Compliance & Ethics

: A: The purpose of this policy is to detail the components of the NeuSpark Person Directed Services (NeuSpark PDS) Corporate Compliance Program, relating to the seven elements of an Effective Compliance Program. This Corporate Compliance Program is established for the entire NeuSpark PDS organization, including its employees, contractors, agents, the Board of Directors, and interns.

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: A: It is NeuSpark PDS's policy that any employee, contracted employee, volunteer, or governing body member who witnesses, learns of, or is asked to participate in potentially non-compliant activities must report the matter immediately to his/her/their supervisor and to the Compliance Officer. If the potential non-compliant activity involves the Corporate Compliance Officer or the Compliance Officer, the information must be reported immediately to the Chief Executive Officer.

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: A: NeuSpark Person Directed Services is committed to prompt, complete, and accurate billing of all services provided to individuals. The Agency and its employees, contractors and agents shall not make or submit any false or misleading entries on any claim forms. No employee, contractor or agent shall engage in any arrangement or participate in such arrangement at the direction of another person, including any supervisor or manager that result in the submission of a false or misleading entry on claims forms or documentation of services that result in the submission of a false claim.

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: A: It is the policy of NeuSpark Person Directed Services (the Agency) that its employees avoid Conflicts of Interest so that employees of PDS may represent the organization in a positive and ethical manner. All employees must avoid situations involving a conflict between their personal business interests and the interests of NeuSpark PDS. Employees must avoid outside business interests that could compromise an employee’s commitment to the agency – either by dividing loyalties or by diverting the energies and attention owed to PDS in the normal course of employment.

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