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Summary of Corporate Compliance Plan
Introduction
Message to Ohel Children’s Home and Family Services Employees and Vendors
This manual provides guidance to Ohel’s employees, Board and vendors on its Corporate Compliance Program. We have developed this Program to ensure that we comply with federal, state and city laws governing our work and that we adhere to the highest ethical standards in doing so. The Board of Directors and Executive Management are committed to complying with this Program. As part of this commitment, we will educate and train you on the compliance program’s standards, assist you to comply with its provisions and provide an environment in which you can comply without fear of retaliation. In addition, we have provided several methods for you to report suspected violations of the compliance policies, including a confidential Hotline at (718) 438-0941.

In all of our work, we are committed to conducting ourselves with integrity, both in the delivery of services and in obtaining payment for those services. This commitment cannot be achieved without your commitment and help. We hope you will join us in this endeavor.      

Moshe Hellman    David Mandel 
President      Chief Executive Officer 

Code of Conduct
As an integral member of Ohel’s team, employees are expected to accept certain responsibilities, adhere to acceptable business principles in matters of personal conduct, and exhibit a high degree of personal integrity at all times.  This not only involves sincere respect for the rights and feelings of others but also demands that both in an employee’s business and in their personal life they refrain from any behavior that might be harmful to themselves, their coworkers, and/or the agency, or that might be viewed unfavorably by current or potential customers or by the public at large. Whether employees are on or off duty, their conduct reflects on Ohel.  They are, consequently, encouraged to observe the highest standards of professionalism at all times.

Listed below are some of the rules and regulations of the Agency.  This list should not be viewed as being all-inclusive.  Types of behavior and conduct that Ohel considers inappropriate and which could lead to disciplinary action up to and including immediate termination of employment without prior warning, at the sole discretion of the Agency, include but are not limited to, the following:

Falsifying employment or other Agency records, including, but not limited to, billing documentation, progress notes and contact records
Knowingly presenting or causing to be presented a false or fraudulent claim to the Federal government for payment;
Knowingly making, using, or causing to be made or used, a false statement to get a false or fraudulent claim paid by the Federal government;
Improper or fraudulent billing for health care services;
The preparation of inaccurate or incomplete cost reports;
The payment or receipt of kickbacks in return for client referrals; and
The misuse of Agency funds. 
Inaccurate documentation
Violating the Agency’s nondiscrimination and/or sexual harassment policy
Soliciting or accepting gratuities from customers or clients
Establishing a pattern of excessive absenteeism or tardiness
Engaging in excessive, unnecessary, or unauthorized use of the Agency’s supplies, particularly for personal purposes
Reporting to work intoxicated or under the influence of nonprescribed drugs
Illegally manufacturing, possessing, using, selling, distributing, or transporting drugs
Bringing or using alcoholic beverages on the Agency’s property or using alcoholic beverages while engaged in the Agency’s business off Agency premises, except where authorized
Fighting or using obscene, abusive, or threatening language or gestures
Stealing property from coworkers, customers, or clients of the Agency 
Having unauthorized firearms on Agency premises or while on Agency business
Disregarding safety or security regulations
Engaging in insubordination
Failing to maintain the privacy and security of the Agency, customer, or client information
There shall be no use of corporal punishment upon consumers
Engaging in any activity that constitutes abuse of consumers as defined in state and federal regulations 
Modeling inappropriate or unacceptable behavior to a client
Failing to maintain client information as confidential and failing to utilize such information in a professional manner at all times.  To the extent employees or volunteers obtain HIV related information concerning a client, such information shall be maintained in confidence as required by applicable law
Clients shall not carry out the duties of employees unless such tasks are described in their plan of service by their planning team for the purpose of increasing their skills
Clients shall not be subject to inappropriate exposure to firearms or other weapons in or on the grounds of the agency’s facilities.  However, this shall not prevent an individual from pursuing the opportunity to receive certification of successful completion of a hunter safety course for a specified firearm or weapon, and the subsequent appropriate use of such firearm or other weapon deemed appropriate and documented in the individual's plan of services.
There shall be no personal financial transactions between employees, volunteers, and clients, unless with the express written authorization of the Corporate Compliance Officer.
Clients shall not be left alone, unsupervised in their residence unless there is specific, written permission for them to be left alone as per their plan of service.
There shall be no smoking in agency program sites unless there is a specific designated area for such.

