Eagle Rising Catholic Ministry Corporate Compliance Plan
Policy
It has been and continues to be the policy of Eagle Rising Catholic Ministry (ERCM),
sometimes referred to hereinafter as "Eagle Rising Catholic Ministry", “ERCM”,
"Eagle Rising", “Ministry”, or “the Ministry”, to comply with all applicable federal, state,
and local laws and regulations, and payer requirements, and to adhere to the
Ministry;s code of conduct as contained ournrecruitment handbook. We have always
been and remain committed to our responsibility to conduct our business affairs with
integrity based on sound ethical and moral standards. We will hold our staff,
volunteers, members, participants, agents and vendors to these same standards.
Mission, Philosophy and Code of Conduct
ERCM is a nonprofit 501(c)(3) organization serving as a Catholic ministry of charity
and service, dedicated to providing help to youth in need, hope to those in despair
and inspiration for others to follow. We are motivated by the Gospel of Jesus Christ to
cherish, preserve and uphold the sacredness and dignity of all human life, foster
charity and embody Catholic teaching as we act to serve our youth to become Christ-
centered Leaders in our community
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We uphold the dignity of every individual we serve, regardless of race, religion, creed,
or life circumstances. Our commitment is to ensure that all aspects of members and
participants we serve align with our mission statement, policies, professional
standards, and legal regulations. As a Catholic ministry we provide a supportive
community for young people to deepen their relationship with God, develop their faith,
and build meaningful relationships with peers and mentors, through Bible studies,
retreats, service projects, and social events. We strive to spread the Good News and
serve others in the name of Christ. Our mission is to provide spiritual nourishment,
support, and resources to those in need, fostering a deeper connection with God and
with one another.
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Our Board of Directors, volunteers and staff are prohibited from engaging in any
behavior that conflicts with the best interests of ERCM or even gives the perception
of such a conflict. ERCM is unwavering in its dedication to providing consistently
high-quality care and services. Our services are delivered with cultural competence, a
commitment to conflict-free practices, a person-centered approach, and a problem-
focused perspective. Every member of the ERCM team is bound by all relevant laws
and ERCM policies governing the delivery of care and services. Respect is
paramount, and we expect all participants, members, Board of Directors, supervisors,
and supervised staff to be treated with respect and dignity accordingly.
When any person knows or reasonably suspects that the expectations above have
not been met, this must be reported to immediate supervisors, the Compliance Officer
(CO) or the Director of Human Resources, so each situation may be appropriately
dealt with.
Compliance Program Oversight
ERCM has a designated Compliance Officer (CO). The CO is directly obligated to
serve the best interests of ERCM, our members, participants, staff and volunteers.
Responsibilities of the CO include but are not limited to:
• Overseeing and monitoring the implementation of the compliance program
• Directing Ministry internal audits established to monitor effectiveness of
compliance standards
• Providing guidance to management, medical/clinical program personnel, and
individual departments regarding policies, procedures and governmental laws,
rules, and regulations
• Maintaining a reporting system (hotline) and responding to concerns,
complaints, and questions related to the compliance program
• Acting as a leader regarding regulatory compliance issues
• Investigating and acting on issues related to compliance
• Coordinating internal investigations and implementing corrective actions
For the purposes of this Compliance Plan, the role of the ERCM Compliance
Committee is to advise and assist the Compliance Officer in the implementation of the
Compliance Plan. Compliance issues are reported by the Compliance Officer to the
Compliance Committee, where appropriate.
Exclusion Screening and Credentialing:
Any member, volunteer, staff or prospective staff who holds, or intends to hold, a
position with substantial discretionary authority for ERCM is required to disclose any
name changes and any involvement in non-compliant activities. In addition, ERCM
performs reasonable inquiries into the background of such applicants, contractors
and vendors.
The following organizations may be queried with respect to potential staff, contractors
and vendors:
a) The Federal System for Award Management available on the SAM
website: http://www.sam.gov/
b) U. S. Department of Health and Human Services,Office of Inspector General
(OIG)’s List of Excluded Individuals andEntities (LEIE) available on the
website: http://exclusions.oig.hhs.gov/
c) Office of the New York State Attorney General https://ag.ny.gov
d) New York State Staff Exclusion List(SEL) https://www.justicecenter.ny.gov/staff-exclusion-list
Education and Training
Education and training are critical elements of the Compliance Plan. Compliance
policies and standards will be communicated to all staff and volunteers through
required participation in training programs. All personnel shall participate in training
and/or discussion on the topics identified below:
• History and background of Corporate Compliance
• Applicable laws and regulations
• Legal principles regarding compliance and responsibilities related thereto
• Duty to report misconduct.
As part of their orientation, each staff, volunteer and contractor shall receive a written
copy of the Compliance Plan, laws and regulations that affect their position. All
education and training relating to the Compliance Plan will be verified by attendance
and a signed acknowledgement of receipt of the Compliance Plan and standards.
Attendance at compliance training sessions is mandatory and is a condition of
continued partcipation with ERCM.
Effective Confidential Communications
Open lines of communication between the CO and each staff, volunteer, participant,
member and agent are subject to this Plan (including all ERCM participants,
members and their guardians) are essential to the success of our Compliance
Program.
Both staff as well as participants and interested parties have the right to report any
concerns of fraud, waste, abuse, and neglect. This includes any misuse or overuse of
Medicaid resources as well as concerns regarding the behavior of ERCM staff toward
or regarding participants. The ERCM CO can be contacted by email, phone, or mail
to discuss or report any concern or grievance. If a report would like to be made
anonymously, please utilize an anonymous email address or phone number or mail
an anonymous letter to the address provided below.
Detection and Response
The Compliance Officer shall initially investigate all reports made and together with
the Compliance Committee shall determine whether there is any basis to suspect that
a violation of the Compliance Plan has occurred.
If it is determined that a violation may have occurred, the Compliance Officer and the
Compliance Committee will conduct amore detailed investigation. This investigation
may include, but is not limited to, the following:
• Interviews with individuals having knowledge of the facts alleged
• A review of documents
• Legal research and contact with governmental agencies for the purpose of
clarification
If advice is sought from a governmental agency, the request and any written or oral
response shall be fully documented.
At the conclusion of an investigation, a report shall be issued, summarizing the
findings, conclusions, and recommendations and an opinion as to whether a violation
of the law has occurred.
Regardless of whether a report is made to a governmental agency, the Compliance
Officer shall maintain a record of the investigation, including copies of all pertinent
documentation. This record will be considered confidential and privileged and will not
be released without the approval of the Compliance Committee or legal counsel.
Whistleblower Provisions and Protections
The False Claims Act provides protection to qui tam relators who are discharged,
demoted, suspended, threatened, harassed, or inany other manner discriminated
against in the terms and conditions of their inclusion at ERCM as a result of their
furtherance of an action under the False ClaimsAct.
ERCM will not take any retaliatory action against any staff if the staff discloses
information about the Ministry's policies, practices or activities to a regulatory, law
enforcement or other similar agency or public official. Protected disclosures are
those that assert that the Ministry is in violation of a law that creates a substantial and
specific danger to the public health and safety or which constitutes healthcare fraud
under the law or that assert that, in good faith, the staff believes constitute improper
quality of client care.
Contact Information
Promptly report any issues, concerns, violations or suspected violations to the
Compliance Officer utilizing the contact information below.
Compliance Officer: Kimberly Croker
Compliance Hotline: 347 243 9934
Compliance Email: kcroker@eaglerisingnyc.org
Compliance Drop Box:
Kimberly Croker,
Compliance Officer
4711 Church Ave
Brooklyn, Ny 11203