Corporate Responsibility
Plan Overview
Noble’s Corporate Compliance Program is one of the key components of our commitment to the highest standards of corporate conduct and ethics. The purpose of Noble’s Corporate Compliance Program is to establish and maintain a system that encourages and promotes ethical business conduct throughout all levels of our organization and to prevent and detect violations of law or Noble policy and procedure.
We have tailored Noble’s Corporate Compliance Program to fit the unique environment and characteristics of our organization. Considering Noble’s size and the scope of operations, we rely upon several key staff members to share responsibility for implementing our Program: President & CEO; Vice President & CFO; Vice President of Compliance & Operations; Assistant Vice President of Programs; and the Director of Human Resources all have critical roles in the Corporate Compliance Program.
Following is a description of our Corporate Compliance and Ethics Program which references multiple policies, procedures & programmatic activities, as well as the commitment of Noble Leadership & employees. In order to meet our evolving compliance needs, we regularly review & enhance our program.
Designated Staff
The Vice President & CFO; Vice President of Compliance & Operations; Assistant Vice President of Programs; and the Director of Human Resources have been designated by Noble to oversee the key elements of the Corporate Compliance Plan. This oversight involves review of policies & procedures relative to Compliance, internal audits relative to Compliance, and establishment & maintenance of a library of regulations and/or access to these regulations, including but not limited to BQIS, CARF, BDDS, SBOH, APS, CPS, Wage and Hour, Workers Comp, GAAP, and HIPAA. These positions report to the CEO on matters related to ethics & compliance.
Written Policies and Procedures
The Noble Code of Ethics and Agency Procedures detail expected employee behavior. Agency procedures regarding Safety, Finance, Risk Management, Human Resources, Behavior, Communications, Facilities Maintenance, Information Technology, Medical, Health & Safety, Transportation, and other Administrative and Programmatic issues help guide employees. Agency procedures are reviewed annually and as needed for continued relevancy, pertinence and necessity. Staff may access procedures within the payroll or client database and print procedures as needed/requested for individuals served. Changes made to agency procedures will be disseminated to all staff prior to being updated/posted in designated database. All originals will be maintained in the Gdrive Agency Procedures Folder.
Auditing and Monitoring
Internal audits of the billing process and data entry are conducted by designated staff in the Program Service areas and in the Fiscal Department. Results of the audits are reported to the Program Directors, the CFO and the President/CEO for recommended action and reviewed by the Agency Corporate Compliance Committee on a quarterly basis. Quality audits of programmatic activities are conducted by the Program Directors.
Training and Education
In addition to a formalized New Employee Orientation program, and a formalized ongoing training & education program, staff are required to complete annual training on key areas of the Compliance and Ethics Program. All employees must sign an acknowledgement of receipt of the Code of Ethics and the Ethical Code of Service Provision, along with other key policies & procedures.
Confidential Communication
Noble maintains an “open door” policy with all employees, especially in areas concerning Ethics and Compliance. Any report involving a violation of the Code of Ethics or Compliance Procedures will be investigated by the Vice President of Compliance & Operations; Assistant Vice President of Programs; and the Director of Human Resources. All communication will be kept confidential to the degree possible while conducting the investigation. Findings of the investigation will be made to the President/CEO and reviewed quarterly by the Agency Corporate Compliance Committee. A member of the Agency Corporate Compliance Committee will report at each meeting of the Audit Committee of the Board a summary of all reports of potential fraud and abuse and any pending legal activity. Employees who violate the Code of Ethics or other Corporate Compliance Procedures will be subject to disciplinary action, up to and including termination.
“No Reprisal” System for Reporting Suspicious Activities
No disciplinary action will be taken against any staff member who reports in good faith an act of wrongdoing including waste, fraud, and abuse or a violation of the Noble Code of Ethics or other agency policy. However, an employee will be subject to disciplinary action if Noble reasonably concludes that the report of wrongdoing was knowingly fabricated to cause harm to someone else or to protect the reporting party or others.
A recorded statement regarding violations can be left 24 hours a day / 7 days a week at 855-372-8345. If leaving a message, please include as much information as possible to aid in investigation of the allegation. All allegations will be responded to within 48 hours of the report.
