Complaints and grievances regarding program and services or access to health care services for enrolled consumers are to be directed to the appropriate State office. If a HealthCare Access Maryland (HCAM) consumer has a concern, unanswered question, or complaint regarding his/her treatment or quality of service delivered by HCAM, the consumer may exercise his/her right to file a grievance by following the steps below.
Step 1: The consumer should first address their question, concern, complaint, or grievance to the person perceived as the source of the confusion or conflict. It is anticipated that most conflict will be resolved in this step. If not resolved by direct communication at the source of the problem, or if the consumer does not wish to address the other person involved, he/she may proceed to step 2.
Step 2: The consumer may consult the HCAM employee’s direct supervisor, explain the conflict, and solicit the Human Resources Manager’s intervention as a conflict resolution mediator. It is the duty of the Human Resources Manager to inform all involved parties of the conflict, collect information, conduct an investigation, conduct interviews, and help facilitate a mutually agreeable resolution. If the consumer wishes to remain anonymous or to appoint a representative as his/her spokesperson or advocate, the Human Resources Manager should accommodate and protect the wishes of the consumer. The consumer may request a meeting of all involved parties and solicit the assistance of the Departmental Supervisor and Human Resources Manager as a mediator. A mutually agreed upon neutral party may also serve as a mediator. Notes of this meeting should be taken for documentation purposes.
Step 3: The consumer may choose to bypass steps 1 and 2 and initiate a grievance directly to HCAM’s CEO. This step may be taken with or without the knowledge of the staff involved in the grievance. The grievance may be communicated by telephone or letter. A letter is preferred for the purpose of clear understanding. (If the consumer wishes to maintain anonymity, it should be approached with the understanding that a full investigation may not be achieved.) Grievances should be addressed to:
HealthCare Access Maryland, Inc.
c/o President
1 N Charles Street, Suite 900
Baltimore, MD 21201
When a grievance is received in the CEO’s office, written notification must be sent to the complainant within 15 calendar days. It is incumbent upon the CEO, the Human Resources Manager, or the Departmental Supervisor to conduct a professional, impartial, timely, and thorough investigation within 30 days. A letter detailing the findings of the investigation and any action to be taken by HCAM will be generated and sent to the consumer at the conclusion of all investigative activities.
- FRAUD, WASTE, ABUSE, AND FINANCIAL IMPROPRIETY PREVENTION…
It is the policy of HealthCare Access Maryland to safeguard and protect all of HCAM’s resources. HCAM’s Administration Department and Executive Team are primarily responsible for safeguarding resources by establishing and maintaining sound internal controls designed to deter and detect potential misuse of resources, by taking action to minimize financial loss when misuse occurs, and by correcting abuse. All employees and board members are responsible for reporting improprieties they observe.
Any member of the staff or member of the board of directors who has information about known or suspected financial improprieties, misuse of the organization’s resources, or other ethical problems is encouraged to report their concerns to the Corporate Compliance Officer (CCO), who will then investigate. In the event that the allegations involve the CCO, the individual may report their concerns directly to the HCAM’S CEO. In the event that the allegations involve the CEO of HCAM, the individual may report their concerns directly to HCAM’s Board President. The sources of reports about financial improprieties and misuse of the organization’s resources will be held in confidence unless the individual who reports the situation agrees to reveal his/her identity or the report leads to legal actions and a court order is issued for information regarding the case.
HCAM will investigate any possible impropriety or fraudulent or dishonest use or misuse of HCAM’s resources or property by board members or staff. Anyone found to have engaged in an impropriety or fraudulent activity is subject to disciplinary action by HCAM up to and including termination or dismissal and civil or criminal prosecution, when warranted.
Examples of fraudulent conduct or impropriety include but are not limited to the following:
- Misappropriation or misuse of the organization’s resources, such as funds, supplies, or other assets
- Authorizing or receiving compensation for goods not received, services not performed, or hours not worked
- Forgery or alteration of documents belonging to HCAM and/or its partners
- Pursuit of a benefit or advantage in violation of HCAM’s conflict of interest policy
- Abuse or inappropriate activity with a program participant
- Fraudulent financial reporting
- Fraudulent reporting of work completed (e.g., number of clients seen, etc.)
Criteria used to determine whether certain activities or behavior constitute misuse of resources include state and federal laws and HCAM’s internal policies and procedures.