If an employee’s performance, work habits, overall attitude, conduct, or demeanor becomes unsatisfactory in the judgment of the Agency, based on violations either of the above or of any other Agency policies, rules, or regulations, the employee will be subject to disciplinary action, up to and including dismissal.

Ohel is committed to providing quality residential and non-residential services for individuals with developmental and/or psychiatric disabilities and other services to its clients, while observing the highest standards of professional, clinical, legal and business ethics.  Employees are expected and trained to treat all clients with dignity and respect and comply with all applicable privacy and security laws, including the Health Information Portability and Accountability Act (HIPAA).  Training on these items, among others, is provided as part of our orientation process and detailed in Agency policy and procedure.  Ohel’s Compliance Program forms the foundation of Ohel’s overall compliance efforts, which seek to ensure continuing compliance with all applicable laws, rules, regulations and contractual obligations that govern Ohel’s operations. 

Ohel developed its Compliance Program, including its Code of Conduct and policies and procedures that address key risk areas, to guide its best efforts to operate under ethical and legal standards.  Ohel expects that all aspects of patient care and business conduct will be performed in compliance with this Compliance Program, professional standards and applicable governmental laws, rules and regulations.

To demonstrate that Ohel has developed an effective compliance program, Ohel must demonstrate that it has (1) developed standards, procedures, and a Code of Conduct in order to reduce the prospect of improper conduct; (2) designated a high-level individual to oversee compliance; (3) taken steps to train and communicate the standards to employees, Board members and vendors, as appropriate; (4) engaged in internal auditing on fiscal compliance and established a reporting system by which employees can report potential misconduct without fear of intimidation or retribution; (5) developed disciplinary policies to encourage good faith participation in the Compliance Program by all affected individuals and taken appropriate disciplinary measures against individuals found to have violated the Compliance Program or related policies and procedures; (6) developed a policy of non-intimidation and non-retaliation for good faith participation in the Compliance Program; and (7) taken reasonable steps to respond to and prevent future violations.  The following Compliance Program Overview establishes the steps Ohel has implemented to ensure the effectiveness of its Program.

Policies and Procedures Overview
Ohel’s compliance philosophy is expressed within this Compliance Program and related documents, including the Code of Conduct and policies and procedures related to compliance, clinical operations, human resources and fiscal management. Collectively, these documents establish standards and procedures that must be followed by Ohel employees and, as applicable, independent contractors and the Board.  Understanding and following these standards will reduce the prospect of unethical, illegal and criminal conduct. 

The Code of Conduct emphasizes the shared common values and culture Ohel seeks to cultivate that guide Ohel’s operations each day.  As part of the hiring and appointment process, Ohel will disseminate the Plan to new employees and Board members and train them on such.  Ohel also requires that a copy of the Ohel Compliance Program and Code of Conduct be provided to all independent contractors that are required to receive such by applicable law.  Ohel will review, revise and develop new policies and procedures, as necessary, to ensure that Ohel operations are conducted in accordance with any changes in law or newly identified areas of significant risk. 

Compliance Program Structure and Oversight Responsibilities
Corporate Compliance Officer

Ohel has designated a Compliance Officer with overall responsibility for the day-to-day management and oversight of the development, implementation, operations and revision of the Compliance Program. The Compliance Officer reports directly to the Chief Administrative Officer (“CAO”), and periodically to the Board of Directors or its Risk Management Committee.  The Compliance Officer may be reached at 718-686-3320 or through the confidential Compliance Hotline at (718) 438-0941.  The duties and responsibilities of the Corporate Compliance Officer include: 

With the assistance of the Corporate Compliance Committee, developing, overseeing and monitoring implementation of the Compliance Program, including the Code of Conduct and the Hotline, and ensuring that the effectiveness of the Compliance Program is maintained at all times so that Ohel may certify annually to the Department of Health that this Program meets the requirements of 18 NYCRR Part 521;

Developing, coordinating and participating in a multifaceted educational and training program that focuses on the key elements of the Compliance Program and seeks to ensure that all Ohel employees and the Board are knowledgeable of, understand, and comply with, pertinent federal and state legal and regulatory requirements;

Developing and implementing specific written policies and procedures that establish processes to facilitate regulatory compliance, as well as disciplinary guidelines for violations of the Compliance Program, and that encourage Ohel employees to report suspected fraud and other improprieties without fear of retaliation;

Assessing areas of risk for the organization and tailoring the operations of the Program (policies, training, auditing) to those risk areas;

Directing and coordinating activities related to regular internal audits to investigate and monitor compliance with standards and procedures under the Compliance Program and applicable laws and regulations

Serving on the Board of Directors’ Risk Management Committee and updating the Committee on the activities of the Compliance Program, including internal audit findings, identified risk, reporting by employees, and disciplinary actions for breaches of the Program. 

