{ "document_id": 11774, "page": 21, "width_pt": 612, "height_pt": 792, "rotation": 0, "pipeline_version": "paddleocr-vl-1.6+paul-48", "engine": "paddleocr_vl", "source_run_id": 11885, "item_count": 13, "counts_by_type": { "footer": 1, "heading": 5, "text": 7 }, "build_ms": 2, "items": [ { "id": "p21.1", "order": 1, "type": "text", "bbox": { "l": 83.04, "t": 719.28, "r": 183.36, "b": 706.08 }, "text": "compliance materials." }, { "id": "p21.2", "order": 2, "type": "text", "bbox": { "l": 82.08, "t": 694.32, "r": 542.4, "b": 617.76 }, "text": "AIM will maintain a management-level Compliance Committee with members selected to represent the operational and support functions needed to address AIM’s compliance risk areas. The committee will coordinate with the Compliance Officer, meet no less than quarterly, support the annual compliance work plan and risk assessment, review audits and investigations, monitor corrective actions, assess resources and systems, and report through the Compliance Officer to the Chief Executive Officer and Board." }, { "id": "p21.3", "order": 3, "type": "heading", "bbox": { "l": 83.04, "t": 605.04, "r": 222.24, "b": 592.32 }, "text": "3. Training and Education", "attrs": { "block_label": "paragraph_title" }, "level": 3 }, { "id": "p21.4", "order": 4, "type": "text", "bbox": { "l": 82.08, "t": 591.36, "r": 542.16, "b": 489.36 }, "text": "AIM will provide compliance-program training and education to all “affected individuals” whose functions or contracts are affected. Training will occur during orientation or engagement, at least annually thereafter, and when changes in responsibilities or significant compliance risks require additional instruction. It will address AIM’s risk areas, written policies and standards of conduct, the role of the Compliance Officer and Compliance Committee, reporting methods, non-retaliation and non-intimidation protections, disciplinary standards, auditing and monitoring, and the obligation to report, return, and explain Medicaid overpayments. AIM will maintain a training plan and document the content, dates, attendance, and completion of required training." }, { "id": "p21.5", "order": 5, "type": "heading", "bbox": { "l": 83.28, "t": 477.36, "r": 192.48, "b": 464.64 }, "text": "4. Reporting Hotline", "attrs": { "block_label": "paragraph_title" }, "level": 3 }, { "id": "p21.6", "order": 6, "type": "text", "bbox": { "l": 81.84, "t": 464.16, "r": 542.64, "b": 360.72 }, "text": "“Affected individuals” may communicate compliance questions or report suspected violations anonymously or confidentially through AIM’s hotline at 518-450-2896, secure web portal, compliance email address, direct contact with the Compliance Officer, or another reporting method identified in AIM’s compliance materials. These channels are publicized and accessible to all “affected individuals.” Reports involving the Compliance Officer may be made to the Chief Executive Officer or Chief Operating Officer. Nothing in this policy restricts lawful communication with a government agency. AIM will protect confidentiality to the extent reasonably possible and prohibits retaliation or intimidation for good-faith reporting or participation in a compliance review or investigation." }, { "id": "p21.7", "order": 7, "type": "heading", "bbox": { "l": 82.56, "t": 349.68, "r": 335.76, "b": 336.72 }, "text": "5. Monitoring, Auditing, and Internal Reporting", "attrs": { "block_label": "paragraph_title" }, "level": 3 }, { "id": "p21.8", "order": 8, "type": "text", "bbox": { "l": 82.08, "t": 336.48, "r": 542.16, "b": 259.2 }, "text": "The Compliance Officer and Compliance Committee will maintain a risk-based monitoring and auditing plan. The Quality Assurance/Compliance team will assess internal controls and risk-management systems; verify compliance with laws, regulations, contracts, and AIM policies; conduct audits and investigations concerning potential fraud, waste, abuse, and other noncompliance; identify patterns, weaknesses, and systemic risks; and recommend corrective actions that strengthen controls, improve efficiency, mitigate risk, and prevent recurrence." }, { "id": "p21.9", "order": 9, "type": "heading", "bbox": { "l": 83.04, "t": 247.44, "r": 296.4, "b": 234.96 }, "text": "6. Non-Retaliation and Non-Intimidation", "attrs": { "block_label": "paragraph_title" }, "level": 3 }, { "id": "p21.10", "order": 10, "type": "text", "bbox": { "l": 82.08, "t": 234.24, "r": 542.64, "b": 156.48 }, "text": "AIM prohibits retaliation or intimidation against any “affected individual” who, in good faith, reports a potential compliance issue, seeks guidance, assists with an audit or investigation, participates in the compliance program, or refuses to participate in conduct reasonably believed to violate law or AIM policy. Allegations of retaliation or intimidation will be investigated promptly and independently. Confirmed violations will result in corrective or disciplinary action, and AIM will take appropriate steps to protect the reporting person and remedy the effects of retaliation." }, { "id": "p21.11", "order": 11, "type": "heading", "bbox": { "l": 83.28, "t": 145.44, "r": 261.6, "b": 132.24 }, "text": "7. Investigations and Remediation", "attrs": { "block_label": "paragraph_title" }, "level": 3 }, { "id": "p21.12", "order": 12, "type": "text", "bbox": { "l": 82.32, "t": 131.76, "r": 543.12, "b": 79.68 }, "text": "AIM will promptly assess and investigate reported or detected compliance issues under the direction of the Compliance Officer. Investigators will be selected based on independence, subject matter, and complexity. AIM will preserve relevant records, maintain confidentiality to the extent reasonably possible, document findings and corrective actions, and monitor remediation to completion. When an" }, { "id": "p21.13", "order": 13, "type": "footer", "bbox": { "l": 300, "t": 37.44, "r": 312.48, "b": 27.84 }, "text": "20", "attrs": { "block_label": "number" } } ], "excluded_furniture": { "first": [], "last": [] } }