1. CORPORATE
COMPLIANCE
Corporate Compliance
Training is designed to
keep you aware of
your role in ensuring
that Bridgeway
continues to act in
accordance with all
standards and
expectations
mandated by law.
Compliance training is
mandatory for all
employees, upon hire,
as needed, and at
least annually
thereafter
August 4, 2014
Prepared by:
Bobby Dillard

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Corporate
Compliance
Bridgeway is committed to maintain a culture which
encourages employee input, questions, and reports of
violations of law, regulation and the code of conduct without
any fear of retaliation. Each report or question offers
employees an opportunity to contribute positively to the
quality of services at Bridgeway. The purpose of this plan is
to ensure that all employees understand their responsibility
to prevent and detect any fraud, waste or abuse within
Bridgeway.
“Ethics and compliance are the
responsibility of all employees of
Bridgeway”

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What Is Corporate
Compliance?
Corporate means: A group of
people acting together – an
organization – made up of
many individuals.Corporate
includes every member – the
entire organization. The
actions of each person,
together, create the actions of
the corporate body.
Compliance means: Acting in
accordance with a set of
standards or expectations
mandated by law

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Why Do We Need
Corporate
Compliance
Training?
We are committed to
providing effective, quality
services to those we serve.
All Bridgeway services must
be accessible, cost
effective, and meet the
needs of our consumers and
our communities .
Corporate Compliance is a
part of how Bridgeway
accomplishes this level of
service
Bridgeway is not some
distant corporate entity
apart from you and your
coworkers.
“Bridgeway isYOU…
…AND me, and
everyone working within
the organization”
Therefore, Corporate
Compliance is required of
everyone in the
organization to maintain
our business of serving our
consumers
“Our consumers are the reason we
are in business”

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Individual
Responsibility
It is YOUR responsibility to
do your job in manner that is
ethical and complies with
the laws and regulations that
govern our work
It is YOUR responsibility to
seek supervisory assistance if
YOU have doubts or are
unclear about staying in
compliance
It is YOUR responsibility to
seek assistance from your
program director, HR
professional, or corporate
compliance officer to stay
compliant if you believe your
supervisor has provided
incorrect guidance
It is YOUR responsibility to
detect, prevent and
report any incidents of
Abuse, Fraud, Harassment,
Waste, Discrimination,
Corporate Malfeasance, or
any other Noncompliance
with applicable regulations,
policies, or procedures
“All Bridgeway employees
must be in compliance
with State and Federal
laws and organizational
Policies and Procedures”
“Corporate Compliance
Depends OnYOU”

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RegulationsAre a
Requirement of
Funding – It’s a Deal!
Before any money can be
paid an agreement/contract
must be signed.
We agree to provide services
as specified in our agreement
in keeping with all applicable
laws and regulations.
They agree to pay ONLY if
all specifications are met and
all laws and regulations are
followed.
“Most of the dollars
received by Bridgeway to
fund services, pay the
mortgage, keep the lights
on, and make payroll
come to us through state
and federal government
sources”

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We Can
Demonstrate
Compliance
Through Providing
Required
Documentation
The Consumer Plan
It must be created by
appropriate individuals
(including the consumer
and/or guardian) and
qualified staff
It must be signed and dated.
It must meet all time
requirements, initially upon
admission, and annually
thereafter. (Annually is
considered to be no more
than 365 days)
It must be reviewed and
modified periodically as
necessary .
The goals should be
written in “I” (first
person)language, from the
consumer’s point of view.
It must be clear that the
consumer was involved in
the development of the
plan.
Progress Notes
All progress notes must be
tied to a goal/objective in
the consumer plan
All progress notes must be
written within 24 hours
of service delivery in
order to ensure accuracy
and quality
Correct codes must always
be used

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What is FRAUD? Fraud is usually considered
to be an act that is
intentionally designed to be
dishonest, deceptive, or
misleading.
But today due to legislation
and ever tighter government
scrutiny even documentation
or billing mistakes are now
considered to be FRAUD.
Current legislation
highlights the
government’s intent to
reduce their deficit,
particularly Medicaid
spending, through denying
payment and imposing
fines upon those who
provide services but fail to
live up to the specifications
of their agreement.
In order to ensure the
uninterrupted payment for
services it is our
responsibility, each
member of Bridgeway, to
understand and follow
the specifications set forth
in our agreements.
“Tighter enforcement means more
money returned to the government
and fewer dollars for service
providers like Bridgeway to deliver
those services”

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Mistakes Can Lead
ToAccusations of
FRAUD
State and federal False
Claims Acts prohibit billing
for services that were never
provided, are not eligible
for billing, incorrectly
coded, or not properly
related to the service plan.
We must, therefore, ensure
the quality and compliance of
every aspect of our services
in order to avoid penalties
.
“Any documentation/billing
mistake can now be considered to
be fraud by the government”

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When Our Request
For Payment is Not
Accepted
If a claim or a bill submitted for services does not meet all
specifications and requirements of the law it can be labeled
as:
Unsubstantiated, Unclaimable, Undocumented or
Fraudulent
Consequences will then occur