Corporate Compliance Committee
Ohel has established a Corporate Compliance Committee to assist the Compliance Officer in the development, implementation, oversight and evaluation of the effectiveness of its compliance program.  The members of the Compliance Committee will be appointed by the CEO of Ohel.  In appointing members of the Compliance Committee, the CEO shall include management representatives from a broad cross section of departments, including, at a minimum, finance, human resources and clinical.  The primary responsibility of the Compliance Committee, which will be chaired by the Compliance Officer, is to assist the Compliance Officer in the development, implementation, oversight and evaluation of the effectiveness of the Compliance Program, to assist in the annual review of the Compliance Program and its activities and to provide feedback to the CEO and to the Board of Directors, or the Risk Management Committee of the Board, on the effectiveness of the Compliance Officer and the Compliance Program.

The Compliance Committee will receive reports from the Compliance Officer on issues, incidents and reports that are under investigation, will assist the Compliance Officer in developing recommendations for corrective action to be presented to the [Executive Director/CEO], the Board and, as appropriate, senior management.  The reports will evaluate the effectiveness of the corrective actions, once implemented, in preventing any occurrence of the problems or behaviors targeted.

Members of the Compliance Committee will treat confidential and sensitive information that it has disclosed to the Compliance Committee in a manner that secures and protects it from further disclosure outside the direct activities of the Compliance Committee.  The members of the Committee will act individually in their various responsibilities as employees to promote compliance, to encourage employee participation in the Compliance Program, to answer questions about the scope and purpose of the program, to receive reports of concerns, incidents and inappropriate behaviors, and to bring these reports to the prompt attention of the Compliance Officer. Written minutes will be kept of all Compliance Committee meetings and actions, which minutes will be made available to the members of the Board of Directors upon request. 

Board of Directors
The Ohel Board of Directors, including the Board’s Risk Management Committee, will be knowledgeable about the content and operation of the Compliance Program and will be updated by Agency staff, including the Compliance Officer, regarding the implementation and effectiveness of the Compliance Program.  The training for the Board of Directors is further discussed in the Compliance Training policy.  The Board will exercise oversight of the effectiveness of the Program.

Due Care in Assignment of Responsibilities – Background Checks
Ohel will use due care not to employ, contract with or delegate substantial discretionary authority to any individual with a propensity to engage in illegal activities.  To maintain the integrity of services and financial and business operations, it is critical that Ohel hire and contract with individuals and entities that have the same respect for applicable legal and ethical obligations that Ohel has.  This standard applies to personnel in positions with “substantial” control over Ohel, including, but not limited to those having the ability to affect and determine policy and to negotiate contracts.  Each prospective employee will be required to disclose whether he or she has been convicted of committing a crime. 

As per the Employee Screening Policy, Ohel will determine if prospective employees have been excluded from participation in the federal healthcare programs by checking the LEIE, EPLS, and OMIG Exclusion Lists; Ohel will not hire or utilize the services of any individual or entity which has been excluded.  Ohel will also comply with any requirements promulgated under applicable state law with respect to background checks and appropriate screening activities to the extent those requirements apply to personnel within Ohel’s operations, including reviewing criminal history (fingerprints), motor vehicle records, and child abuse and neglect information.   Ohel may rely on third parties for this information.  

Education and Training
As per the Compliance Training policy, the Board and all employees will be informed about regulatory requirements, the operation of the Compliance Program, and Ohel policies and procedures that implement these requirements, as they apply to each individual.  Therefore, Ohel will discuss the Plan with the Board, substantial authority personnel and other employees. New employees, including executive-level employees, and the Board will receive training on the Ohel Code of Conduct, this Compliance Program and those policies and procedures relevant to their duties as part of an orientation program.  Ohel will tailor its training based on the roles and responsibilities of each group of individuals and in a manner that the individual can understand. 

