AND ANNUAL REPORTS.
A. Implementation Report Within 120 days after the Effective Date, Post Acute Medical shall submit a written report to OIG summarizing the status of its implementation of the requirements of this CIA (Implementation Report). The Implementation Report shall, at a minimum, include:
1. the name, address, phone number, and position description of the Compliance Officer required by Section III.A, and a summary of other noncompliance job responsibilities the Compliance Officer may have;
2. the names and positions of the members of the Compliance Committee required by Section III.A;
3. the names of the managing members who are responsible for satisfying the Manager’s compliance obligations described in Section III.A.3;
4. the names and positions of the Certifying Employees required by Section III.A.4 and a copy of the written process for Certifying Employees to follow for the purpose of completing the required Certification;
5. a list of all Policies and Procedures required by Section III.B;
6. the Training Plan required by Section III.C.1 and a description of the Manger’s training required by Section III.C.2 (including a summary of the topics covered, the length of the training, and when the training was provided);
7. a description of (a) the Focus Arrangements Tracking System required by Section III.D.1.a, (b) the internal review and approval process required by Section III.D.1.e; and (c) the tracking and monitoring procedures and other Focus Arrangements Procedures required by Section III.D.1;
8. the following information regarding the IRO(s): (a) identity, address, and phone number; (b) a copy of the engagement letter; (c) information to demonstrate that the IRO has the qualifications outlined in Appendix A to this CIA; and
AND ANNUAL REPORTS.
A. Implementation Report Within 120 days after the Effective Date, Sutter shall submit a written report to OIG summarizing the status of its implementation of the requirements of this CIA (Implementation Report). The Implementation Report shall, at a minimum, include:
1. the name, business address, business phone number, and position description of the Compliance Officer required by Section III.A, and a summary of other noncompliance job responsibilities the Compliance Officer may have;
2. the names and positions of the members of the Compliance Committee required by Section III.A;
3. the names of the Board Committee members who are responsible for satisfying the Board compliance obligations described in Section III.A.3;
4. the names and positions of the Certifying Employees required by Section III.A.4 and a copy of the written process for Certifying Employees to follow in order to complete the certification required by Section III.A.4;
5. a list of the Policies and Procedures required by Section III.B; 6. the Training Plan required by Section III.C.1 and a description of the Board training required by Section III.C.2 (including a summary of the topics covered, the length of the training, and when the training was provided);
7. the following information regarding the IRO(s): (a) identity, address, and phone number; (b) a copy of the engagement letter; (c) information to demonstrate that the IRO has the qualifications outlined in Appendix A to this CIA; and (d) a certification from the IRO regarding its professional independence and objectivity with respect to Sutter that includes a summary of all current and prior engagements between Sutter and the IRO;
8. a description of the risk assessment and internal review process required by Section III.E;
9. a description of the Disclosure Program required by Section III.F; 10. a description of the Ineligible Persons screening and removal process required by Section III.G;
AND ANNUAL REPORTS.
A. Implementation Report Within 180 days after the Effective Date, South Miami Hospital shall submit a written report to OIG summarizing the status of its implementation of the requirements of this CIA (Implementation Report). The Implementation Report shall, at a minimum, include:
1. the name, address, phone number, and position description of the Hospital Compliance Officer required by Section III.A, and a summary of other noncompliance job responsibilities the Hospital Compliance Officer may have;
2. the names and positions of the members of the Hospital Compliance Committee required by Section III.A;
3. the names of the Board members who are responsible for satisfying the Board of Directors compliance obligations described in Section III.A.3;
4. the names and positions of the Certifying Employees required by Section III.A.4;
5. the written process for Certifying Employees to follow for the purpose of completing the certification described in Section III.A.4;
6. a list of the Policies and Procedures required by Section III.B; 7. the Training Plan required by Section III.C.1 and a description of the Board of Directors training required by Section III.C.2 (including a summary of the topics covered, the length of the training, and when the training was provided);
AND ANNUAL REPORTS.
A. Implementation Report Within 90 days after the Effective Date, Foot Healers shall submit a written report to OIG summarizing the status of its implementation of the requirements of this IA (Implementation Report). The Implementation Report shall, at a minimum, include:
1. the name, address, phone number, and position description of the Compliance Officer required by Section III.A, and a summary of other noncompliance job responsibilities the Compliance Officer may have;
2. a list of the Policies and Procedures required by Section III.B.;
3. a copy of the notice required by Section III.C, a description of where the notice is posted, and the date the notice was posted;
4. the following information regarding the IRO: (a) identity, address, and phone number; (b) a copy of the engagement letter; (c) information to demonstrate that the IRO has the qualifications outlined in Appendix A to this IA; and (d) a certification from the IRO regarding its professional independence and objectivity with respect to Foot Healers;
5. a copy of the documentation demonstrating that Foot Healers has screened all Covered Persons against the Exclusion List as required by Section III.F within 30 days of the Effective Date;
6. a copy of Foot Healers’ policies and procedures regarding the identification, quantification and repayment of Overpayments required by Section III.H;
7. a copy of any certifications from Foot Healers and the third party billing company required by Section III.J (if applicable);
8. a list of all of Foot Healers’ locations (including locations and mailing addresses), the corresponding name under which each location is doing business, and each location’s Medicare and state Medicaid program provider number(s), and/or supplier number(s); and
AND ANNUAL REPORTS.
