LOS ANGELES COUNTY
DEPARTMENT OF MENTAL HEALTH
  Policy 106.11 Compliance Plan
 
  PROCEDURES
  1. Compliance, Privacy, and Audit Services (CPAS) shall report to the Office of the Chief Deputy Director to maintain its independence and objectivity.
     
  2. CPAS will incorporate in its operations the Elements for an Effective Compliance Program as defined by the Code of Federal Regulations Title 42 Section 438.608.
     
    1. Develop and implement written policies and procedures and standards of conduct that articulate the Department’s commitment to comply with all applicable federal and State standards (DMH Policy 106.02);
       
    2. Designate a Compliance Officer and a Compliance Program Steering Committee (DMH Policies 106.07 and 106.12);
       
    3. Conduct effective training and education for the Compliance Officer and the Department’s employees;
       
    4. Develop effective lines of communication between the Compliance Officer and the Department’s employees (DMH Policy 106.01);
       
    5. Enforce standards through well publicized disciplinary guidelines, including but not limited to continuing to not hire or employ sanctioned individuals (DMH Policies 106.03 and 605.01);
       
    6. Conduct internal auditing and monitoring; and
       
    7. Provide for prompt response to detected offenses, develop corrective action plans, and report to the proper enforcement authorities. 
       
  3. In addition to the elements identified above in Sections B.1. - B.7., CPAS will continuously identify areas of risk through its auditing and monitoring and special reviews that may need management attention and/or corrective actions.
     
    1. CPAS will participate in the Los Angeles County Department of Mental Health Risk Management Roundtable (DMH Policy 106.16).
       
    2. CPAS will respond to potential non-compliance issues detected through routine monitoring.
       
    3. CPAS will respond to alleged non-compliance issues as reported to CPAS through other channels including the Los Angeles County Auditor-Controller’s Office.