1st Choice Ambulette
Medicaid Compliance

Our Commitment to Compliance

Facility Transport Solutions, Inc., d/b/a 1st Choice Ambulette, has adopted and maintains a Medicaid Compliance Program under 18 NYCRR Subpart 521-1, NY Social Services Law § 363-d, and 42 U.S.C. § 1396a(a)(68). We bill only for trips we actually performed, we run safe and properly credentialed vehicles, and we do not retaliate against anyone who reports a concern in good faith.

Standards of Conduct

Every employee, manager, contractor, and member of the governing body is expected to follow these standards:

  • Bill only what we did. Trips actually rendered, at the correct level of service, under a valid authorization. No upcoding, no ghost trips, no billing after a recipient is hospitalized or deceased.
  • Document accurately and on time. Manifests, GPS, signatures, credentials — contemporaneous and truthful. Never alter, destroy, or hide a record.
  • Drive safely and legally. No operating with expired license, 19A, medical card, or vehicle inspection. Secure every wheelchair. Report every accident.
  • No kickbacks, no gifts to referral sources. Nothing of value offered, paid, solicited, or accepted to induce Medicaid referrals. De minimis branded items only.
  • No Excluded Persons. Nobody on OIG LEIE, federal SAM, or NY Medicaid exclusion lists works for us or contracts with us on Medicaid service.
  • Protect health information. Access PHI only as needed for the job. No discussing recipients in public, in text messages, or on social media. Don't leave manifests in vehicles.
  • Speak up. Report concerns — internally or directly to OMIG. We do not retaliate.
  • Keep records six years. Trip records, driver files, vehicle files, billing records.

These standards apply at every level of the company, including the owner and the Compliance Officer.

How to Report a Compliance Concern

You can report fraud, waste, abuse, or any other compliance issue through any of the channels below. Reports are kept confidential to the extent allowed by law. You may also report directly to a government agency — you are not required to use an internal channel first.

1. Compliance Officer

Gil Amado, President & CO

2. Confidential Mail

Mark "CONFIDENTIAL"

  • Attn:Compliance Officer — CONFIDENTIAL
  • Co.:Facility Transport Solutions, Inc.
  • Addr:236 Seaman Ct., Westbury, NY 11590

Opened only by the Compliance Officer.

3. Anonymous Hotline (24/7)

Truly anonymous

  • Phone:[hotline phone — coming soon]
  • Web:[hotline web — coming soon]
  • Drop box:Locked box in the main office, retrieved monthly by the Outside Committee Member.

Operated by a third party. No caller ID. Not routed through the Compliance Officer.

4. Report Outside the Company

Government channels

You may report directly. We will not retaliate.

Non-Retaliation

We do not retaliate against any employee, contractor, or Medicaid recipient who, in good faith, reports a compliance concern, cooperates in an investigation, or reports to a government agency. Retaliation is itself a serious violation that will result in discipline up to termination.

Your rights are also protected by federal and New York law — including the federal False Claims Act (31 U.S.C. § 3730(h)), the NY False Claims Act (NY State Finance Law § 191), and NY Labor Law § 740 and § 741.

The identity of any reporter is kept confidential except as necessary for disciplinary action, referral to MFCU/OMIG/law enforcement, or legal proceedings. The anonymous channel is not traced and the Compliance Officer does not attempt to identify anonymous reporters.

What Our Compliance Program Covers

Our written program implements the seven elements required by 18 NYCRR § 521-1.4 and addresses the risk areas required by § 521-1.3(d), tailored to non-emergency medical transportation:

  • Trip verification and billing integrity (GPS, Tobi, manifest reconciliation).
  • Broker billing accuracy (MAS, ModivCare, MTM) — roster / authorization matching, no duplicates, coordination of benefits.
  • Driver and vehicle credentialing (NY VTL Article 19-A, license, DOT medical card, inspection, insurance).
  • Standing-order reconciliation against facility census (no billing after hospitalization, discharge, or death).
  • Monthly exclusion screening (OIG LEIE, federal SAM, NY Medicaid exclusion lists).
  • Anti-kickback and gift restrictions (including the MTA Vendor Code of Ethics).
  • HIPAA / PHI handling in a transportation context.
  • 60-day overpayment return rule and OMIG self-disclosure.
  • Annual compliance training for all Affected Individuals; new-hire training within 30 days.
  • Quarterly Compliance Committee meetings; annual program effectiveness review; ETIN annual certification.

Whistleblower Laws That Protect You

Federal False Claims Act (31 U.S.C. §§ 3729–3733)

Prohibits knowingly submitting false claims to the federal government, including Medicaid. "Knowingly" includes actual knowledge, deliberate ignorance, and reckless disregard. Civil penalties per claim plus treble damages. A whistleblower who brings a qui tam action may receive 15–30% of any recovery. Section 3730(h) separately protects whistleblowers from retaliation, with remedies including reinstatement and double back pay.

NY False Claims Act (State Finance Law §§ 187–194)

State analog for false claims to NY State, including Medicaid. Includes qui tam and anti-retaliation provisions.

NY Social Services Law § 145-b

Penalty of three times the amount falsely obtained from Medicaid by false statement or concealment.

NY Social Services Law §§ 145, 145-c, 366-b

Criminal penalties (§ 145) and benefit sanctions (§ 145-c) for fraudulently obtaining public assistance, including Medicaid; misdemeanor and felony penalties under § 366-b for fraudulent practices in furnishing medical assistance.

NY Penal Law Articles 155, 175, 176, 177

Larceny (Art. 155); offenses involving false written statements (Art. 175); insurance fraud (Art. 176); and Health Care Fraud (Art. 177). Article 177 specifically criminalizes knowingly providing materially false information to a health plan, including Medicaid and Medicaid Managed Care, in order to receive payment.

Federal Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b))

Criminalizes knowingly and willfully offering, paying, soliciting, or receiving remuneration to induce referrals under a federal health care program.

Civil Monetary Penalties Law (42 U.S.C. § 1320a-7a)

Civil penalties for false claims, kickbacks, and the employment of Excluded Persons.

NY Labor Law §§ 740 and 741

Prohibit retaliation against employees who disclose employer activity reasonably believed to violate law, or (for health care employees) to create a substantial and specific danger to public health or safety, or to constitute improper patient care. Remedies include reinstatement, back pay, and attorney's fees.

Questions

If you have a question about our Compliance Program or you'd like a copy of the full written Program, contact the Compliance Officer at compliance@1stchoiceambulette.com or 516-319-3103.