Common use of Arrangements Transactions Review Clause in Contracts

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN during the Reporting Period. The IRO shall assess whether CHN has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHN’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.); b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented; c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHN’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement; d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHN’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); and g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 25 randomly selected Focus Arrangements that were entered into or renewed by CHN Progenity during the Reporting Period. The IRO shall assess whether CHN Progenity has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNProgenity’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.ei.e., items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.); b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented; c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNProgenity’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement; d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNProgenity’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); and g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN Healthquest, Inc. during the Reporting Period. The IRO shall assess whether CHN Healthquest, Inc. has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 III.E.1 and‌‌ III.E.2 of the CIAIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNHealthquest, Inc.’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.ei.e., items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNHealthquest, Inc.’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNHealthquest, Inc.’s policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 III.E.2 of the CIA.IA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-non- compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Healthquest, Inc. and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG OIG‌ notifies CHN Healthquest, Inc. and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN GSMC during the Reporting Period. The IRO shall assess whether CHN GSMC has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements.Arrangements.‌ 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNGSMC’s centralized tracking system in a manner that permits the IRO to identify: : (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNGSMC’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNGSMC’s policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA.CIA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN GSMC and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN GSMC and its IRO that an Additional Transactions Review will be required.required.‌

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN Post Acute Medical during the Reporting Period. The IRO shall assess whether CHN Post Acute Medical has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNPost Acute Medical’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.); b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented; c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNPost Acute Medical’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement; d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNPost Acute Medical’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); and g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Post Acute Medical and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN Post Acute Medical and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 15 (or 20%, whichever is greater) randomly selected Focus Arrangements that were entered into or renewed by CHN Avanti during the Reporting Period. The IRO shall assess whether CHN Avanti has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 m.D.1 and III.D.2 m.D.2 of the CIA, with respect to the selected Focus Arrangements.Arrangements.‌ 1. The IRO’s 's assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHN’s Avanti's centralized tracking system in a manner that permits the IRO to identify: identify:‌‌ (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ ' performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented; documented;‌ Avanti CIA - Appendix B 3‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHN’s Avanti's policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement; d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHN’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); and g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN and its IRO that an Additional Transactions Review will be required.Arrangement;‌

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN during the Reporting Period. The IRO shall assess whether CHN Xxxxxxxxx has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections Sections‌‌ III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNNorthwell’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.ei.e., items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌‌‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) review)‌ and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNXxxxxxxxx’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNNorthwell’s policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and medical equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA.CIA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Northwell and OIG an Additional Transactions Review Report that includes the information specified specified‌ in Section D below, within 60 days of the date the OIG notifies CHN Northwell and its IRO that an Additional Transactions Review will be required.required.‌

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN Healthquest, Inc. during the Reporting Period. The IRO shall assess whether CHN Healthquest, Inc. has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 III.E.1 and‌‌ III.E.2 of the CIAIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNHealthquest, Inc.’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.ei.e., items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNHealthquest, Inc.’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNHealthquest, Inc.’s policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 III.E.2 of the CIA.IA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-non- compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Healthquest, Inc. and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN Healthquest, Inc. and its IRO that an Additional Transactions Review will be required.required.‌

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN Greenway during the Reporting Period. The IRO shall assess whether CHN Greenway has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 III.E.1 and III.D.2 III.E.2 of the CIA, with respect to the selected Focus Arrangements.Arrangements.‌ 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNGreenway’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) review)‌ and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNGreenway’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNGreenway’s policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 III.E.2 of the CIA.CIA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require that the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Greenway and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN Greenway and its IRO that an Additional Transactions Review will be required.required.‌

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN Provider during the Reporting Period. The IRO shall assess whether CHN Provider has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements.Arrangements.‌‌ 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNProvider’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, ; (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.ei.e., items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNProvider’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNProvider’s policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA.CIA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Provider and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN Provider and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN Paksn during the Reporting Period. The IRO shall assess whether CHN Paksn has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNPaksn’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.); b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented; c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNPaksn’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement; d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNPaksn’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); and g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Paksn and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN Paksn and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN Flower Mound during the Reporting Period. The IRO shall assess whether CHN Flower Mound has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements.Arrangements.‌ 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNFlower Mound’s centralized tracking system in a manner that permits the IRO to identify: : (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually actually‌ provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌‌‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNFlower Mound’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNFlower Mound’s policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA.CIA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Review‌ Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Flower Mound and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN Flower Mound and its IRO that an Additional Transactions Review will be required.required.‌‌‌

