Corporate Compliance
St. Mary’s Healthcare System for Children’s Commitment to Corporate Compliance
St. Mary’s Healthcare System for Children (the “System”) (St. Mary’s Administrative Services; St. Mary’s Hospital for Children; Extraordinary Home Care; SMH Care Management; and Extraordinary Pediatrics, PC) is committed to providing quality services that comply with all applicable federal and state laws. The System’s Compliance Program demonstrates our firm commitment to the highest standards of ethics and compliance which includes All Affected Individuals (Employees, Chief Executive, Senior Administrative(s), Manager(s), Contractor(s), Agent(s), Subcontractor(s), Independent Contractor(s), Governing Body Member(s), and Corporate Officer(s)) comply with our Compliance Program and applicable compliance policies.
Code of Conduct:
Perform all business activities and duties with honesty and integrity according to the System’s Code of Conduct:
- Follow all laws and regulations that apply to your business activities and duties, including requirements of government social service or health care programs. These requirements generally include, but are not limited to, maintaining complete and accurate records and submitting only complete and accurate claims for medically necessary services or equipment provided; and
- Contact an immediate supervisor, senior administrative member, or the System’s Audit and Compliance Manager, Christine Hutton at (718) 281-8587 or Chief Compliance Officer, Adam Waxer at (718) 281-8585 if you have knowledge of or are concerned about a potential false claim or other violation. The System’s policies strictly prohibit retaliation, in any form, against an individual reporting an issue or concern in good faith. Retaliation is subject to discipline, including termination of employment or termination of the business relationship with St. Mary’s Healthcare System for Children and any of its entities.
Compliance Training:
The System welcomes All Affected Individuals to review our compliance training initially and annually thereafter. However, certain vendors are required to take our mandatory compliance training annually as per Title 18 § 521-1.4(d)(2).
Vendors: Vendors can access and attest the training by clicking here.
For more information regarding any training and policies, please contact Christine Hutton, Audit and Compliance Manager at (718) 281-8585.
We encourage All Affected Individuals to report any actual or suspected violations of the System’s policies and procedures and/or federal or state law. Reports of potential fraud, waste, abuse and compliance issues also may be directly made to the Chief Compliance Officer or designee, in writing, via email, or telephone. Compliance Hotline callers may remain anonymous and those who choose to give their name will have their identities protected to the extent allowed by law. Our investigation includes many methods to determine whether any misconduct occurred. Compliance takes all calls seriously. Inquiries are reviewed by the Compliance Department and may also be reviewed by other applicable departments such as the Human Resources and Legal Department.
If you have any compliance issues, you can report them to the Compliance Hotline. The Compliance Hotline has multi-lingual operators who can take reports from individuals whose first language is not English. The Compliance Hotline can be reached by calling (888) 343-2581, available 24 hours a day, seven days a week at or online https://www.integrity-helpline.com/stmaryskids.jsp or scan the QR code (at the bottom).
This training program lasts approximately 30 minutes and will address the System’s commitment to Compliance. If, due to a disability or any other barrier, you need accommodation to assist you in accessing and/or completing any part of the training module, please promptly contact the Audit and Compliance Manager, Christine Hutton at (718) 281-8587. The course must be completed in its entirety to receive credit toward your training record.
Government oversight:
The Office of Inspector General of the U.S. Department of Health (OIG) and Human Services and the New York State Office of Medicaid Inspector General (OMIG) provide information regarding waste, fraud, and abuse in the federal and New York State health care programs. The Office for Civil Rights of the US Department of Health and Human Services (OCR) is the agency responsible for the enforcement of the HIPAA privacy and security rules.
Learn more at OIG, OMIG and OCR.
False Claims Act (Federal and NY State):
The False Claims Act (FCA), 31 USC §§3279-3733 is a federal law that strictly prohibits a person or organization from knowingly submitting a false claim or using a false record to receive payment or property from the federal government, whether the payment is received directly or indirectly. Knowingly means that someone knew that the claim was false, deliberately ignored whether the claim was false, or acted with reckless disregard for the truth of the submitted claim.
New York State recently enacted the New York State Finance Law, Article 13, §§187-194, that created a State False Claims Act (SFCA) very similar to the Federal FCA. The SFCA prohibits a person or organization from knowingly submitting a false claim or making a false record or statement in order to receive payment from the state or a local government agency.
NY State Criminal Laws
New York State has several laws that make it a misdemeanor or a felony to obtain medical services through false statements, false records, or false claims. These laws include those specific to monies or property received from government social programs, such as Social Services Law §145, Social Services Law §366-b, and Penal Law Article 177 (Health Care Fraud). Also included are laws that generally prohibit theft and fraud, such as Penal Law Article 155 (Larceny), Penal Law Article 175 (False Written Statements) and Penal Law Article 176 (Insurance Fraud).
Penalties:
In 2025, the penalties under the False Claims Act (FCA) are adjusted for inflation, resulting in a minimum penalty of $14,308 and a maximum penalty of $28,619 per claim. The adjustment in penalties went into effect as of January 2025.
Protections for Whistleblowers:
The Whistleblower Protection Act (WPA) is a federal law designed to shield employees who report suspected violations of laws, rules, or regulations, gross mismanagement, gross waste of funds, abuse of authority, or substantial and specific dangers to public health or safety.
The FCA prohibits employers from taking any adverse action against any Affected Individuals who report fraud or participate in FCA–related legal actions. This includes termination, demotion, or harassment. If a whistleblower believes he or she has been retaliated against, he or she may file a suit against the employer to be reinstated to his or her former position, recover twice the amount of any pay owed, interest in the pay owed, and compensation for any special damage that occurred because of the discrimination.
New York Labor Laws:
NY Labor Law §§ 740 & 741, often referred to as the State’s Whistleblower law, protects employees including former employees, or natural persons employed at independent contractors from retaliation for reporting employer misconduct or violation of law.
Section 740 shields employees who report violations that pose a substantial and specific danger to public health or safety, or violate laws, rules or regulations.
Section 741 extends these protections to healthcare workers who report improper patient care or violations related to patient safety.
Under these laws, the Employees must first alert the System of the alleged violation and provide a reasonable opportunity for the System to investigate and remedy the problem.
Compliance Matters:
If you would like to discuss any potential compliance concerns, contact the Audit and Compliance Manager, Christine Hutton at (718) 281-8587 or Chief Compliance Officer, Adam Waxer at (718) 281-8585. You can also visit the Compliance Hotline Website or call (888) 343-2581, available 24 hours a day, seven days a week or scan the QR Code.
Thank you for your commitment to maintaining our high ethical standards and assisting us in our efforts to prevent and eliminate fraud, waste, and abuse in the provision of our quality of services.