Compliance. Governance. Doing Business with Hometown.
Hometown Health Centers is a Federally Qualified Health Center (FQHC) incorporated under New York State’s not-for-profit law. It provides quality healthcare services without regard to the patient’s ability to pay. As part of the Medicare and Medicaid programs, Hometown maintains robust compliance standards to identify and stamp-out fraud, waste, and abuse.
Anyone affiliated with Hometown Health Centers (Hometown) is expected to participate in its Compliance Program. Contractors, Board Members, and Staff (including interns and students) are required to promptly report concerns about fraud, waste, and abuse. Patients are also strongly encouraged to report concerns. See contact information below.
Anyone reporting concerns is protected under State and Federal whistleblower protections. If you make a report, you cannot: lose a contract; be fired from your job; demoted or denied a work promotion; be removed as a board director; or denied care as a patient for making a report.
Hometown’s Compliance Program is designed to meet obligations under Federal Law, New York State Social Services Law, and New York Code of Rules and Regulations. In addition, updating the Program to include the latest healthcare industry best practices is ongoing. See below for citations to some of the applicable Federal and State Laws and Regulations.
Doing Business with Hometown
Hometown sometimes requires quality services or products at a fair price from carefully screened contractors. They are checked on Exclusion Lists, their business reputation is evaluated, and a final selection is based on a competitive bidding process if applicable.
As noted, contractors are expected to comply with Hometown’s Compliance Program or have a comparable program in place to aggressively combat fraud, waste, and abuse.
Hometown’s Compliance Officer (contact information listed below) must be notified if concerns arise regarding impropriety, unethical conduct, or violations to State and Federal Law and Regulations.
In addition to meeting some of the compliance standards outlined above, vendors may be required to collaborate with contract auditing, provide evidence of up-to-date cybersecurity protocols, share appropriate training documentation, assist in any State or Federal investigation, and give System and Organization Control Reports (SOC-1 or SOC-2) regarding security, financial controls, processing integrity, and privacy/confidentiality upon request. Also, contractors must receive written authorization from Hometown before any assignment or subcontracting is allowed. On the rare occasion subcontractors are permitted, they too will be required to meet compliance standards to identify and stop fraud, waste, and abuse.
Vendors receive an annual letter reminding them of obligations to either abide by Hometown’s Compliance Program or to have one in place meeting best practices for compliance. These practices should include training.
All Staff, vendors, Board Members, job applicants, prospective Board Members, and anyone seeking to do business with Hometown Health Centers shall be regularly checked on State and Federal Exclusion Lists.
Persons or businesses on Exclusion Lists are those who have committed Medicare or Medicaid fraud.
It is illegal for any vendor or consultant listed on a State or Federal Exclusion List to do business with an entity participating in the Medicare, Medicaid, or other State or Federal healthcare programs. This also applies to employees and Board Members.
Hometown Health Centers is classified as a “Federal Public Health Service” employee. It receives some of its funding from the US Department of Health and Human Services (HHS). It has Federal Public Health Service (PHS) deemed status regarding certain health or health-related claims, including medical malpractice claims. Hometown employees and some persons affiliated with it are covered under the Federal Tort Claims Act (FTCA). For further information please visit:
Important Hometown Documents
Board Bylaws – Hometown Health Centers is a Federally Quality Health Center (FQHC). As a not-for-profit community health center, it is governed with Bylaws and State and Federal Laws as enforced by an elected, volunteer Board of Directors.
Code of Conduct – The Code is part of Hometown’s overall Compliance Program. It encompasses principles of ethics, integrity, character, professionalism, and compliant behavior.
Board Resolution – The Resolution is example of commitment by Hometown’s Board of Directors to compliance which includes, but is not limited to identifying and stopping fraud, waste, and abuse under State and Federal law. Hometown’s Board and the Staff are dedicated to being good stewards of resources while providing quality, accessible care.
Mission & Values – As a Federally Qualified Health Center (FQHC) or community health center, Hometown provides access to quality healthcare to an underserved population. It’s Mission and Values reflects its commitment to patients and the community while being good stewards of resources.
Corporate Compliance Manual – The Manual provides Staff, vendors, Board Members, and anyone affiliated with Hometown a resource to help meet the requirements of the Compliance Program. It is reviewed and approved annually by the Board of Directors.
Important State and Federal Laws and Regulations
• Federal False Claims Act (31 USC §§ 3729-3733)
• Federal Anti-Kickback Statute ( 42 USC § 1320a-7b(b))
• Federal Physician Self-Referral Law (42 USC §1395nn)
• Federal Exclusion Statute (42 USC §1320a-7)
• Federal Deficit Reduction Act (42 USC §1396a(a)(68))
• Federal Patient Protection and Affordable Care Act ( 42 USC §18001)
• New York False Claims Act (State Finance Law §§ 187-194)
• New York Social Services Law (§ 363-d – Effective Compliance Program)
• New York Social Services Law (§ 145-b – False Statements)
• New York Social Services Law (§ 145-c, 366-b – Penalties, Sanctions)
• New York Penal Law Article 175 (False Written Statements)
• New York Penal Law Article 176 (Insurance Fraud)
• New York Penal law Article 177 (Healthcare Fraud)
• Part 521, Title 18, of the New York State Codes, Rules, and Regulations
Compliance Officer Contact to Report Concerns about Fraud, Waste, and Abuse
Paul Jesep, Compliance Officer
Hometown Health Centers
1044 State Street
Schenectady, NY 12065
Compliance Hotline (*67) 518-688-3460 to leave an anonymous message. The Hotline is available 24/7.
If you’re a patient and see something suspicious, you’re strongly encouraged to report it. Patients cannot be denied affordable and timely access to quality care for reporting a concern. It is illegal.
Concerns also can be reported to the State and/or Federal Office of Medicaid Inspector General (OMIG) or other appropriate government agencies.
"SEE SOMETHING? SAY SOMETHING."