Corporate Compliance Program

Agencies and departments of the U.S. Government have identified a number of instances of fraud, abuse, and waste in federally-funded health care programs including Medicare and Medicaid. The Board of Trustees of NYU Hospitals Center (NYUHC) and the New York University School of Medicine Foundation (NYUSoM), together with the “Medical Center” or (NYULMC), as well as Medical Center administration and management, recognize the seriousness of the issues raised by the Government and recognize that failure to comply with the applicable laws and regulations could threaten the Medical Center’s continuing participation in these health care programs.

The Boards, therefore, have directed that the Medical Center undertake an integrity program in order to continue the institution’s commitment to high standards of conduct, honesty, and reliability in its business practices. This integrity program is called a Compliance Program (the “Program”). The primary purpose of the Program is to make a sincere effort to prevent, detect, and correct any fraud, abuse, or waste in the Medical Center in connection with federally funded health care programs and private health plans. In order to accomplish this goal, the program strives to create a culture that promotes understanding of and adherence to applicable federal, state, and local laws and regulations. To be effective the Compliance Program should be a continuously evolving effort to meet the changing regulatory landscape. NYU Langone Medical Center believes that an effective compliance program must have seven basic elements, as first described by the U.S. Sentencing Commission Guidelines:

  1. Written policies and procedures,
  2. A designated compliance officer and a compliance committee,
  3. Effective training and education,
  4. Effective lines of communication,
  5. Standards enforced through well-publicized disciplinary guidelines,
  6. Auditing and monitoring, and
  7. Responses to detected offenses and corrective action plans.

The Compliance Program describes these seven basic elements as they fit within NYULMC and details the fundamental principles, values, and operational framework for compliance within the institution. It articulates the organization’s commitment to compliance and the goals to which the organization strives. Important compliance documents that help to establish and continue to influence, the Compliance Program include, but are not limited to The 1998 OIG Hospital Compliance Guidance, the 2005 OIG Supplemental Hospital Compliance Guidance, the 2000 OIG Compliance Guidance for Physician Practices, the OIG 2014 Work Plan, the NYS OMIG Compliance Regulations, the NYS OMIG 2014-2015 Work Plan, and the NYULMC Internal Audit, Compliance & Enterprise Risk Management 2011-2012 Work Plan.