Corporate Compliance

Finger Lakes Health has a reputation for conducting itself in accordance with the highest level of business and community ethics and in compliance with applicable governing laws.  The Board of Directors and management have adopted a detailed Corporate Compliance Program (Program) to establish a framework in accordance with applicable laws and regulations to promote and assure ethical business practice and provide guidance and protocol to each employee and contactor regarding his or her conduct.  The Program documents which include the Corporate Compliance Program document, Reporting Requirements/Code of Ethics & Business Conduct, Whistleblower Policy/Non-Retaliation/Non-Intimidation for Good Faith Participation in the Compliance Program, Compliance with Applicable Federal and State False Claims Acts: Overview of the Laws Regarding False Claims and Whistleblower Protections are available for review on the Health System's website at flhealth.org.

The Program documents include Finger Lakes Health’s policies and procedures and describe the organization's expectations regarding compliance.  The Health System is also committed to developing and maintaining internal controls that will prevent or detect errors.  To accomplish this goal, reviews and audits of areas of concern identified internally as well as by the Office of Inspector General (OIG), Office of Medicaid Inspector General (OMIG), Department of Justice (DOJ), state agencies and professional organizations are conducted.

It is important that all employees and individuals associated with Finger Lakes Health:

1. comply with the standards contained in the Program
2. immediately report any suspected violations
3. assist compliance personnel in investigating allegations of wrongdoing. 

While there will be no retaliation on those who raise issues, failure to observe the provisions of the Program and associated policies and procedures of the Health System can result in serious consequences.

The Program's goals are to:

1. prevent the occurrence of unethical or unlawful behavior
2. halt such behavior as soon as reasonably possible after discovery
3. make restitution
4. educate individuals appropriately

Individuals encountering situations not specifically addressed in the Program should apply the overall philosophy and concepts of the Program to the situation along with highest ethical standards.  Questions or concerns should be reported to your immediate supervisor if you are a Finger Lakes Health employee, your FLH contact, or may be made to the Corporate Compliance Officer (315-787-4023) or through the Compliance Line (315-789-4791).  

Employees are trained upon hire during their orientation and re-educated as part of their mandatory annual training that Finger Lakes Health does not permit any form of retaliation or intimidation regarding the reporting of compliance situations or concerns.  Furthermore, Finger Lakes Health will promptly investigate reported concerns and take appropriate action for correction and reporting.