individuals we support. Our workplace safety practices are guided by applicable Occupational Safety and Health Administration requirements, state laws and agency procedures.

Employees have the right to:

• Work in a safe environment
• Receive training regarding workplace hazards
• Report unsafe conditions without punishment
• Receive appropriate protective equipment when required
• Raise safety concerns or request further review

Employees are responsible for following safety procedures, participating in required training, using protective equipment appropriately and remaining attentive to potential risks. Common workplace risks may include slips, trips and falls, unsafe equipment, fire hazards, infection exposure, environmental hazards and unsafe work practices.

All employees must:

• Follow established health and safety procedures
• Use required personal protective equipment
• Promptly report hazards or unsafe conditions
• Report workplace accidents, illnesses and injuries immediately
• Cooperate with accident reviews and corrective actions
• Follow building access, visitor and security requirements
• Help maintain safe, orderly and hazard-free work areas

Work-related injuries, regardless of severity, must be reported immediately to a supervisor or Human Resources. Prompt reporting allows the agency to arrange appropriate assistance, complete required documentation, address hazards and prevent similar incidents.

Safety is a shared responsibility. Through training, hazard awareness, prompt reporting and corrective action, Siddharth Services works to prevent injuries and protect the well-being of its employees and the people it supports.