The Ulster County Comptroller’s Office released an audit of the Ulster County Corporate Compliance Program, identifying areas for enhancement in training and structural changes to the Corporate Compliance Committee.

Corporate compliance, essential for certain federal and state funding, entails adherence to relevant laws and regulations. The audit emphasized that improved training and changes in committee structure, process, and communications could mitigate risks. Historically, senior management and executives have not consistently met training requirements, though compliance has improved under the current administration.

The audit noted that the program agreed to assign unique tracking numbers to complaints, facilitating better tracking. The risk assessment, currently limited to early childhood education and homecare programs, could expand to other areas. Additionally, the Compliance Committee could be strengthened with representation from the Legislature and the Comptroller’s office.

Comptroller March Gallagher highlighted the need for more targeted communications, suggesting that personnel-related matters and Medicaid fraud allegations should be reported in summary form to provide a broader risk overview. She also pointed out that the Medicaid fraud hotline receives more calls than the compliance hotline, which still references former County Executive Michael Hein’s anti-fraud initiative.

“By setting a tone from the top on training, streamlining communications, tracking complaints with unique identifiers, and sending all complaints to an expanded committee, the County’s Corporate Compliance Program can better serve taxpayers by identifying and addressing risks,” Gallagher said.

In response, Corporate Compliance Officer Thomas Gibney and Deputy County Executive Jamie Capuano welcomed the audit’s recommendations and provided corrections to some of the audit’s data and analysis.

Management Response
The Compliance Committee acknowledged the need for rigorous review and stated plans to implement several audit recommendations. They highlighted improvements in training completion rates since the introduction of an online training module in 2023. While previous audits failed to account for completion rates over time, the 2023 training completion rate reached 95%, significantly higher than in previous years.

The Compliance Committee agreed to share lists of employees who fail to complete training with supervisors but disagreed with rewarding employees for mandatory training completion. They also committed to implementing a unique tracking number for all complaints and improving the transparency and documentation of compliance issues.

Regarding communication, the committee emphasized the distinction between the Corporate Compliance hotline and the Special Investigation Unit hotline. They clarified that personnel matters fall outside the Corporate Compliance Program’s scope.