Compliance & Ethics

Care You Can Trust. Standards We Live By.

At Metro Community Health Centers, compliance is not an afterthought. It is built into how we deliver care, protect your privacy, and serve our communities across New York.

Why Compliance Matters

Healthcare compliance is more than paperwork. It is how Metro Community Health Centers protects patients, supports staff, and earns the trust of the communities we serve. Our program is mandated by federal and New York State law and reflects our commitment to ethical care.

Patient Protection

Safeguards for privacy, billing accuracy, and the quality of every visit.

Legal & Regulatory Alignment

Aligned with New York Social Services Law Section 363-d, 18 NYCRR Part 521, and the Deficit Reduction Act of 2005.

A Culture of Integrity

Ethics, honesty, and accountability across every program, location, and team member.

Continuous Improvement

Routine monitoring and auditing so we identify risks early and correct course quickly.

Our Program

Our Compliance Program

Metro Community Health Centers maintains an effective compliance and ethics program built on the standards established by the New York State Office of the Medicaid Inspector General (OMIG) and federal authorities. Our program is overseen by a designated Compliance Officer who reports directly to the Board of Directors and Chief Executive Officer.

The goals of our compliance program are to:

  • Detect and correct payment and billing errors
  • Make corrections quickly and document them thoroughly
  • Operate a system of checks and balances to prevent recurrence
  • Identify, assess, and address compliance risks
  • Repay any overpayments promptly, regardless of cause
  • Demonstrate a clear commitment to integrity in our operations
  • Build a culture of compliance and ethics across every team

This program is informed by Chapter 8 of the Federal Sentencing Guidelines, which recognizes an effective compliance and ethics program as a meaningful factor in how organizations are evaluated.

Read Our Code of Conduct

Mandated By Law

  • New York Social Services Law Section 363-d
  • 18 NYCRR Part 521
  • Deficit Reduction Act of 2005 (DRA)
  • 42 USC Section 1396a(a)(68)

The 7 Elements of an Effective Compliance Program

Required by SSL Section 363-d subdivision 2 and 18 NYCRR Section 521.3(c), these seven elements are the foundation of every credible healthcare compliance program. Metro Community Health Centers builds each one into our daily operations.

01

Written Policies & Procedures

Clear policies and a Code of Conduct that define ethical expectations and apply to every team member, contractor, and partner.

02

Compliance Officer & Committee

A designated Compliance Officer with direct reporting to the Board of Directors and CEO, supported by a multidisciplinary Compliance Committee.

03

Training & Education

Onboarding and annual training for all affected individuals on compliance expectations, risk areas, and how to raise concerns.

04

Open Lines of Communication

Multiple accessible channels (phone, email, in person) so anyone can report a compliance concern without fear of retaliation.

05

Disciplinary Standards

Clear, consistent implications for non-compliance and encouragement for good-faith participation in the program.

06

Auditing & Monitoring

Routine identification of risk areas through internal audits, monitoring activities, and an annual risk assessment.

07

Response & Corrective Action

A defined process for investigating concerns, correcting issues, repaying overpayments, and preventing recurrence.

Compliance Officer: Vonalis Piña, M.S.Ed., LCSW, SIFI - Director of Behavioral Health and Compliance Officer

Quality, Whole-Person Care, and Continuous Improvement

Compliance is the floor. Quality is the ceiling we keep raising. Our quality improvement work, Patient-Centered Medical Home model, and integrated Behavioral Health services all reinforce safe, equitable, and effective care.

Quality Improvement

We continuously measure outcomes, gather patient feedback, and refine our processes so that every visit is safer and more effective than the last.

Patient-Centered Medical Home (PCMH)

Our care teams coordinate around you. Primary care, specialty referrals, preventive screenings, and chronic disease management work together as one connected experience.

Behavioral Health Integration

Mental health and primary care are not separate journeys. Our integrated model brings behavioral health support directly into the care you already receive.

Privacy & HIPAA

Your Privacy. Protected.

Metro Community Health Centers complies with the Health Insurance Portability and Accountability Act (HIPAA) and all applicable New York State privacy regulations. Your health information is used and shared only as permitted by law and as needed to deliver, coordinate, and pay for your care.

