safely secured and not accessible to people served.

Employees suspected of possessing alcohol, cannabis, or illegal drugs are subject to inspection and search, with or without notice. Employees’ personal belongings, including bags, purses, and clothing, and all AIM property, are also subject to search and inspection, with or without notice. Employees who violate this policy will be subject to discipline, up to and including termination. Any questions regarding AIM’s drug-free workplace compliance efforts should be directed at Human Resources.

Employees must submit to drug or alcohol testing when AIM has reasonable suspicion of impairment. Reasonable suspicion must be based on specific, contemporaneous observations concerning appearance, behavior, speech, odor, coordination, or other objective indicators. Refusal to undergo drug or alcohol testing may result in disciplinary action up to/including termination. AIM Services, Inc. ensures compliance with the ADA, New York Human Rights Law and other applicable laws.

AIM’s Corporate Compliance Program is designed to prevent, detect, and correct noncompliance with Medicaid program requirements, including fraud, waste, and abuse. In accordance with New York Social Services Law § 363-d and 18 NYCRR Subpart 521-1, the program addresses seven required elements: written compliance policies and standards of conduct; a designated Compliance Officer and Compliance Committee; compliance training and education; effective confidential communication with the Compliance Officer; disciplinary standards; auditing and monitoring; and prompt response to compliance issues, including investigation, correction, self-disclosure, and repayment when required.

For this section, “affected individuals” includes AIM employees, the Chief Executive Officer and other senior administrators, managers, governing body members, corporate officers, contractors, agents, subcontractors, and independent contractors whose functions are affected by AIM’s compliance risk areas. Those risk areas include billing, payment, ordered services, documentation, coding, medical necessity, quality of care, governance, mandatory reporting, credentialing, contractor oversight, and other areas identified through AIM’s experience and risk assessments.

AIM will maintain written compliance policies, procedures, and standards of conduct that are available, accessible, and applicable to all affected individuals. The documents will identify governing federal and state requirements and AIM's risk areas; describe compliance expectations and responsibilities; explain how to identify, report, and resolve potential compliance issues; prohibit retaliation and intimidation; establish disciplinary standards; and document the structure and operation of each element of the compliance program. AIM will review the documents at least annually and revise them when legal, regulatory, operational, or risk changes require an update. AIM will distribute the standards of conduct at appointment or engagement and after material revisions and will document receipt as required by policy.

AIM will designate a qualified Compliance Officer who reports directly to the Chief Executive Officer and periodically to the Board of Directors and who has direct access to senior management and the Board. The Compliance Officer will oversee the day-to-day operation of the compliance program; develop an annual compliance work plan; review policies and training; coordinate the Compliance Committee; investigate and respond to compliance issues; monitor corrective actions; and report at least quarterly to the Chief Executive Officer and Board on program activities and effectiveness. Current contact information for the Compliance Officer will be maintained in AIM's employee directory and