Compliance Plan

Block Institute (also referred to as the Organization) is committed to providing services of the highest quality and to being in full compliance with all federal, state, and local laws and regulations. As part of that commitment, Block Institute has adopted this Compliance Plan and Code of Conduct as the basis of its efforts in fostering an organizational culture that promotes responsible and honest conduct, transparency in all business transactions, and adherence to the laws and regulations of the government oversight agencies and funders.

1. Policy

It has been and continues to be the policy of Block Institute (sometimes referred to as the Organization) to comply with all applicable Federal, State, and local laws and regulations, and payer requirements. It is also the Organization’s policy to facilitate the prevention of improper or illegal activities, to provide mechanisms to detect any violations of laws and regulations and work to prevent, detect, and investigate issues related to fraud, waste, and abuse. To ensure this, Block Institute has established this Compliance Plan and commits to maintaining an effective Compliance Program.

1. Commitment

Block Institute is, and will remain, committed to our responsibility to conduct our business affairs with integrity based on sound ethical and moral standards. We will hold all Affected Individuals to these same standards.

Block Institute is committed to maintaining and measuring the effectiveness of our Compliance Program and Code of Conduct through monitoring and auditing systems reasonably designed to detect noncompliance by all persons who are affected by the required provider’s risk areas including the required provider’s employees, the Chief Executive and other senior administrators, managers, contractors, agents, subcontractors, independent contractors, and governing body and corporate officers.

Block Institute is committed to the prevention of improper or illegal activities and to provide mechanisms to detect noncompliance, including but not limited to, any violations of laws and regulations, healthcare program requirements, the Code of Conduct and Block Institute’s policies and procedures. The Organization is committed to the prompt investigation and resolution of reported or detected noncompliance.

Block Institute is committed to the performance of regular, periodic compliance audits by internal and/or external auditors who have expertise in Federal and State healthcare statutes, regulations, and healthcare program requirements.

1. Responsibility

All persons who are affected by the required provider’s risk areas including the required provider’s employees, the Chief Executive and other senior administrators, managers, contractors, agents, subcontractors, independent contractors, and governing body and corporate officers shall acknowledge that it is their responsibility to report any instances of suspected or known noncompliance to their immediate supervisor, the Chief Executive, or the Compliance Officer without fear of retaliation, retribution, or intimidation. Failure to report known noncompliance or making reports that are not in good faith will be grounds for disciplinary action, up to and including termination of employment, contract, assignment, or appointment. Reports related to harassment or other workplace-oriented issues will be referred to Human Resources.

1. Policies and Procedures and Code of Conduct

Block Institute will communicate its compliance standards and policies through required training and communication initiatives and distribution of this Compliance Plan and the Code of Conduct to all Affected Individuals.

1. Compliance Officer and Compliance Committee

Block Institute has appointed a Compliance Officer who is responsible for the overall operation of the Compliance Program. A Compliance Committee works with the Compliance Officer to implement and maintain an effective Compliance Program.

1. Discipline/Enforcement

This Compliance Plan will be consistently enforced through appropriate disciplinary mechanisms including, if appropriate, discipline of Affected Individuals responsible for failure to detect and/or report noncompliance.

1. Organization Response

Detected noncompliance, discovered through any mechanism, such as compliance auditing procedures and/or confidential reporting of noncompliance, will be responded to in an expedient manner. Block Institute is dedicated to the resolution of such matters and will take all reasonable steps to prevent further similar violations, including any necessary modifications to the Compliance Plan and policies and procedures.

1. Due Diligence

Block Institute will, at all times, exercise due diligence with regard to background and professional license investigations for all Affected Individuals.

1. Non-Retaliation, Non-Intimidation, and Whistleblower Protections

Block Institute will not take any retaliatory action against an Affected Individual who, in good faith, reports actual or suspected noncompliance or illegal activities or for good faith participation in the Compliance Program.

Block Institute will not take any retaliatory action against an employee if the employee discloses certain information about the Organization’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 Organization is in violation of a law that creates a substantial and specific danger to the public health and safety; or that constitute healthcare fraud under the law; or that assert that the employee, in good faith, believes constitutes improper quality of care.

Reporting and Investigating Compliance Concerns
Block Institute recognizes that a critical aspect of its Compliance Program is the establishment of a culture that promotes prevention, detection, and resolution of instances of conduct that do not conform to Federal and State requirements, the Organization’s ethical and business policies, and fraud, waste, and abuse prevention.

To promote this culture, Block Institute has established processes to encourage effective communication and the reporting of compliance questions, issues, concerns, or events that will result in a thorough investigation and appropriate remedial actions.

What Should I Report?

Any known or suspected non-compliance or wrongdoing, such as:

1. - Unethical behavior or activities
  - Illegal behavior or activities
  - Violations of the Code of Conduct or the Compliance Program
  - Violations of laws and regulations
  - Violations of Block Institute's Policies and Procedures
  - Falsification of records or documents
  - Improper acts in the delivery or billing of services
    Suspected fraud, waste, or abuse
  - Any misuse or misappropriation of Block Institute’s funds, information, equipment, facilities, or other assets/resources
  - Any act of retaliation or intimidation for reporting concerns or participating in an investigation

Who can I report to?

Email: complianceinfo@blockinstitute.org

Compliance Officer:
Christopher Gutierrez
917-275-3650
cgutierrez@blockinstitute.org
376 Bay 44th St, Brooklyn, NY 11214

Executive Director:
Scott L. Barkin
718-906-5415
slbarkin@blockinstitute.org
376 Bay 44th St Brooklyn, NY 11214