IX. FRAUD AND ABUSE COMPLIANCE POLICY

It is the policy of Western New York Independent Living, Inc. (WNYIL Inc.) to consistently and fully comply with all laws and regulations pertaining to the delivery of and billing for services, which apply to WNYIL Inc. on account of its participation in Medicaid and other government programs.

A. Introduction

WNYIL Inc. has developed this Fraud and Abuse Compliance Policy to be a comprehensive statement of the responsibilities and obligations of all employees regarding submissions for reimbursement to Medicaid, and other government payers for services rendered by WNYIL Inc. In addition, this policy is intended to apply to business arrangements with direct care personnel, vendors and other persons, which may be impacted by federal or state laws relating to fraud and abuse.

B. Compliance standards manual

Compliance standards and manuals specific to selected areas of WNYIL Inc. shall be developed and kept current with applicable laws and regulations. The compliance manual shall be a resource for the employees of each selected area designed to enhance the ability of employees to perform their responsibilities in compliance with WNYIL Inc.'s compliance policy and applicable laws and regulations. The designated manager in each affected area is responsible for ensuring that the compliance standards and manuals as required by this program or as designated by the responsible officer are developed and maintained in accordance with this policy.

C. Employee participation and reporting

It is the responsibility of every employee in WNYIL Inc. to abide by applicable laws and regulations and support WNYIL Inc.'s compliance efforts. All employees are required to report their good faith belief of any violation of the Compliance Plan or applicable law. WNYIL Inc., at the request of the employee, will provide such anonymity to the employee(s) who report as is possible under the circumstances in the judgment of WNYIL Inc., consistent with its obligations to investigate employee concerns and take necessary corrective action. There shall be no retaliation in the terms and conditions of employment as a result of such reporting. Employees will report their good faith belief of violations of the Compliance Plan or applicable laws.

1. Either orally or in writing to their manager.


2. By utilizing the compliance hotline at 1-866-576-8042. If you are able to do per call blocking, dial *67 before dialing 1-866-576-8042 to block your number on our caller ID.


3. Entering complaints via our webpage: www.wnyil.org/corporatecompliance.


4. Either orally or in writing to WNYIL Inc.'s Corporate Compliance Officer at Western New York Independent Living, Inc.

   Tina Brown, Corporate Compliance Officer
   WNYIL Inc.
   3108 Main Street
   Buffalo NY 14214
   Phone: (716) 836-0822 ext. 102

D. Responsible officer

WNYIL Inc. has designated the Corporate Compliance Officer as the individual within WNYIL Inc. responsible for overall implementation and operation of the Corporate Compliance Plan. The Corporate Compliance Officer shall be responsible for ensuring that:

1. Standards and manuals are reviewed and updated as necessary,


2. Employee and vendor screening mechanisms are in place and are operating properly,


3. Employees are receiving adequate education and training and that such education and training are documented,


4. Audit procedures are implemented in accordance with WNYIL Inc.'s audit policies,


5. Employee complaints and other concerns regarding compliance are promptly investigated, and


6. Adequate steps are taken to correct any identified problems and prevent the recurrence of such problems.

E. Report to the Board

The Corporate Compliance Officer will report in writing at least annually to WNYIL Inc.'s Board of Directors on the status of compliance within WNYIL Inc., and at other times as appropriate. This report shall include the results of any recommendations resulting from the audit work plans conducted during the prior year, and any other information requested by the Board.