A. Implementation Report Within 120 days after the Effective Date, APM, Park Center, and Xxxxxx shall submit a written report to OIG summarizing the status of their implementation of the requirements of this CIA (Implementation Report). The Implementation Report shall, at a minimum, include:
1. the name, address, phone number, and position description of the Compliance Officer required by Section III.A, and a summary of other noncompliance job responsibilities the Compliance Officer may have;
2. the names and positions of the members of the Compliance Committee required by Section III.A;
3. the names and positions of the Certifying Employees required by Section III.A.3;
4. a list of all Policies and Procedures required by Section III.B; 5. the Training Plan required by Section III.C.1 (including a summary of the topics covered, the length of the training, and when the training was provided);
AND ANNUAL REPORTS.
A. Implementation Report Within 90 days after the Effective Date, PANF shall submit a written report to OIG summarizing the status of its implementation of the requirements of this IA (Implementation Report). The Implementation Report shall, at a minimum, include:
1. the name, address, phone number, and position description of the Compliance Officer and Compliance Manager required by Section III.A, and a summary of any noncompliance job responsibilities the Compliance Manager may have;
2. the names of the Board members who are responsible for satisfying the compliance obligations described in Section III.B;
3. a list of the Policies and Procedures required by Section III.C.;
4. a copy of the notice required by Section III.D, a description of where the notice is posted, and the date the notice was posted;
5. a description of the PAP Measures required by Section III.F;
6. the following information regarding the IRO: (a) identity, address, and phone number of the IRO; (b) a copy of the engagement letter between PAN and the IRO; (c) identity, address, and phone number of the Legal Reviewer; (d) information to demonstrate that the IRO and the Legal Reviewer have the qualifications outlined in Appendix A to this IA; and (e) a certification from the IRO regarding its professional independence and objectivity with respect to PANF (including any Legal Reviewer) as specified in Section E of Appendix A that includes a summary of all current and prior engagements between PANF and the IRO and between PANF and the Legal Reviewer.
7. a copy of the documentation demonstrating that PANF has screened all Covered Persons against the Exclusion List as required by Section III.H within 30 days of the Effective Date;
8. a list of all of PANF’s locations (including locations and mailing addresses), the corresponding name under which each location is doing business, and each location’s Medicare and state Medicaid program provider number(s) and/or supplier number(s) (if applicable); and
9. a certification by the Compliance Officer and the Chief Executive Officer that: (a) he or she has reviewed the IA in its entirety, understands the requirements described within, and maintains a copy for reference; (b) to the best of his or her knowledge, except as otherwise described in the Implementation Report, PANF is in compliance with all of the requirements of this IA; (c) he or she has reviewed the Implementation Report and has made a reasonable inquiry regarding its content and b...
AND ANNUAL REPORTS.
A. Implementation Report Within 150 days after the Effective Date, Banner shall submit a written report to OIG summarizing the status of its implementation of the requirements of this CIA (Implementation Report). The Implementation Report shall, at a minimum, include:
1. the name, address, phone number, and position description of the Compliance Officer required by Section III.A.1, and a summary of other noncompliance job responsibilities the Compliance Officer may have;
2. the names, addresses, phone numbers, and position description of each Area Compliance Program Director required by Section III.A.2, and a summary of other noncompliance job responsibilities each Area Compliance Program Director may have;
3. the names and positions of the members of the System Compliance Committee required by Section III.A.3;
4. the names of the Board members who are responsible for satisfying the Audit Committee compliance obligations described in Section III.A.4; 5. the names and positions of the Certifying Employees required by Section III.A.5;
AND ANNUAL REPORTS.
A. Implementation Report Within 120 days after the Effective Date, Prime shall submit a written report to OIG summarizing the status of its implementation of the requirements of this CIA (Implementation Report). The Implementation Report shall, at a minimum, include:
1. the name, business address, business phone number, and position description of the Corporate Compliance Officer required by Section III.A.1, and a summary of other noncompliance job responsibilities the Compliance Officer may have;
2. the name, address, phone number, and position description of the Deputy Compliance Officers required by Section III.A.2, and a summary of other noncompliance job responsibilities the Deputy Compliance Officers may have;
3. the names and positions of the members of the Compliance Committee required by Section III.A.3;
4. the names of the Board members who are responsible for satisfying the Board compliance obligations described in Section III.A.4;
5. the names and positions of the Certifying Employees required by Section III.A.5 and a copy of the written process for Certifying Employees to follow in order to complete the certification required by Section III.A.5;
6. a list of all Policies and Procedures required by Section III.B; 7. the Training Plan required by Section III.C.1 and a description of the Board training required by Section III.C.2 (including a summary of the topics covered, the length of the training, and when the training was provided);
AND ANNUAL REPORTS. 24 A. Implementation Report................................................................................25
AND ANNUAL REPORTS. A. IMPLEMENTATION REPORT Within one hundred and fifty (150) days after the date of execution of this CIA, Medaphis shall submit a written report to the OIG summarizing the status of implementation of the requirements of this CIA. This implementation report shall include:
(1) the name, address, phone number and position description of the Compliance Officer and compliance committee required in III(A);
(2) a certification by the Compliance Officer that the written Policies and Procedures required by III(B) have been developed, are being implemented, and that each affected employee, as specified in this agreement, has signed the certification attesting he or she has received, read, understood and will abide by the applicable policies and procedures;
(3) a description of the training programs implemented pursuant to III(C), a summary of the activities undertaken in furtherance of the training programs, including schedules and format of the training sessions, and a certification by the Compliance Officer that the training required within the first one hundred and twenty (120) days has been completed;
(4) a description of the confidential disclosure program pursuant to III(E) and a description of the other lines of communication between the compliance officer and employees;
(5) the identity of the independent review organization and the proposed start and completion date of the first engagements; and
(6) a summary of personnel actions taken pursuant to section III(F).