Auditing and Reporting
Internal Auditing and Monitoring
As per the Internal Auditing Policy, Ohel is committed to routinely identifying compliance risk areas and conducting internal audits of identified areas of significant risk.  Appropriate individuals in key management positions will be responsible for engaging in self-monitoring processes conducted within specific departments/divisions.  The Agency’s Department of Quality Improvement will be primarily responsible for internally auditing Agency programs to identify compliance risk areas, ensure credentialing of providers and persons associated with providers, as appropriate, mandating reporting, governance, and quality of care of medical assistance program beneficiaries.  Generally, the Department will conduct random case record reviews to ensure that the programs are complying with all regulatory and contractual requirements, in addition to verifying the accuracy of the billing information.  Staff will compile a report based upon the internal review, which will be shared with appropriate supervisory staff.  Department staff will conduct a follow-up review, as appropriate, to ensure that corrective action was taken to address issues of concern. The Compliance Officer may engage external auditors to conduct additional reviews where appropriate.

Reporting by Employees
As per the Mandatory Reporting policy, each employee, vendor, and Board member has a responsibility to report through Ohel’s compliance processes any activity by any colleague, clinician, independent contractor or vendor that appears to violate applicable laws, rules, regulations, accreditation standards, standards of medical practice or the Compliance Program.  We encourage a culture in which all feel free to report behaviors or actions which they believe should be reported.  Therefore, the effectiveness of Ohel’s Compliance Program depends on the willingness and commitment of the employees in all parts and at all levels of Ohel to step forward, in good faith, with questions and concerns.  Likewise, Ohel is committed to making every effort to maintain, within the limits of the law, the confidentiality of the identity of any individual who reports a concern in good faith. 

It is an expected good practice, when one is comfortable with it and thinks it is appropriate under the circumstances, for concerns to be raised first with a supervisor or the Human Resources Department.  If this is not comfortable or not a viable option, then employees have the option to contact the Corporate Compliance Hotline at (718) 438-0941 where reports may be made confidentially.

As per the Non-retaliation policy, any and all employees who, in good faith, participate in the compliance program, including, but not limited to, reporting potential issues, investigating issues, self-evaluations, audits and remedial actions, and reporting to appropriate officials, will be protected against any retaliation or intimidation.  Any employee who intentionally makes a false accusation with the purpose of harming or retaliating against any individual will be subject to appropriate disciplinary action, up to and including termination.

Disciplinary Action and Incentives
As per the Employee Discipline policy, failure to comply with the Compliance Program, the Code of Conduct and/or laws and regulations applicable to Ohel and its operations may result in disciplinary action, up to and including termination.  Among other things, this relates to an employee’s failure to report suspected problems, participation in non-compliant behavior or encouraging, directing, facilitating or permitting, either actively or passively, non-compliant behavior.  Retraining of staff will occur if misconduct is based on a lack of awareness or understanding of a regulatory obligation, policy or procedure.  Resolution of disciplinary issues will be determined through the Human Resources Department in direct cooperation with the appropriate manager and, as appropriate, other management personnel of Ohel.  The degree of discipline may range from counseling, verbal warnings, written warnings, recommended change or discontinuation of privileges, salary reduction, termination of employment or removal from a particular position or function – and the Agency will endeavor to be consistent in its approach to discipline with the same disciplinary action for similar offenses.  In instances of a vendor’s failure to comply with the Plan, Ohel reserves the right to terminate the contract and/or seek other relief under the law.  Ohel will also seek to reward employees who foster a culture of compliance through merit-based increases, as appropriate.

Detection and Response
As per the Internal Auditing and Mandatory Reporting policy, Ohel is committed to fostering a culture of compliance through detecting, correcting and preventing non-compliant behaviors.  Through the process of corporate compliance reporting structure and the articulation of compliance-related roles and responsibilities at every level of Ohel’s operations, detection and correction of problems is expedited.  If an internal investigation substantiates a reported violation, then it is Ohel’s policy to engage in a two-fold process:  (1) to initiate corrective action, including, as appropriate, making prompt restitution of any overpayment amounts, notifying the appropriate governmental Agency, instituting whatever disciplinary action is necessary; and (2) implementing systemic changes to prevent a similar violation from recurring in the future.

