LOS ANGELES COUNTY
DEPARTMENT OF MENTAL HEALTH
  Policy 106.01 Compliance Program Communication
 
Policy Category:  Administrative
Distribution Level:  Directly-Operated Programs and Contracted Agencies
Responsible Party:  Compliance, Privacy, and Audit Services
 
Approved by Marvin J. Southard, DSW, Director on December 3, 2012
 
I.  PURPOSE
 
To describe particular means by which the Los Angeles County Department of Mental Health (DMH/Department) will establish lines of communication between the DMH Compliance Officer and the employees or other DMH stakeholders, as required by the Code of Federal Regulations Title 42 Section 438.608 (b)(4).
 
II.  POLICY
 
  1. DMH will uphold the highest ethical standards and comply with all rules, regulations, codes, and policies governing the provision of, and reimbursement for, mental health services provided to consumers by or on behalf of Los Angeles County.
     
  2. To support ethical behavior and legal/regulatory compliance, DMH has established the following mechanisms for use by DMH employees or other stakeholders to raise questions, report concerns, or perceived violations. 
     
    1. Most questions or concerns can be resolved promptly on a division/bureau/organizational unit level. This policy does not replace the traditional chain of command mechanism of communication and problem resolution. Rather, it is intended to provide additional paths that may be utilized by employees or other stakeholders for clarification of Departmental policies, mandates, and standards or for the reporting of perceived ethical or legal Compliance Program violations.
       
    2. To ask clarifying questions, express concerns, or report perceived violations, employees and stakeholders may contact:
       
      1. DMH Compliance, Privacy, and Audit Services Bureau (CPAS) by:
         
      2. County of Los Angeles Fraud Hotline by:
         
        • Telephone: 800-544-6861,
        • Fax: 213-633-0991, or
        • Write to: 

          Office of County Investigations
          500 W. Temple Street, Room 515
          Los Angeles, CA 90012
           
  3. In accordance with the Los Angeles County Code of Ordinances, Title 5 Personnel, Chapter 5.02 General Regulations, Section 5.02.060 Retaliation for Reporting Fraud, Waste or Misuse of County Resources Prohibited.
     
    1. No officer or employee of the County of Los Angeles shall use or threaten to use any official authority or influence to restrain or prevent any other person, acting in good faith and upon reasonable belief, from reporting or otherwise bringing to the attention of the County Auditor-Controller or other appropriate agency, office or department of the County of Los Angeles any information which, if true, would constitute: a work related violation by a County officer or employee of any law or regulation; gross waste of County funds; gross abuse of authority; a specific and substantial danger to public health or safety due to an act or omission of a County official or employee; use of County office or position or of County resources for personal gain; or a conflict of interest of a County officer or employee.
       
    2. No officer or employee of the County of Los Angeles shall use or threaten to use any official authority or influence to effect any action as a reprisal against a County officer or employee who reports or otherwise brings to the attention of the Auditor-Controller or other appropriate agency, office or department of the County of Los Angeles any information regarding subjects described in section C.1.
       
    3. Any person who believes he/she has been subjected to any action prohibited in sections C.1. and C.2. may file a complaint with the director of personnel. The Director shall investigate the complaint and thereafter prepare a report thereon which shall be forwarded to the Board of Supervisors.
       
    4. Any officer or employee of the County of Los Angeles who knowingly engages in conduct prohibited by this section shall be disciplined, including but not limited to discharge, in accordance with the personnel rules and regulations of the County of Los Angeles. (Ord. 88-0162 § 1, 1988)
III.  PROCEDURES
 
IV.  AUTHORITIES
 
Code of Federal Regulations Title 42 Section 438.608 (b)(4)
Los Angeles County Code of Ordinances Title 5 Chapter 5.02 Section 5.02.060
DMH Code of Organizational Conduct, Ethics, and Compliance
 
V.  ATTACHMENT