Caz Recovery’s Corporate Compliance

Compliance with rules and regulations around Medicaid is a major obligation for most human services providers. In fact, any organization that bills Medicaid or managed care organizations (MCOs) for services provided are required by law to have a corporate compliance plan in place. We adopted ours in 2017 right before we began providing OASAS’s Rehabilitation element of care at Cazenovia Manor, Madonna House, and Turning Point House.

Caz Recovery went through some major changes between 2014 and 2018, but the conversion to Rehabilitation was possibly the most transformational. It allowed us to start billing Medicaid and MCOs, and this has been a major driver of our recent financial stability. We spent years preparing our agency for the conversion, and we built our Medicaid billing systems and compliance program from the ground up.

This work didn’t just involve writing a compliance plan. As part of the process, we also had to create a role for a Compliance Officer. Jay Swarthout is our Director of Program Development and Evaluation, but he also serves as Caz Recovery’s current Corporate Compliance Officer. Conveniently, Jay has 25 years of experience related to compliance. “In almost every management position that I’ve ever been in over the last 25 years, I’ve had compliance responsibilities,” he said.

Recent & Regular Activities

Earlier this year, we restructured our compliance oversight structure so that we now have a Compliance Committee with Board and Executive Team representation. Together, the group collaborated on updating our compliance plan and a few related policies and procedures. “It’s not just the committee doing compliance,” said Jay. “Everybody who works here is doing compliance.”

Each quarter, Jay and our Compliance Committee audit different activities across the agency. This includes reviewing our vendors to ensure that they aren’t on the Medicaid exclusion lists, checking specific treatment and clinical documentation for completeness, and much more. All new employees receive training on corporate compliance in orientation that reviews the importance of reporting concerns and what fraud, waste, and abuse look like.

Risk & Compliance

Understandably, there are major risks for an organization if it does not take its compliance responsibilities seriously. Providers can face substantial fines and investigations by the New York State Office of the Medicaid Inspector General and Attorney General if evidence of fraud, waste, or abuse by employees is found. The fines can be so serious that they end up crippling organizations. “It’s not pretty,” noted Jay.

Thankfully, Caz Recovery’s compliance oversight of our services and systems is quite strong. “For the size and scope of what our revenue activity is, we have a really good plan,” said Jay. “We’ve done a good job of identifying what our serious risk factors are, and we audit around those in ongoing ways. That really reduces our risk considerably.”