Government Investigations
As per the Government Investigations policy, Ohel will comply with all government investigations as per applicable law. Please call or email Adam Lancer, the agency’s Corporate Compliance Officer, with any questions regarding compliance or client confidentiality issues (718-851-6300, adam_lancer@ohelfamily.org)  

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  • 07/03/2013 - OHEL Bais Ezra’s East Broadway Residence Ligh...
  • 07/03/2013 - OHEL Bais Ezra Ave M Residence Hosts Community ...
  • 06/20/2013 - OHEL Institute Autism Conference on Social Skil...
  • 06/20/2013 - OHEL Caregiving Evening- Addresses Needs of the...
  • 06/20/2013 - SKA and OHEL Team up to Help Provide for Foster...
  • 06/18/2013 - OHEL Scholar in Residence, Charlie Harary, Wows...
  • 06/17/2013 - OHEL Bais Ezra Woodmere Resident Celebrates Her...
  • 6/12/2013 - OHEL Bais Ezra Residents Welcomed in Community...
  • 6/11/2013 - OHEL Discusses Trauma on Nachum Segal Radio Show...
  • 6/5/13 -Touro and OHEL: Delivering Services in an In Increas...
  • 5/21/13 - Oklahoma Tragedy, OHEL Provides Pointers to Parent...
  • 4/4/13 OHEL Bais Ezra’s Annual Chol Haomoed Adventure...
  • 3/14/13 Socialize and Find Your Bashert...
  • 3/6/13 OHEL’S New Five Towns Office...
  • 2/18/13 OHEL Annual Gala 2013...
  • 2/6/13 OHEL Bais Ezra’s Sibshops Program Empowers Siblings...
  • 11/19/2012 - New Project Hope Crisis Counseling Program...
  • 11/14/2012 - OHEL Provides Comfort to Evacuated Residents...
  • 11/13/2012 - Free Carnival...
  • 11/12/2012 - Hurricane Sandy...
  • 11/11/2012 - Rosh Hashana ...
  • 10/31/2012 - Robert Katz as the New Chief Development Office...
  • 10/31/2012 - Etta Israel Center of L.A. Merges with OHEL...
  • 09/14/2012 - Bais Ezra Hosts Community-Wide BBQ...
  • 08/20/2012 - Camp Kaylie Inaugurates the Kleinman Bais Medra...
  • 08/03/2012 - Ruach K’tonton in West Hempstead...
  • 08/02/2012 - OHEL Congratulates Our Own Misayim HaShas...
  • 07/24/2012 - NBA Greats Thrill Campers...
  • 06/19/2012 - Golf Classic...
  • 05/26/2012 - Getting Older...
  • 05/21/2012 - Day of Remembrance...
  • 03/07/2012 - Challenges of Anger Disorders...
  • 03/06/2012 - Bais Ezra 30th Anniversary...
  • 02/14/2012 - Ohel Draws Capacity Crowd...
  • 01/25/2012 - Mel Zachter Named OHEL Co-president...
  • 01/16/2012 - Gary Schaer To Receive the “Legislator of the...
  • 01/02/2012 - Cherish the Children...
  • 10/05/2011 - OHEL Bais Ezra’s Sibshops Program Empowers Si...
  • 08/30/2011 - Kaylie Day: A Dream Fulfilled...
  • 06/28/2011 - Pomegranate’s Chef Boris Grills Up a Great T...
  • 06/24/2011 - OHEL Golf Classic...
  • 05/25/2011 - OHEL Institute for Training Workshop Addressing...
  • 04/13/2011 - OHEL Institute for Training Addresses Eating Di...
  • 03/17/2011 - Over 400 Celebrates Purim with Matisyahu...
  • 03/11/2011 - New OHEL Video Colorizes the World ...
  • 03/11/2011 - OHEL Appoints New Director of Development...
  • 03/02/2011 - Reggae Star Matisyahu To Perform ...
  • 12/20/2010 - OHEL Regional Family Center of Northern NJ Tra...
  • 12/16/2010 - OHEL Provides Training on Addictions ...
  • 12/16/2010 - OHEL Residents and Neighbors Gather for a BBQ ...
  • 12/07/2010 - OHEL Insitute Provides Training On Short-Term T...
  • 11/24/2010 - OHEL Sixth Annual Benefit Concert ...
  • 11/21/2010 - OHEL Benefit Concert November 21st...
  • 11/11/2010 - Team OHEL Wins For OHEL Bais Ezra Kids...
  • 11/10/2010 - OHEL Working Breakfast Addresses Student-Issues...
  • 11/09/2010 - Gaining Couple Therapy Expertise at OHEL...
  • 07/19/2010 - Large Turnout at First Camp Kaylie Open House...
  • 07/13/2010 - “Building Resiliency in Our Children”...
  • 06/28/2010 - OHEL Golf Classic Benefits Children!...
  • 06/08/2010 - Training for Parents of Children with ADHD...
  • 04/28/2010 - Long Islanders Ride for OHEL Residents of the 5...
  • 04/07/2010 - “Reaching Out to Special Friends” Competit...
  • 03/11/2010 - Shloime Dachs Annual Siyum and BBQ...
  • 03/01/2010 - OHEL Draws Capacity Crowd To Celebrate 40 Years...
  • 02/12/2010 - Malky Giniger Presents a Star-Studded New Show...
  • 02/05/2010 - Meeting the Challenge of Postpartum Depression...
  • 01/21/2010 - OHEL 40th Anniversary Annual Dinner...
  • 01/10/2010 - Professionals Prepare to Address Teen Behaviors...
  • 01/08/2010 - Record Number of OHEL Bais Ezra Day Trips ...
  • 01/03/2010 - OHEL Celebrates Purim with Le Cirque Du Purime...