You have the right to:

  • Receive a copy of your medical records
  • Request corrections to your records
  • Know with whom we have shared your information
  • Request restrictions on how your information is used
  • File a privacy complaint without fear of retaliation

Your Right to a Good Faith Estimate

Under the federal No Surprises Act, you have the right to receive a Good Faith Estimate of expected charges for medical items and services if you are uninsured or choose not to use your health insurance to pay for care.

What this means for you:

  • You can ask for a Good Faith Estimate before you schedule a service, or any time during care
  • If you receive a bill more than your Good Faith Estimate, you may be eligible to dispute the charges
  • Asking for an estimate or starting a dispute will never affect the quality of your care

For more information, visit www.cms.gov/nosurprises or call our billing team. Save a copy of your Good Faith Estimate for your records.

Request a Good Faith Estimate
We Want to Hear From You

Report a Compliance Concern

Metro Community Health Centers is committed to ensuring that it has a system in place to respond to possible compliance issues. We will investigate and respond to potential compliance issues as they are identified.

If you believe that a member of the Metro Community Health Centers community is not living up to the highest standards of business ethics and integrity or has committed fraud, please contact our Corporate Compliance Department.

You will not face retaliation for reporting a concern in good faith. Reports may be made anonymously.

Compliance Officer

Vonalis Piña, M.S.Ed., LCSW, SIFI - Director of Behavioral Health and Compliance Officer

Email

MCHCcompliance@mchcny.org

Corporate Compliance Helpline

855-804-1489

Available 24 hours a day, 7 days a week

Frequently Asked Questions

Quick answers about our compliance program, your rights, and how we protect the integrity of your care.

What is a healthcare compliance program?
A compliance program is a structured set of policies, training, monitoring activities, and reporting channels that helps an organization follow the laws and ethical standards that govern healthcare. At Metro Community Health Centers, our program is designed to detect and correct billing errors, prevent fraud, protect patient privacy, and build a culture of integrity across every team.
Why does Metro Community Health Centers have a compliance program?
We are required by law to maintain an effective compliance program under New York Social Services Law Section 363-d, 18 NYCRR Part 521, the Deficit Reduction Act of 2005, and 42 USC Section 1396a(a)(68). Beyond what the law requires, an effective program is the right thing to do for our patients, staff, and community.
Who oversees compliance at MCHC?
Our Compliance Officer, Vonalis Piña, M.S.Ed., LCSW, SIFI, is responsible for the day-to-day operation of the compliance program. The Compliance Officer reports directly to the Chief Executive Officer and the Board of Directors and works with a multidisciplinary Compliance Committee.
How do I report a compliance concern?
You can call our Corporate Compliance Helpline at 855-804-1489 or email MCHCcompliance@mchcny.org . Reports may be made anonymously. We do not retaliate against anyone who reports a concern in good faith.
What kinds of issues should I report?
Anything that does not feel right, including suspected billing errors, fraud, waste, abuse, privacy violations, conflicts of interest, or behavior that conflicts with our Code of Conduct. If you are unsure, please reach out and let us help you figure out the right next step.
Will I get in trouble for reporting?
No. Our non-retaliation policy protects anyone who raises a concern in good faith. You can also choose to report anonymously.
What happens after I report?
The Compliance Officer reviews every concern, decides on the right investigation steps, and works with the relevant departments to respond. We document our findings, take corrective action when needed, and follow up so the issue does not recur.
What is HIPAA, and how does it apply to me?
HIPAA is a federal law that protects your health information. It gives you rights to access, correct, and control how your information is shared. Our Notice of Privacy Practices explains those rights in detail and tells you how to file a privacy complaint.
Who qualifies for a Good Faith Estimate under the No Surprises Act?
Under federal law, uninsured patients and patients who choose to pay out of pocket without using their health insurance are entitled to a Good Faith Estimate of expected charges for scheduled services. You can also request one any time you are quoted a service.
What if my final bill is much higher than my Good Faith Estimate?
If your billed charges are at least $400 more than your Good Faith Estimate, you may be able to dispute the bill through the federal patient-provider dispute resolution process. You generally have 120 days from the date of the disputed bill to start a dispute. Asking for a dispute will not affect the quality of your care.