NEW PASSAGES’ COMPLIANCE REPORTING FACTS  

Q.        Who is to report violations of company policy or law? 

A.        All personnel are required to promptly report all known or suspected violations of wrongdoing.  You may report violations to: 

• Management
• Leadership
• Corporate Compliance Designee
• NEW PASSAGES’ Compliance Line 

Management staff will assist you in reporting violations and will facilitate getting you appropriate advice should you seek their assistance.  If you feel uncomfortable with the above, personnel should report concerns directly to the NEW PASSAGES’ Compliance Line. 

Q.        What is the NEW PASSAGES’ Compliance Line? 

A.        The NEW PASSAGES’ Compliance Line is a phone number, (248) 253-0534, for which you may report in a convenient and confidential way violations of law or NEW PASSAGES’ policy. In order to provide excellent service, the NEW PASSAGES’ Compliance Line is available 24 hours a day, 365 days a year. 

You can also make reports in writing by sending information to Corporate Compliance Designee c/o NEW PASSAGES at 70 Lafayette, Pontiac, Michigan 48342. 

Q.        What types of wrong doing should be reported? 

A.        Report concerns or report suspected violations related to: 

• Bribes and Kickbacks
• Medicare/Medicaid Fraud and Abuse
• Conflicts of Interest
• Fraudulent Billing
• Privacy of Personnel and Patient Records
• Confidentiality of NEW PASSAGES’ Information
• Alteration or Destruction of NEW PASSAGES’ Records or Financial Documents
• Potential Criminal Violations
• Other Violations of law or NEW PASSAGES’ Policy
   

Q.        What concerns should not be referred to the NEW PASSAGES’ Compliance Line? 

A.        The Compliance Line is NOT to be used to report an immediate threat to person, property or environment. These conditions must immediately be reported as outlined in NEW PASSAGES’ client rights and health & safety policies and procedures. 

Q.        Do I have to provide my name? 

A.        No. You may give your name if you desire, but it is not required. There are no recorders on the telephone line or any devices that can identify or trace the number from which you are calling.  NEW PASSAGES’ is interested in resolving your concerns, not identifying the person reporting the issue. 

Q.        How does NEW PASSAGES’ Compliance Line work? 

A.        The call will be directed to the Corporate Compliance Designee.   The Designee will review the message and make the necessary inquiries.  The Designee will report review activities and review results to the New Passages’ Leadership Team.  

Q.        Are callers limited in the number of times they can report? 

A.        No. You may call as often as you wish to report information. 

Q.        Will there be a review process after each report is made? 

A.        Each report is taken seriously. Whether there is a review depends on a number of factors including the information provided, the details, docu­mentation, if any, and NEW PASSAGES’ policy.  

Q.    What protection is afforded to me when I call the NEW PASSAGES’ Compliance Line? 

A.     Under law and our own policy, NEW PASSAGES’ will not make reprisals (retaliation, retribution, or harassment) against personnel who furnish good faith reports of inappropriate activities.  Confidentiality regarding personnel concerns and problems will be maintained at all times, insofar as legal and practical, informing only those personnel who have a need to know.         

Personnel cannot exempt themselves from the consequences of wrongdoing by self-reporting, although self-reporting may be taken into account in determining the appropriate course of action.