After settling with the New York State Attorney General’s Medicaid Fraud Control Unit on charges related to regulatory improprieties and over-billing of Medicaid claims, the Hospital agreed to the appointment of an Independent Monitor to ensure compliance with specific integrity provisions that were made part of the settlement agreement. Guidepost Solutions served as that monitor for seven years.
Our monitoring team reviewed the Hospital’s Code of Conduct, Code of Interest, protocols and procedures; made recommendations and worked with the Hospital to improve upon them; oversaw the Hospital’s procurement and hiring functions; managed its integrity hotline and conducted investigations in connection with calls to that hotline; worked with the Hospital’s procurement director to establish an integrity screening process for vendors and suppliers that included selecting and performing background investigations for more than 200 vendors; and conducted investigations into allegations of conflicts of interest involving real estate transactions. We continuously conducted forensic audits of targeted Hospital transactions and its departments, programs and projects. In addition, as part of our oversight, we routinely monitored the work of Hospital managers on bidding processes for construction matters and regularly analyzed financial statements, cost reports, loan documents, contracts, management letters, and compliance and internal audit reports to identify potential integrity risks and issues.