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 25 randomly selected Focus Arrangements that were entered into or renewed by CHN Radeas during the Reporting Period. The IRO shall assess whether CHN Radeas has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNRadeas’s centralized tracking system in a manner that permits the IRO to identify: : (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.); b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented; c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNRadeas’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement; d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNRadeas’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); and g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Radeas and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN Radeas and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN KRMC, HC, and/or NOSM during the Reporting Period. The IRO shall assess whether CHN KRHS has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements.Arrangements.‌ 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNKRHS’s centralized tracking system in a manner that permits the IRO to identify: identify:‌‌ (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.ei.e., items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) review)‌ and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNKRHS’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNKRHS’s policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);; and‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA.CIA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN KRHS and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN KRHS and its IRO that an Additional Transactions Review will be required.required.‌

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 25 randomly selected Focus Arrangements that were entered into or renewed by CHN Vision Quest during the Reporting Period. The IRO shall assess whether CHN Vision Quest has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNVision Quest’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.); b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented; c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNVision Quest’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement; d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNVision Quest’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); and g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Vision Quest and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN Vision Quest and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO Monitor of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN Respironics during the Reporting Period. The IRO Monitor shall assess whether CHN Respironics has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements.Arrangements.‌ 1. The IROMonitor’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHN’s Respironics’ centralized tracking system in a manner that permits the IRO Monitor to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHN’s Respironics’ policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHN’s Respironics’ policies and procedures;procedures;‌‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA.CIA.‌ 2. For any Focus Arrangement for which the IRO Monitor cannot verify compliance with each of the applicable requirements specified in Section C.1 A.1 above, the IRO Monitor shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO Monitor may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌ 3. If the IRO Monitor cannot verify compliance with each of the applicable requirements specified in Section C.1 A.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO Monitor to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IROMonitor, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Respironics and OIG an Additional Transactions Review Report that includes the information specified in Section D B below, within 60 days of the date the OIG notifies CHN Respironics and its IRO Monitor that an Additional Transactions Review will be required.required.‌

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN APM, Park Center, or Xxxxxx during the Reporting Period. The IRO shall assess whether CHN has APM, Park Center, and Xxxxxx have complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements.Arrangements.‌ 1. The Each IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHN’s APM, Park Center, and Xxxxxx’x centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.ei.e., items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHN’s APM, Park Center, and Xxxxxx’x policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHN’s APM, Park Center, and Xxxxxx’x policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA.CIA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-non- compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO shall be required to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN APM, Park Center, and Xxxxxx and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN APM, Park Center, and Xxxxxx and its IRO that an Additional Transactions Review will be required.required.‌

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 100 randomly selected Focus Arrangements that were entered into or renewed by CHN BioReference during the Reporting Period. The IRO shall assess whether CHN BioReference has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNBioReference’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.); b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented; c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNBioReference’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement; d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNBioReference’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); and g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN BioReference and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN BioReference and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO Monitor of 50 100 randomly selected Focus Arrangements that were entered into or renewed by CHN DaVita Dialysis during the Reporting Period. The IRO Monitor shall assess whether CHN DaVita Dialysis has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 Section III.D of the CIA, CIA with respect to the selected Focus Arrangements. 1. The IROMonitor’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Health Care Provider(s) involved in the Focus Arrangement was selected consistent with DaVita Dialysis’s Selection Process and Selection Criteria (if applicable); b. verifying that the Focus Arrangement is maintained in CHNDaVita Dialysis’s centralized tracking system in a manner that permits the IRO Monitor to identify: (i) identify the parties to the Focus Arrangement, (ii) the name(s) Arrangement and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, /services, /equipment, or /space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) ; c. verifying that the parties’ performance under remuneration related to the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.)was determined using the appropriate Valuation Methodology; b. d. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals approvals, and that such review and approval is appropriately documented;; DaVita HealthCare Partners Inc. Corporate Integrity Agreement – Appendix C c. e. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHN’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked; f. verifying that the services and activities are properly tracked and reviewed by DaVita Dialysis, and that the parties to the Focus Arrangement are complying with performing the financial terms of services required under the Focus Arrangement; d. verifying that the business need or business rationale for the applicable Focus Arrangement is specified and is consistent with CHN’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. g. verifying that the use of leased space, medical supplies, medical devices, and equipment, and other patient care items are is properly monitored by DaVita Dialysis, and that such use is consistent with the terms of the applicable Focus Arrangement (if applicable); and g. h. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 III.D.4 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 100 randomly selected Focus Arrangements that were entered into or renewed by CHN WBH during the Reporting Period. The IRO shall assess whether CHN WBH has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements.Arrangements.‌ 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNWBH’s centralized tracking system in a manner that permits the IRO to identify: identify:‌ (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNWBH’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNWBH’s policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA.CIA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Review‌ Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN WBH and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN WBH and its IRO that an Additional Transactions Review will be required.required.‌

