A school board is responsible for the education of the children residing in its district and must provide for the governance and oversight of the district’s affairs, personnel, and properties.  To address these responsibilities, the board should establish a strong control environment, issue comprehensive policies, ensure the district operates in accordance with its mission and all legal requirements monitor the district’s financial condition, and ensure the district hires qualified individuals.

 

The control environment sets the tone of an organization, influencing the control consciousness of its people. The governing board and other management personnel set the proper tone for the control environment when they establish and effectively communicate a code of ethics and written policies and procedures, behave in an ethical manner, observe the same rules they expect everyone else to observe, and require the appropriate standard of conduct from everyone in the organization.  Employees observe how management conducts itself, and that conduct often speaks more fluently then the written policies that management expects employees to follow.

 

The Kenmore-Tonawanda UFSD, therefore, promulgates:

 

1. A code of ethics as applies to Medicaid billing, payments, medical necessity and quality of services, mandatory reporting, credentialing and other risk areas that may be identified by due diligence.
2. A staff/governance board training schedule on procedures and compliance issues.
3. A communication process where compliance issues can be reported confidentially.
4. The appointment of a Medicaid compliance officer with the responsibilities articulated.
5. Disciplinary procedures that encourage good faith reporting and sanctions for failure to do so.
6. Definition of administrative responsibilities for fair and firm enforcement of discipline for failure to comply.
7. A system for routine identification of compliance risk areas.
8. A system for responding to, investigating, correcting, reporting and developing policies that discourage non-compliance issues or activities.

 

It is the board’s policy to fairly and firmly enforce the disciplinary policies pertaining to Medicaid non-compliance.

 

Part 521, Title 18 of Codes, Rules and Regulations of the State of New York