Housing Works’ Commitment to Compliance

Housing Works, Inc. and its affiliates, including Housing Works Health Services, Inc., Housing Works Health Services II, Inc., Housing Works Health Services III, Inc., Bailey House, Inc., and Positive Health Project, Inc. (the “Affiliates” and, collectively with Housing Works, Inc., “Housing Works”) is committed to upholding all federal and state laws, regulations, and ethical standards. To this end, Housing Works has adopted a Compliance Program to promote Housing Works’ compliance with all applicable federal and state laws, rules, regulations, policies, and standards, and ethical standards. Housing Works’ Compliance Program, Compliance Plan, Standards of Conduct, and associated policies and procedures provide guidance to all persons who are affected by Housing Works’ compliance risk areas, including Housing Work’ employees, contractors, and Board of Directors members on how to conduct themselves when working for Housing Works. The goals of Housing Works’ 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 Housing Works; and
3. Respond swiftly to compliance problems through investigation, disciplinary, and corrective action.

To receive additional information on Housing Works’ Compliance Program, please contact Housing Works, Inc.’s Vice President for Operations & Compliance Officer, Erica Hudson, at hudson@housingworks.org or (718) 408-6549, or the Affiliates’ Director of Healthcare Compliance, Gillian Saunders, at (347) 675-7689 or g.saunders@housingworks.org.

Housing Works’ Standards of Conduct

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

To receive additional information on Housing Works’s Standards of Conduct, please contact Housing Works’ Vice President for Labor Relations and Investigations, Jewel Allred, at (646) 823-3592 or j.allred@housingworks.org, or Housing Works, Inc.’s Vice President for Operations & Compliance Officer, Erica Hudson, at hudson@housingworks.org or (718) 408-6549, or the Affiliates’ Director of Healthcare Compliance, Gillian Saunders, at (347) 675-7689 or g.saunders@housingworks.org.

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 Housing Works’ Compliance Hotline at (888) 337-3845 (anonymously or otherwise);
2. Make a report to any member of Housing Works’ Compliance Committees;
3. Make a report to any supervisor;
4. Make a report to any member of Housing Works’ Boards of Directors;
5. Make a report to any of Housing Works’ Chief Executives, including Housing Works’ Chief Executive Officer (“CEO”), Housing Works, Inc.’s President, or any of the Executive Directors of the Affiliates;
6. For reports regarding Housing Works, Inc., make a report to Housing Works, Inc.’s Vice President for Operations & Compliance Officer, Erica Hudson
   1. By telephone at (718) 408-6549;
   2. By email at hudson@housingworks.org;
   3. In writing by mail to Attn: Vice President for Operations & Compliance Officer, Housing Works, Inc., 81 Willoughby St. 2nd floor, Brooklyn, New York 11201 (anonymously or otherwise);
7. For reports regarding the Affiliates, make a report to the Affiliates’ Director of Healthcare Compliance & Special Operations, Gillian Saunders:
   1. By telephone at (347) 675-7689;
   2. By email at g.saunders@housingworks.org; or
   3. In writing by mail to Attn: Director of Healthcare Compliance, Housing Works Health Services III, Inc., 57 Willoughby Street, Fl 2, New York, New York, 11201(anonymously or otherwise).

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

Housing Works will ensure that the confidentiality 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 people reporting compliance issues will be protected from non-intimidation and non-retaliation pursuant to Housing Works’ Non-Retaliation and Non-Intimidation Policy.

The above reporting methods may also be used to ask compliance-related questions and to communicate directly with Housing Works’ Compliance Officers.