Corporate Compliance

The Brothers of Mercy’s Commitment to Compliance

The Brothers of Mercy is committed to upholding all Federal and State laws, regulations, and ethical standards.  To this end, Brothers of Mercy has adopted a Compliance Program to promote Brothers of Mercy’s compliance with all applicable Federal and State laws, rules, regulations, policies, and standards, and ethical standards.  Brothers of Mercy’s Compliance Program, Compliance Plan, Standards of Conduct, and associated policies and procedures provide guidance to all persons who are affected by Brothers of Mercy’s compliance risk areas, including Brothers of Mercy’s employees, contractors and Board of Directors members on how to conduct themselves when working for Brothers of Mercy.  The goals of Brothers of Mercy’s Compliance Program are to:

1. Prevent fraud, waste, abuse, and other improper or unethical conduct;
2. Detect any improper or unethical conduct at an early stage before it creates a substantial risk of liability for Brothers of Mercy;
3. Respond swiftly to compliance problems through investigation, disciplinary, and corrective action.

To receive additional information on Brothers of Mercy’s Compliance Program, please contact Al Caci, Compliance Officer, at acaci@brothersofmercy.org or (716) 759-6985 ext. 258.

Brothers of Mercy’s Standards of Conduct

Brothers of Mercy recognizes that operating in an ethical and legal manner is not only an obligation of Brothers of Mercy, but is an obligation of each individual providing services on Brothers of Mercy’s behalf.  Brothers of Mercy’s Standards of Conduct set forth the basic principles that guide Brothers of Mercy’s decisions and actions. All employees, contractors and Board members of Brothers of Mercy are required to comply with Brothers of Mercy’s Standards of Conduct in carrying out their duties.

To receive additional information on Brothers of Mercy’s Standards of Conduct, please contact Al Caci, Compliance Officer, at acaci@brothersofmercy.org or (716) 759-6985, extension 258.

Reporting Compliance Concerns

If you believe that a compliance violation may have occurred, you should report the issue immediately using any of the following reporting methods:

1. Make a report to Brothers of Mercy’s Compliance Hotline at (716) 759-6985 ext. 429;
2. Report to Brothers of Mercy’s Compliance Officer, Al Caci, by telephone at (716) 759-6985 ext. 258 or email at acaci@brothersofmercy.org;

Report to Brothers of Mercy’s Compliance Officer, Al Caci, in writing by mail to Attn: Compliance Officer, Brothers of Mercy Nursing & Rehabilitation Center, 10570 Bergtold Road, Clarence, New York  14031;

1. Make a report using the Brothers of Mercy Compliance Dropbox, located adjacent to the gift shop near the elevators on the first floor;
2. Report to a member of Brothers of Mercy’s Compliance Committee; or
3. Report to a Brothers of Mercy Supervisor or its Chief Executive Officer.

Anonymous reports of compliance issues can be made using Brothers of Mercy’s Compliance Hotline, Compliance Dropbox, or by making a report in writing by mail to the Compliance Officer.  All reports of potential compliance issues will be investigated thoroughly and in a timely manner.

Brothers of Mercy will ensure that the confidentially of persons reporting compliance issues is maintained unless the matter is subject to a disciplinary proceeding, referred to, or under investigation by the New York State Attorney General’s Medicaid Fraud Control Unit, the New York State Office of the Medicaid Inspector General, or law enforcement, or disclosure is required during a legal proceeding.  All persons reporting compliance issues will be protected from non-intimidation and non-retaliation pursuant to Brothers of Mercy’s Non-Retaliation and Non-Intimidation Policy.

The above reporting methods may also be used to ask compliance-related questions and to communicate directly with Brothers of Mercy’s Compliance Officer.