ARTICLES

  • Overnight Respite...
  • Employment: The Power of a Paycheck...
  • After the Brooklyn fire tragedy in which seven children died...
  • Rav Elya Brudny and Others Address Over 200 at Conference to...
  • Does Alan Turing have Aspergers Syndrome?...
  • Foster Parenting: How will it affect my children?...
  • “Hard to Place,” Not Hard to Love...
  • The Ties That Bind: Keeping Siblings Together in Foster Car...
  • Confronting Abuse in the Frum World ...
  • Understanding the Educational and Behavioral Needs of Childr...
  • When Divorce Can Save a Marriage...
  • Jewish Kids are in Foster Care, Too...
  • A Fulfilling Life ...
  • Richard Bernstein to Become First Blind State Supreme Court ...
  • Ask the Expert: Eligibility Specialist...
  • Meachorei Hapargod: Lessons for Elul, Courtesy of Summer Ca...
  • Early Parental Loss...
  • Are Gedolim Stories Good Chinuch?...
  • Is Recovery From Mental Illness Possible?...
  • Helping Your Child Accept a New Baby...
  • Self-Esteem or Self-Validation?...
  • “Knock, Knock” “Who's There?” OPWDD: Welcoming the F...
  • Developmentally Disabled Employees Shine In The Workplace...
  • “I Take Care” — Mrs. Miriam Lubling, a”h...
  • The Hallmark of Klal Yisrael: A Caring Heart… Foster care ...
  • Redefining strength...
  • Sustaining the Excitement of the First Year of Marriage...
  • No Complaints...
  • No Shidduch Left Behind...
  • Statewide Project Continues Offering Services to Sandy Victi...
  • 75th Anniversary of the Horrors of Kristallnacht...
  • Etta at OHEL Dedicates Fourth Group Home...
  • Staten Island Jewish victims of Hurricane Sandy Still in Nee...
  • A Slice of Home: Through the eyes of a foster child...
  • Ask Sarah: Newly Married & Worried About Divorce...
  • As New Year Approaches, N.Y. Community Devastated by Hurrica...
  • Oniomania: A Look into the Minds of Compulsive Shoppers...
  • Teens and Saturday Nights: A Parenting Approach...
  • The Loss of a Dream...
  • Help! My Adolescent is Out of Control!...
  • Protecting Our Children: Does a Bakery Have a Soul?...
  • Who Am I? Standing at the precipice of death longing for sta...
  • Nobody Quite Knew What to do With Yaakov...
  • Understanding the Coordination between Early Intervention an...
  • Understanding your "peckel", your packet of problems...
  • Life for Frum Women in domestic violence shelters...
  • United We Stand: The Impact of Disabilities on Marriage...
  • Unique Needs of Children in Foster Care...
  • The Success Story that Finally Happened...
  • It’s a painful process to watch. We joke about it all the ...

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