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Commitment to Compliance

Consistent with the long tradition of ethical and responsible conduct of the Visiting Nurse Service of New York (VNSNY), VNSNY CHOICE is committed to serving its members, providers and everyone with whom it does business pursuant to the highest ethical, business and legal standards.

To that end, VNSNY CHOICE has implemented a comprehensive Compliance Program to ensure that legal and ethical conduct is an integral part of our organization’s culture and operations.

Compliance Program guidelines last updated: 1/1/2020.

Code of Conduct

The VNSNY Code of Conduct is a statement of ethical and compliance principles that guide the daily operations of VNSNY, its subsidiaries and affiliates, including VNSNY CHOICE. The Code of Conduct establishes key ethical principles that we require all directors, officers, employees, contractors, agents, First Tier, Downstream and Related Entities (“FDRs”) and others associated with VNSNY and its FDRs to follow, as well as standards to help ensure compliance with applicable laws and company policies.

The Code of Conduct requires VNSNY CHOICE’s employees, Board members, administrators, physicians, volunteers, and those with whom we do business to report any action(s) that may be unlawful, inappropriate, or in violation of the Code of Conduct, applicable policies and procedures, or applicable laws, rules, and regulations. Be assured, there will be no intimidation of, or retaliation against, anyone who in good faith reports a compliance concern.

Code of conduct last updated: 4/1/2021.

Compliance Policies and Procedures

VNSNY CHOICE and VNSNY have adopted and implemented numerous compliance policies and procedures that further support our commitment to compliance, as embodied in the Compliance Program and Code of Conduct, and ensure that the Program is operating effectively and with integrity. These policies and procedures include, without limitation:

Nondiscrimination Notice
(Last updated: 4/15/2022)

VNSNY Policy on Non-Retaliation and Non-Intimidation
(Last updated: 3/12021)

VNSNY CHOICE Health Plans Fraud, Waste, and Abuse Detection Manual
(Last updated: 3/21/2022)

The Detection and Prevention of Fraud, Waste and Abuse and Applicable Federal and State Laws (DRA Policy)
(Last updated 1/1/2020)

Sanction Checks
(Last updated 3/1/2021)

Policy How to Report a Compliance Concern

Anonymous Hotlines and Online Reporting Tool

VNSNY CHOICE Hotline: (888) 634-1558

VNSNY Online Reporting Tool:

Through our Hotline and Online Reporting Tool, individuals can report a compliance concern, including fraud, waste and abuse, or seek guidance about compliance questions:

Any individual may make a report. All reports will be taken seriously and, if warranted, investigated by Compliance or the Special Investigations Unit.

When making a report, please provide as much detail as possible, such as names, dates, and a description of the issue. Unless you prefer to remain anonymous, please include your name and telephone number so that we may contact you if we have any questions during our investigation.

Fraud, Waste, and Abuse Detection and Prevention

VNSNY CHOICE has established a comprehensive Fraud, Waste, and Abuse Prevention Program to prevent, detect, and correct fraud, waste, and abuse by employees, members, providers, agents, contractors and FDRs of VNSNY CHOICE. For more information, please see the Fraud, Waste and Abuse Detection and Prevention page.

Compliance Leadership

Individuals can always contact VNSNY CHOICE Compliance directly with any compliance concerns or questions.

VNSNY Chief Compliance and Privacy Officer
Annie Miyazaki-Grant
SVP, Chief Compliance & Privacy Officer
(212) 609-7470

VNSNY CHOICE Compliance Officer
Doug Goggin-Callahan
VP, CHOICE Compliance & Regulatory Affairs
(201) 779-2584

Other Ways to Contact Compliance

Individuals can also send materials to the CHOICE Compliance Department by fax or mail:

Attn: VNSNY CHOICE Compliance Department
220 East 42nd Street, 3rd Floor
New York, NY 10017
(646) 459-7730 (fax)

VNSNY CHOICE Hotline: (888) 634-1558

VNSNY Online Reporting Tool:

Helpful Links:

CMS Compliance Program Policy and Guidance – Information on Centers for Medicare and Medicaid Services (CMS) Compliance Program requirements and links to compliance training.

NYS OMIG Compliance – New York State Office of the Medicaid Inspector (NYS OMIG) General Bureau of Compliance page, with links to the Compliance Library.

HHS Office of Civil Rights – HIPAA – U.S. Department of Health and Human Service Office of Civil Rights website offers information on health information privacy and security.

New York State Department of Health – Information about New York State Department of Health, as well as Model Contracts for VNSNY CHOICE’s Medicaid Managed Long Term Care (MLTC) and Medicaid Managed Care Special Needs Plan (SNP) can be accessed here.