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What Can Result If
We Don’t Comply?
Failure by any member of the
Bridgeway organization to
comply with our contracts
and agreements can result in:
Money returned for services
already provided.
Fines
Legal action that can include
forfeiture of the business and
even incarceration
“Any of these
consequences could mean
an end to those services
being provided; an end to
the program providing
those services, or even an
end to the organization,
and therefore, could mean
an end to our jobs and an
end to our ability to help
and serve others”

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The Impact Of
Noncompliance On
the Organization, the
Consumer, and YOU
A loss of financial resources
An inability to pay our bills
A loss of credibility within
our communities
A loss of goodwill with our
consumers
A loss of our ability to serve
those in need.
“The more compliance
mistakes we make the more
money the government can
take back through
investigations and audits”
.

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Ensuring Corporate
Compliance
Clinical staff must deliver
services and document those
services following all
regulations
Consumer plans/reviews
must meet all time frames
prescribed by law
All documentation must
relate to a specific objective
within a current Plan
All progress notes must
relate to the Plan
All documented services
must have been provided
to the consumer
All documentation must be
properly signed, authorized
by appropriate individuals
and dated
All billing must be accurate
and supported by
appropriate documentation
All records must be
complete and maintained
in a manner that is
accessible to appropriate
staff and surveyors
“All staff must be aware of the
regulations and standards applicable
to their area of service”

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Ensuring Corporate
Compliance
Human Resources must
ensure the credibility of all
staff through the initiation of
required criminal background
checks, Nurse Aid Registry
checks, verification of
credentials, and obtaining
proof of insurance
Human Resources must also
monitor that proper hiring
and disciplinary procedures
are occurring
Financial staff must ensure
that correct codes that
specifically reflect the
services delivered are used.
Financial staff must follow
proper procedures when
billing errors are discovered,
Maintenance staff must
ensure that all service
environments adhere to
appropriate building codes,
safety codes, and
accessibility standards
All staff must maintain
their qualifications for their
employment as well as
continue to update their
knowledge and skills
through ongoing
education and training
All staff must understand
their commitment to
corporate compliance
“We are committed to recognizing
and acting upon any shortfall or
error in our service delivery system”

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SomeActions That
YOU Can Take To
Ensure Compliance
Ask for information and
instruction if you do not
understand how to be
compliant in a particular
situation.
Double check your work to
be sure your information is
correct.
Use your creativity to
develop more effective ways
of work!
Understand YOUR
responsibility to report
compliance issues
immediately. Don’t wait for a
crisis to occur!!
Organizations that fail to
be aware of ongoing
compliance issues or
choose to ignore them are
destined at some point to
have these issues pointed
out by surveyors or others
resulting in potentially
devastating
consequences.
It is always best to uncover
these issues, though
painful they may be, and
correct them ourselves
voluntarily before the
correction is mandated
form outside of the
organization.
“It is our intent to be in
compliance at all times”

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Reporting
Noncompliance
Bridgeway believes that its employees are its major resource
in discovering information about compliance within our
organization. The effectiveness of our compliance program
depends on the willingness of employees in all parts, and at
all levels of the organization to step forward, in good faith,
with questions and concerns. We believe strongly that in all of
these cases, resolution of problem behaviors or actions will
result in better service for our consumers. Bridgeway will
ensure that those who have so reported in good faith do not
suffer any retaliation from their peers or supervisors.
To report compliance
issues, contact:
• Your Supervisor
• Your Program Director
• Human Resources
• A Management Officer
• The Compliance Officer
You can report:
In person, by phone, mail, e-mail
Or Phone@309-836-4153

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Bridgeway
encourages
employee questions
and/or reports
We take each report
seriously
It is our intent to make sure
that employees who do
report:
Do not suffer any retaliation
by their peers or supervisors
for their good faith reports
or questions;
Have more than one way to
report questionable behavior
or to ask questions about
compliance
Have the choice of keeping
their names confidential
when making a specific
report for as long as the
organization can reasonably
do so.
“We investigate each report to
determine the extent of the
problem and the corrective
action(s) needed”

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We Pledge To deal openly and honestly
with consumers and their
families, our communities,
third party payers,
government entities, and
auditors
To maintain high standards
of business and ethical
behavior
To hire, train and support
quality staff to provide
excellent services to our
consumers
To provide services
without discrimination
based on disability, sex,
age, race, color or national
origin
To provide services only
with staff that are properly
qualified, licensed and
credentialed
To recognize and act
upon any shortfall or error
in our service delivery
system

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Thank YOU!
WE thank YOU - for YOUR time, YOUR consideration, and
all of YOUR efforts in making Bridgeway the preferred
provider in our communities.
YOUR dedication to providing care in compliance with
regulations and standards ensures the future of Bridgeway
and the people we serve.
“YOU are the face and hands, the
arms and legs, and, yes, the heart
and soul of Bridgeway”