issue may involve criminal, civil, or administrative law, material Medicaid payment error, or credible evidence of misconduct, AIM will obtain appropriate legal or professional guidance and make required disclosures or referrals. Identified Medicaid overpayments will be reported, returned, and explained within the time required by law, and systemic issues will result in corrective action such as repayment, policy revision, training, discipline, process redesign, and expanded auditing.
Clear and consistent disciplinary actions will be applied to employees who violate company policies, legal standards, or ethical expectations. The disciplinary action will be consistent with the policies in this handbook and will be fair, transparent, and scalable based on the severity of the violation.
This Code of Conduct has been adopted as part of AIM Services, Inc.'s Corporate Compliance Program. It establishes the legal and ethical standards that apply to all affected individuals, including employees, as defined in Corporate Compliance Program Policy, and supports AIM's commitment to prevent, detect, and correct noncompliance, fraud, waste, and abuse. Each affected individual must understand and follow this Code, applicable laws and regulations, AIM policies and procedures, and the requirements of their role. Questions or concerns must be raised promptly through the reporting channels described in Corporate Compliance Program Policy.
Legal Compliance - All affected individuals must conduct AIM business in accordance with applicable federal and New York laws, regulations, contractual requirements, program rules, and AIM policies. No person may direct, authorize, participate in, conceal, or knowingly ignore unlawful or noncompliant conduct. When a requirement is unclear, the individual must seek guidance from a supervisor, the Compliance Officer, Human Resources, or other appropriate AIM resource before acting.
1.1 - Antitrust – Examples of conduct prohibited: agreement to fix prices, bid rigging, boycotts, unfair trade practices including bribery, deception and intimidation.
1.2 - Tax – All tax and information returns will be filed accurately.
1.3 - Fraud, Waste, Abuse, False Claims, and Overpayments - Affected individuals must ensure that claims, service records, time records, cost reports, supporting documentation, and other information submitted to AIM, Medicaid, or another payer are accurate, complete, timely, and supported by services actually provided and properly authorized. Prohibited conduct includes billing for services not rendered, duplicative or medically unnecessary services, unsupported or altered documentation, falsifying records, misrepresenting eligibility or qualifications, concealing an error, and knowingly retaining overpayment. Suspected errors, false claims, overpayments, fraud, waste, or abuse must be reported promptly through the channels identified in AIM's Compliance Program Policy.
1.4 - Lobbying/Political activity – No individual may, at AIM's expense, contribute money, property or services to any political candidate, party or organization in violation of law.
1.5 - Environmental – AIM's operations will be conducted with respect for the environment.
1.6 - Discrimination – All employees, consumers and other persons will be treated fairly and equitably.
Business Ethics - Affected individuals must act honestly, fairly, and in AIM's best interests. They may not engage in deception, misrepresentation, theft, bribery, falsification, concealment, misuse of confidential information, obstruction of an audit or investigation, or any scheme intended to deprive another person, AIM, a government program, or another payer of money, property, information, or honest services.
Confidentiality and Privacy - Affected individuals will protect confidential, proprietary, personal, and health information and may access, use, or disclose it only as authorized and necessary to perform assigned duties or as otherwise permitted or required by law. This obligation applies to information concerning people supported, families, employees, applicants, contractors, vendors, investigations, personnel matters, business operations, and protected health information. Suspected loss, unauthorized access, use, or disclosure must be reported immediately in