Gateway Community Industries, Inc.

Corporate Compliance Policy

Updated December 31, 2016

Approved by the Board of Directors February22, 2017

 

INTRODUCTION

In support of the Gateway Community Industries, Inc. mission, vision, and core values, and to comply with all Federal, State and Local healthcare regulations and mandates, Gateway and its affiliated entities have adopted this Corporate Compliance Program to ensure our organization provides services to our community with integrity and without waste or fraud.

The law requires all providers to comply with standards and regulations and set organization wide standards to define, communicate and monitor compliance with these standards.

Our Plan documents the systems which are in place to insure efficient, legal and ethical standards.  Several key components of the Plan are set forth below and are noted to ensure that we have programs in place to exercise due diligence to prevent, detect, correct and eliminate non-adherence to Standards, Policies and Procedures by our employees or our agents.

Key components of the Plan include the following company wide standards:

  • Compliance with all Policies and Procedures
  • Appropriate authority and oversight
  • Communication of the Corporate Compliance Plan; expected code of conduct, education, training, and communication of updates
  • A system for both confidential reporting and investigation of Compliance Concerns
  • Enforcement and Discipline
  • Internal controls including: methods for audits, ongoing monitoring of practices, identifying concerns, correction and measuring results for verification in a timely and effective manner
  • Documentation and Reporting
  • Whistleblower Protections

Adhering to and Safeguarding the Plan

This plan has been prepared with the assistance of the executive team, directors, and staff of Gateway through the efforts of the Compliance Team (and is adopted by the Board of Directors). Gateway shall make every effort to assure compliance with the law given limitations imposed by practical and commercial realities.

 

Authority and Oversight

Ultimate accountability and oversight for Corporate Compliance lies with the Board of Directors and the President & Chief Executive Officer (CEO).  Responsibility for the orientation of all initiates lies with the CEO.  The Board of Directors is committed to providing both the human and financial resources necessary to develop, implement, support, maintain, and monitor an ethical environment, which complies with all Federal, State, and Local Law.  The acceptance of this plan and the designation of a Chief Quality and Compliance Officer (CQCO) evidence this commitment.

The Chief Quality and Compliance Officer is a specific individual within high-level personnel of the organization who is responsible for operational oversight and implementation of Gateway’s compliance activities and reports directly to the President and CEO as well as the Board of Directors.

Additionally, the CQCO can request to meet directly with the Board of Directors in an Executive Session.

The CQCO communicates compliance activities to the Board of Directors on a monthly basis. Additionally, the CQCO presents a comprehensive compliance report to the Quality, Audit, and Compliance subcommittee of the Board of Directors on a quarterly basis.

In order for the CQCO to carry out his/her duties, he/she shall have access and authority to review all documentation relevant to compliance activities as well as seek the advice of outside legal counsel when appropriate. This documentation includes but is not limited to:

  • Policies and Procedures
  • Service RecipientRecords
  • Billing Records
  • Contracts, Service Agreements, Joint Ventures, Leases
  • Any related documentation