Common use of Arrangements Systems Review Clause in Contracts

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMC’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMC’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMC’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMC’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMC’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMC’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMC’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMC, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMC’s internal review and approval process, and other Arrangements systems, policies, processes, and procedures; 8. KDMC’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, when appropriate; and 9. KDMC’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMC’s Xxxxxxxx’x systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMC’s Xxxxxxxx’x systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMC’s Xxxxxxxx’x systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMC’s Xxxxxxxx’x systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMC’s Xxxxxxxx’x systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMC’s Xxxxxxxx’x systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMC’s Xxxxxxxx’x systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCXxxxxxxx, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMC’s Xxxxxxxx’x internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures; 8. KDMC’s Xxxxxxxx’x systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; and 9. KDMC’s Xxxxxxxx’x systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCHalifax’s systems, policies, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMCHalifax’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMCHalifax’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMCHalifax’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMCHalifax’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMCHalifax’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMCHalifax’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCHalifax, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee and Board of Commissioners on the Focus Arrangements Tracking System, KDMC; Halifax’s internal review and approval process, ; and other Arrangements systems, policies, processes, and procedures; 8. KDMCHalifax’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, when appropriate; and 9. KDMCHalifax’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCWCH’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following:following:‌ 1. KDMCWCH’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System;System;‌ 2. KDMCWCH’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements;Arrangements;‌ 3. KDMCWCH’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable);applicable);‌ 4. KDMCWCH’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable);applicable);‌ 5. KDMCWCH’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority authority‌ to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement;Arrangement;‌ 6. KDMCWCH’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCWCH, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law;Law;‌ 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMCWCH’s internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures;procedures;‌ 8. KDMCWCH’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; andand‌ 9. KDMCWCH’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.CIA.‌

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCVanguard’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMCVanguard’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMCVanguard’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMCVanguard’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMCVanguard’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMCVanguard’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMCVanguard’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCVanguard, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMCVanguard’s internal review and approval process, and other Arrangements systems, policies, processes, and proceduresProcedures; 8. KDMCVanguard’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; and 9. KDMCVanguard’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCION’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMCION’s systems, policies, processes, and procedures with respect to creating and maintaining the Selection Process and Selection Criteria Procedures required by Section III.D.1 of the CIA; 2. ION’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 23. KDMCION’s systems, policies, processes, and procedures for tracking the names and positions of the Arrangements Covered Person(s) involved in the original negotiations for all Focus Arrangements, the Arrangements Covered Person(s) with oversight over the Focus Arrangement, the lawyer who reviewed and approved the Focus Arrangements, and the names and positions of the Arrangements Covered Person(s) involved with financial aspects of the Focus Arrangement; 4. ION’s systems, policies, processes, and procedures for tracking all remuneration to and from all parties to Focus Arrangements to ensure that the parties are complying with the financial terms of the Focus Arrangement; 5. ION’s systems, policies, processes, and procedures for tracking all investments made by and estimated rates of return received during the term of the CIA by all parties to all Ownership Arrangements; 36. KDMCION’s systems, policies, processes, and procedures for tracking all discounts (e.g., prompt pay discounts, electronic payment discounts), write-offs, debt forgiveness, short-pays, accounts receivable, collection efforts, settlements related to any Focus Arrangement, and aging of balances; 7. ION’s systems, policies, processes, and procedures for tracking the fair market value determination of remuneration specified in the Focus Arrangement, including the fair market value amount or range, the individuals or entities that determined the fair market value amount or range, and the names and positions of the Arrangements Covered Person(s) involved with the fair market value determination; 8. ION’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable); 49. KDMCION’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 510. KDMCION’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 611. KDMCION’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCION, the internal controls designed to ensure that all required approvals are obtained, the process for documenting the business need or business rational for all Focus Arrangements, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law; 712. ION’s systems, policies, processes, and procedures for determining and documenting the fair market value of the remuneration specified in all Focus Arrangements; 13. the Compliance Officer and Arrangements Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMCION’s internal review and approval process, and other Arrangements systems, processes, policies, processes, and procedures; 814. KDMCION’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; and; 915. KDMCION’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA; and 16. ION’s systems, policies, processes, and procedures with respect to creating and maintaining the Fair Market Value Reviews and Oversight Process required by Section III.E of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCSpecialCare’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMCSpecialCare’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMCSpecialCare’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMCSpecialCare’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMCSpecialCare’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMCSpecialCare’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMCSpecialCare’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCSpecialCare, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMCSpecialCare’s internal review and approval process, and other Arrangements systems, processes, policies, processes, and procedures; 8. KDMCSpecialCare’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; and 9. KDMCSpecialCare’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCPHC’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMCPHC’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMCPHC’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMCPHC’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMCPHC’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMCPHC’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMCPHC’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCPHC, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMCPHC’s internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures; 8. KDMCPHC’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; and 9. KDMCPHC’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCPCMC’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following:following:‌ 1. KDMCPCMC’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System;System;‌ 2. KDMCPCMC’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements;Arrangements;‌ 3. KDMCPCMC’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable);applicable);‌ 4. KDMCPCMC’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable);applicable);‌ 5. KDMCPCMC’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority authority‌ to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement;Arrangement;‌‌ 6. KDMCPCMC’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCPCMC, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law;Law;‌ 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMCPCMC’s internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures;procedures;‌ 8. KDMCPCMC’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; andand‌ 9. KDMCPCMC’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.CIA.‌

