Compliance and Ethics Commitment

At ADAPT of the Hudson Valley, we hold ourselves to the highest ethical, legal and professional standards. That affects everything we do: it means we promote responsible, honest conduct; that our business transactions are transparent; and that we not only respect the laws and regulations of the government agencies that fund our work, but work every day to offer the very highest standards of care.

Our Compliance Program is central to how we maintain these standards. Its key elements start with written standards.

1. Written Standards of Conduct, Policies and Procedures

The Code of Ethics and Employee Handbook sets clear expectations about how we should act toward the individuals and families we support, the vendors with whom we do business, the government entities that regulate and fund us, and even how we interact with our colleagues.

We also have specific policies and procedures addressing:

    • Conflict of Interest
    • Compliance, Ethical Responsibility Reporting
    • False Claims and Whistleblower
    • Incident Reporting
    • Employee Time and Attendance
    • Documentation of Services Rendered
    • Billing for Services including processes to detect, record and correct errors
    • Gift Acceptance
    • Consultant and Vendor Agreements
    • Abuse and Neglect

2. The Compliance Officer and Compliance Committee

The agency’s Compliance Officer coordinates and monitors compliance activities across the agency, with the help of a committee made up of employees from across the agency. The Compliance Committee meets to monitor compliance activities, evaluate the effectiveness of the Compliance Program, discuss best practices and recommend changes when appropriate.

3. Education and Training

All staff receive Compliance training when they are first hired and every year after that. Members of the Board of Directors also attend annual training.

4. Internal Lines of Communication

ADAPT of the Hudson Valley is committed to fostering open communications at all levels within the organization. If you are an employee, vendor or contractor who thinks there may be an issue with abuse, fraud or waste, you are urged to report the situation to a member of ADAPT of the Hudson Valley’s Management Staff, or to:

    • Vincent Carlucci
      Director of Corporate Compliance and Quality Improvement 845-695-2586
    • ADAPT of the Hudson Valley Anonymous Reporting & Ethics Hotline
    • Christine Sutton
      Director of Human Resources 845-695-2505

For an employee, reporting misconduct is an obligation set out in our Code of Ethics, whenever you have reason to believe it is taking place. No attempt will be made to identify an individual who requests anonymity, and even if you choose to use your name, your name will not be revealed unless required by law or usual circumstances.

No person who makes a report in good faith has to worry about retaliation. The agency is committed to responding promptly and appropriately.

5. Disciplinary Guidelines

Every employee is expected to uphold the agency’s high ethical standards and any violation of the Code of Ethics is subject to a disciplinary action, which could result in sanctions, from warnings to suspension or termination.

6. Monitoring and Auditing

The agency works hard to prioritize risk and monitor accordingly taking into account changes in regulatory requirements, operations or business practices.

7. Responding to Compliance Issues

As part of its Compliance Program, ADAPT of the Hudson Valley will insure that all reports of suspected waste, fraud or abuse or violations of the agency Code of Ethics will be immediately and objectively investigated and resolved promptly.

8. Protection from Retaliation

To ensure that no one who makes a good faith report of a problem is punished in any way at all, the Agency is committed to disciplining any employee who discharges, suspends, threatens, or otherwise discriminates against an employee who in good faith initiates or assists in reporting a suspected violation of our Code of Ethics.


The following members of the ADAPT of the Hudson Valley Compliance Department are available to support you:

Vincent Carlucci
Director of Corporate Compliance & Quality Improvement
Cell 845-806-1971 | Office 845-695-2586

Kayla Babcock
Manager of Compliance & Quality Improvement – Internal Audits
Cell 845-645-2074 | Office 845-695-2587

Jeremy Morgan
Manager of Compliance & Quality Improvement – Incident Management
Cell 845-649-9500 | Office 845-695-2583

Samantha Northcote
Fleet Management Specialist
Cell 845-645-2106 | Office 845-695-2582


Protecting confidential health information is essential to an agency like ours and the Health Information Portability and Accountability Act (HIPAA) is the Federal law that secures protected health information (PHI).

We have developed policies and procedures that ensure our compliance with HIPAA regulations. These policies can be found on the agency’s Intranet site. Please click here to access the Agency’s Notice of Privacy Practices.

If you have any questions or concerns you may contact:

Privacy Officer – Vincent Carlucci
Cell 845-806-1971

Security Officer – Micah DeVries
Cell 845-395-8184