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected all of the Focus Arrangements that were entered into or renewed by CHN OCOM during the Reporting Period. The IRO shall assess whether CHN OCOM has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNOCOM’s centralized tracking system in a manner that permits the IRO to identify: : (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.); b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented; c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNOCOM’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement; d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNOCOM’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); and g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN CII during the Reporting Period. The IRO shall assess whether CHN CII has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNCII’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.); b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented; c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNCII’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement; d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNCII’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); and g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN CII and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN CII and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN CRMC during the Reporting Period. The IRO shall assess whether CHN CRMC has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements.Arrangements.‌ 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNCRMC’s centralized tracking system in a manner that permits the IRO to identify: identify:‌‌ (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.); b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNCRMC’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNCRMC’s policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA.CIA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN CRMC and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN CRMC and its IRO that an Additional Transactions Review will be required.required.‌

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN Rockport during the Reporting Period. The IRO shall assess whether CHN Rockport has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNRockport ’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.); b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented; c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNRockport ’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement; d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNRockport ’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); and g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Rockport and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN Rockport and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN Provider during the Reporting Period. The IRO shall assess whether CHN Provider has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 III.E.1 and III.D.2 III.E.2 of the CIAIA, with respect to the selected Focus Arrangements.Arrangements.‌ 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNProvider’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.ei.e., items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);etc.);‌‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNProvider’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNProvider’s policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 III.E.2 of the CIA.IA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review Review‌ (Additional Transactions Review) and complete and submit to CHN Provider and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN Provider and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 randomly selected Focus Arrangements that were entered into or renewed by CHN SPD during the Reporting Period. The IRO shall assess whether CHN SPD has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements. 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHNSPD’s centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.); b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented; c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHNSPD’s policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement; d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHNSPD’s policies and procedures; e. verifying that the service and activity logs are properly completed and reviewed (if applicable); f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); and g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA. 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance. 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO to select an additional sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN SPD and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN SPD and its IRO that an Additional Transactions Review will be required.

Arrangements Transactions Review. The Arrangements Transactions Review shall consist of a review by the IRO of 50 14 randomly selected Focus Arrangements that were entered into or renewed by CHN Vascular Access Centers during the Reporting Period. The IRO shall assess whether CHN Vascular Access Centers has complied with the Focus Arrangements Procedures and the Focus Arrangements Requirements described in Sections III.D.1 and III.D.2 of the CIA, with respect to the selected Focus Arrangements.Arrangements.‌ 1. The IRO’s assessment with respect to each Focus Arrangement that is subject to review shall include: a. verifying that the Focus Arrangement is maintained in CHN’s Vascular Access Centers’ centralized tracking system in a manner that permits the IRO to identify: (i) the parties to the Focus Arrangement, (ii) the name(s) and position(s) of the Arrangements Covered Person(s) involved in the negotiation, review, and approval of the Focus Arrangement; (iii) the relevant terms of the Focus Arrangement (i.e., the items, services, equipment, or space to be provided, the amount of compensation, the effective date, the expiration date, etc.); and (iv) the parties’ performance under the Focus Arrangement (i.e, items or services actually provided, equipment or space actually provided or leased, amount of payments, dates of payment, etc.);services‌ b. verifying that the Focus Arrangement was subject to the internal review and approval process (including both a legal and business review) and obtained the necessary approvals and that such review and approval is appropriately documented;documented;‌ c. verifying that the remuneration related to the Focus Arrangement has been determined in accordance with CHN’s Vascular Access Centers’ policies and procedures for determining and documenting the fair market value of the remuneration, that the remuneration is properly tracked, and that the parties to the Focus Arrangement are complying with the financial terms of the Focus Arrangement;Arrangement;‌ d. verifying that the business need or business rationale for the Focus Arrangement is specified and is consistent with CHN’s Vascular Access Centers’ policies and procedures;procedures;‌ e. verifying that the service and activity logs are properly completed and reviewed (if applicable);applicable);‌ f. verifying that leased space, medical supplies, medical devices, and equipment, and other patient care items are properly monitored (if applicable); andand‌ g. verifying that the Focus Arrangement satisfies the Focus Arrangements Requirements of Section III.D.2 of the CIA.CIA.‌ 2. For any Focus Arrangement for which the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above, the IRO shall identify and review the system(s) and process(es) that resulted in the identified non-compliance and recommend improvements to such system(s) and process(es). The IRO may need to review additional documentation and/or interview personnel to identify the system(s) and process(es) that resulted in the identified non-compliance.compliance.‌ 3. If the IRO cannot verify compliance with each of the applicable requirements specified in Section C.1 above with respect to at least 90% of the Focus Arrangements subject to the Arrangements Transactions Review, then, at its discretion, within 60 days of receipt of the Arrangements Transactions Review Report, the OIG may require the IRO shall be required to select an additional additional‌ sample of Focus Arrangements, not to exceed the number of Focus Arrangements initially reviewed by the IRO, that will be subject to the Arrangements Transactions Review (Additional Transactions Review) and complete and submit to CHN Vascular Access Centers and OIG an Additional Transactions Review Report that includes the information specified in Section D below, within 60 days of the date the OIG notifies CHN Vascular Access Centers and its IRO that an Additional Transactions Review will be required.required.‌‌