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMC’s the DIG Entities’ systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMC’s the DIG Entities’ systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMC’s the DIG Entities’ systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMC’s the DIG Entities’ systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMC’s the DIG Entities’ systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMC’s the DIG Entities’ systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMC’s the DIG Entities’ systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCthe DIG Entities, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMC’s the DIG Entities’ internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures; 8. KDMC’s the DIG Entities’ systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Anti- Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; and 9. KDMC’s the DIG Entities’ systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMC’s Xxxxx’x systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following:following:‌ 1. KDMC’s Xxxxx’x systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System;System;‌ 2. KDMC’s Xxxxx’x systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements;Arrangements;‌ 3. KDMC’s Xxxxx’x systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable);applicable);‌ 4. KDMC’s Xxxxx’x systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable);applicable);‌ 5. KDMC’s Xxxxx’x systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement;Arrangement;‌‌ 6. KDMC’s Xxxxx’x systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCXxxxx, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law;Law;‌ 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMC’s Xxxxx’x internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures;procedures;‌ 8. KDMC’s Xxxxx’x systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; andand‌ 9. KDMC’s Xxxxx’x systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.CIA.‌

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMC’s Hebrew Homes’ systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMC’s Hebrew Homes’ systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMC’s Hebrew Homes’ systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMC’s Hebrew Homes’ systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMC’s Hebrew Homes’ systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMC’s Hebrew Homes’ systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMC’s Hebrew Homes’ systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCHebrew Homes, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Anti- Kickback Statute and Xxxxx LawStatute; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMC’s Hebrew Homes’ internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures; 8. KDMC’s Hebrew Homes’ systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; and 9. KDMC’s Hebrew Homes’ systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCExactech’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMCExactech’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMCExactech’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMCExactech’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMCExactech’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMCExactech’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement;; Exactech, Inc. - Appendix B 6. KDMCExactech’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCExactech, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx LawStatute; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMCExactech’s internal review and approval process, and other Arrangements systems, policies, processes, and procedures; 8. KDMCExactech’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; and 9. KDMCExactech’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCPrimex’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMCPrimex’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMCPrimex’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMCPrimex’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMCPrimex’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMCPrimex’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMCPrimex’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCPrimex, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMCPrimex’s internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures; 8. KDMCPrimex’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; and 9. KDMCPrimex’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCIHS’s systems, policies, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMCIHS’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMCIHS’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMCIHS’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMCIHS’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMCIHS’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMCIHS’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCIHS, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee and Board of Commissioners on the Focus Arrangements Tracking System, KDMC; IHS’s internal review and approval process, ; and other Arrangements systems, policies, processes, and procedures; 8. KDMCIHS’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, when appropriate; and 9. KDMCIHS’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMC’s the GIS Parties’ systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following:following:‌ 1. KDMC’s the GIS Parties’ systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System;System;‌ 2. KDMC’s the GIS Parties’ systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements;Arrangements;‌ 3. KDMC’s the GIS Parties’ systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable);applicable);‌ 4. KDMC’s the GIS Parties’ systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable);applicable);‌ 5. KDMC’s the GIS Parties’ systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to to‌ initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement;Arrangement;‌‌ 6. KDMC’s the GIS Parties’ systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCthe GIS Parties, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law;Law;‌ 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMC’s the GIS Parties’ internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures;procedures;‌ 8. KDMC’s the GIS Parties’ systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; andand‌ 9. KDMC’s the GIS Parties’ systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.CIA.‌

