The Corporate Compliance Program of Beth Sholom Lifecare Community (“Beth Sholom”) is a written and operational commitment to organization-wide compliance with all applicable laws. This includes laws governing quality of care, laws and regulations and state licensure laws, fraud and abuse-specific laws like the federal False Claims Act and Anti-Kickback Statute, HIPAA Omnibus, and a variety of other laws governing the delivery of care and claims for payment in nursing facilities.
The Corporate Compliance Program is concerned with the detection and prevention of fraud, waste and abuse in all areas. The government defines “fraud” as the intentional deception or misrepresentation when the individual knows it to be false (or does not believe it to be true), knowing that the deception could result in an unauthorized benefit to himself or another person. “Abuse” is defined as incidents or practices that are inconsistent with sound health care practice and may result in unnecessary costs, improper payment, or the payment for services that either fail to meet professional standards of care or are medically unnecessary.
The Corporate Compliance Program promotes doing business in a way that prevents intentional or unintentional violations of the laws regulating nursing homes. The Corporate Compliance Program includes policies and procedures, staff training and education and mechanisms to detect, investigate and report any potential conflicts or violations. A Corporate Compliance Program can protect the facility and its employees from civil damages and government sanctions.
Any individual may exercise his or her right to file a complaint with Beth Sholom Lifecare Community (hereafter referred to as “BSLCC”) if that person believes that s/he or any other program beneficiaries have been subjected to unequal treatment or discrimination in the receipt of benefits/services or prohibited by non-discrimination requirements. BSLCC will make a concerted effort to resolve complaints locally, using the agency’s Nondiscrimination Complaint Procedures, as described below. All Title VI complaints and their resolution will be logged as described under “Data collection” and reported immediately.
Should any Title VI investigations be initiated by any Federal Agency (e.g. FTA), or any Title VI lawsuits be filed against BSLCC, the agency will follow these procedures listed below.
These procedures apply to all complaints filed under Title VI of the Civil Rights Act of 1964 as amended, and the Civil Rights Restoration Act of 1987, relating to any program or activity administered by BSLCC as well as to sub-recipients, consultants, and/or contractors. Intimidation or retaliation of any kind is prohibited by law. These procedures do not deny the right of the complainant to file formal complaints with other state or federal agencies, or to seek private counsel for complaints alleging discrimination. These procedures are part of an administrative process that does not provide for remedies that include punitive damages or compensatory remuneration for the complainant. Every effort will be made to obtain early resolution of complaints at the lowest level possible. The option of informal mediation meeting(s) between the affected parties and the Title VI Compliance Officer may be utilized for resolution. The Title VI Compliance Officer will make every effort to pursue a resolution to the complaint. Initial interviews with the complainant and the respondent will request information regarding specifically requested relief and settlement opportunities.
- Any individual, group of individuals, or entity that believes they have been subjected to discrimination prohibited by Title VI nondiscrimination provisions may file a written complaint with BSLCC’s Title VI Program Compliance Officer. A formal complaint must be filed within 180 calendar days of the alleged occurrence or when the alleged discrimination became known to the complainant. The complaint must meet the following requirements:
a. Complaint shall be in writing and signed by the complainant(s).
b. Include the date of the alleged act of discrimination (date when the complainant(s) became aware of the alleged discrimination; or the date on which that conduct was discontinued or the latest instance of the conduct).
c. Present a detailed description of the issues, including names and job titles of those individuals perceived as parties in the complained-of incident.
d. Allegations received by fax or e-mail will be acknowledged and processed, once the identity(ies) of the complainant(s) and the intent to proceed with the complaint have been established. The complainant is required to mail a signed, original copy of the fax or e-mail transmittal for BSLCC to process it.
e. Allegations received by telephone will be reduced to writing and provided to complainant for confirmation or revision before processing.
f. A complaint form will be forwarded to the complainant for him/her to complete, sign, and return to BSLCC for processing.
- Upon receipt of the complaint, the Title VI Compliance Officer will determine its jurisdiction, acceptability, and need for additional information, as well as investigate the merit of the complaint.
- In order to be accepted, a complaint must meet the following criteria:
a. The complaint must be filed within 180 calendar days of the alleged occurrence or when the alleged discrimination became known to the complainant.
b. The allegation(s) must involve a covered basis such as race, color, or national origin.
c. The allegation(s) must involve a program or activity of a federal-aid recipient, subrecipient, or contractor.
- A complaint may be dismissed for the following reasons:
a. The complainant requests the withdrawal of the complaint.
b. The complainant fails to respond to repeated requests for addition information needed to process the complaint.
c. The complainant cannot be located after reasonable attempts.
- Once BSLCC decides to accept the complaint for investigation, the complainant and the respondent will be notified in writing of such determination within seven calendar days. The complaint will receive a case number and will then be logged into BSLCC’s records identifying its basis and alleged harm.
- BLSCC’s final investigative report and a copy of the complaint will be forwarded to the appropriate Federal Agency (e.g. FTA) and affected parties within 60 calendar days of the acceptance of the complaint.
- BSLCC will notify the parties of its final decision.
- If complainant is not satisfied with the results of the investigation of the alleged discrimination and practices the complainant will be advised of their right file a complaint with the appropriate Federal Agency.
Please contact the following:
Sue Berinato, Compliance Officer
1600 John Rolfe Parkway
Richmond, VA 23238
Phone: (804) 421-5037
Email: [email protected]
Discrimination is Against the Law
Beth Sholom Lifecare Community complies with applicable Federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, or sex. Beth Sholom does not exclude people or treat them differently because of race, color, national origin, age, disability, or sex.
Beth Sholom Lifecare Community:
Provides free aids and services to people with disabilities to communicate effectively with us, such as:
-Qualified sign language interpreters
-Written information in other formats (large print, audio, accessible electronic formats, other formats)
Provides free language services to people whose primary language is not English, such as:
-Information written in other languages
If you need these services, contact Sue Berinato, Civil Rights Coordinator (see below).
If you believe that Beth Sholom Lifecare Community has failed to provide these services or discriminated in another way on the basis of race, color, national origin, age, disability, or sex, you can file a grievance with:
Sue Berinato, Corporate Compliance Officer/Civil Rights Coordinator
c/o Beth Sholom Lifecare Community
1600 John Rolfe Parkway
Richmond, VA 23238
Phone: 804-421- 5037 TTY users dial “711”
Fax: 804-741-9813 email: [email protected]
You can also file a civil rights complaint with the
U.S. Department of Health and Human Services, Office for Civil Rights,
Electronically through the Office for Civil Rights Complaint Portal, available at https://ocrportal.hhs.gov/ocr/portal/lobby.jsf,
or by mail or phone at:
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Room 509F, HHH Building
Washington, D.C. 20201
1-800-368-1019, 800-537-7697 (TDD)
Complaint forms are available at http://www.hhs.gov/ocr/office/file/index.html.