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCHome Bound’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMCHome Bound’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMCHome Bound’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMCHome Bound’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMCHome Bound’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMCHome Bound’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMCHome Bound’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCHome Bound, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx LawStatute; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMCHome Bound’s internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures; 8. KDMCHome Bound’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; and 9. KDMCHome Bound’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCCHSI’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following:following:‌ 1. KDMCCHSI’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all current existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System;System;‌ 2. KDMCCHSI’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements;Arrangements;‌ 3. KDMCCHSI’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable);applicable);‌ 4. KDMCCHSI’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable);applicable);‌ 5. KDMCCHSI’s systems, policies, processes, and procedures for initiating Arrangementsarrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement;Arrangement;‌ 6. KDMCCHSI’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCCHSI, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Kickback‌ Statute and Xxxxx Law; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMCCHSI’s internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures;procedures;‌ 8. KDMCCHSI’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; andand‌ 9. KDMCCHSI’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.CIA.‌

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCICH’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following: 1. KDMCICH’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System; 2. KDMCICH’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements; 3. KDMCICH’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable); 4. KDMCICH’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable); 5. KDMCICH’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMCICH’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCICH, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law; 7. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMCICH’s internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures; 8. KDMCICH’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; and 9. KDMCICH’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.

Arrangements Systems Review. The Arrangements Systems Review shall be a review of KDMCFHS’s systems, processes, policies, and procedures relating to the initiation, review, approval, and tracking of Arrangements. Specifically, the Legal IRO shall review the following:following:‌ 1. KDMCFHS’s systems, policies, processes, and procedures with respect to creating and maintaining a centralized tracking system for all existing and new and renewed Focus Arrangements (Focus Arrangements Tracking System), including a detailed description of the information captured in the Focus Arrangements Tracking System;System;‌ 2. KDMCFHS’s systems, policies, processes, and procedures for tracking remuneration to and from all parties to Focus Arrangements;Arrangements;‌ 3. KDMCFHS’s systems, policies, processes, and procedures for tracking service and activity logs to ensure that parties to the Focus Arrangement(s) Arrangement are performing the services required under the applicable Focus Arrangement(s) (if applicable);applicable);‌ 4. KDMCFHS’s systems, policies, processes, and procedures for monitoring the use of leased space, medical supplies, medical devices, equipment, or other patient care items to ensure that such use is consistent with the terms of the applicable Focus Arrangement(s) (if applicable);applicable);‌ 5. KDMC’s systems, policies, processes, and procedures for initiating Arrangements, including those policies that identify the individuals with authority to initiate an Arrangement and that specify the business need or business rationale required to initiate an Arrangement; 6. KDMCFHS’s systems, policies, processes, and procedures for the internal review and approval of all Arrangements, including those policies that identify the individuals required to approve each type or category of Arrangement entered into by KDMCFHS, the internal controls designed to ensure that all required approvals are obtained, and the processes for ensuring that all Focus Arrangements are subject to a legal review by counsel with expertise in the Anti-Kickback Statute and Xxxxx Law;Statute;‌ 76. the Compliance Officer’s annual review of and reporting to the Compliance Committee on the Focus Arrangements Tracking System, KDMCFHS’s internal review and approval process, and other Arrangements systems, process, policies, processes, and procedures;procedures;‌‌‌ 87. KDMCFHS’s systems, policies, processes, and procedures for implementing effective responses when suspected violations of the Anti-Kickback Statute and Xxxxx Law are discovered, including disclosing Reportable Events and quantifying and repaying Overpayments, Overpayments when appropriate; andand‌ 98. KDMCFHS’s systems, policies, processes, and procedures for ensuring that all new and renewed Focus Arrangements comply with the Focus Arrangements Requirements set forth in Section III.F.2 III.D.2 of the CIA.CIA.‌