Common use of Disclosure Program Clause in Contracts

Disclosure Program. Dignity Health has established a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line) to enable individuals to disclose to the Corporate Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with Dignity Health’s policies, conduct, practices, or procedures with respect to a Federal health care program believed by the individual to be a potential violation of criminal, civil, or administrative law. Dignity Health shall continue to maintain this Disclosure Program for the duration of the CIA. Dignity Health shall continue to publicize appropriately the existence of the disclosure mechanism (e.g., via periodic e-mails to employees or by posting the information in prominent common areas). The Disclosure Program shall continue to emphasize a nonretribution, nonretaliation policy, and shall include a reporting mechanism for anonymous communications for which appropriate confidentiality shall be maintained. Upon receipt of a disclosure, the Corporate Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The Corporate Compliance Officer (or designee) shall make a preliminary, good faith inquiry into the allegations set forth in every disclosure to ensure that he or she has obtained all of the information necessary to determine whether a further review should be conducted. For any disclosure that is sufficiently specific so that it reasonably: (1) permits a determination of the appropriateness of the alleged improper practice; and (2) provides an opportunity for taking corrective action, Dignity Health shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-up is conducted. The Corporate Compliance Officer (or designee) shall maintain a disclosure log and shall record each disclosure in the disclosure log within 48 hours of receipt of the Corporate Integrity Agreement Dignity Health disclosure. The disclosure log shall include a summary of each disclosure received (whether anonymous or not), the status of the respective internal reviews, and any corrective action taken in response to the internal reviews.

Disclosure Program. Dignity Health has Prior to the BIPI Effective Date, BIPI established a Disclosure Program that includes a mechanism (e.g., a toll-the toll free compliance telephone lineEthics and Compliance Helpline) to enable individuals to disclose disclose, to the Corporate Compliance Officer CECO or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with Dignity HealthBIPI’s policies, conduct, practices, or procedures with respect to a Federal health care program or an FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Dignity Health BIPI shall continue to maintain this such a Disclosure Program for throughout the duration term of the CIA. Dignity Health BIPI publicizes, and shall continue to publicize appropriately publicize, the existence of the disclosure mechanism Disclosure Program and the Ethics and Compliance Helpline (e.g., via periodic e-mails to employees or employees, by posting the information in prominent common areas). , or through references in the Code of Conduct and during training.) The Disclosure Program shall continue to emphasize a nonretribution, nonretaliation policy, non-retaliation policy and shall include a reporting mechanism for anonymous communications for which appropriate confidentiality shall be maintained. Upon receipt of a disclosure, the Corporate Compliance Officer CECO (or designee) shall gather all relevant information from the disclosing individual. The Corporate Compliance Officer CECO (or designee) shall make a preliminary, good faith inquiry into the allegations set forth in every disclosure to ensure that he or she has obtained obtains all of the necessary information necessary to determine whether a further review should be conducted. For any disclosure that is sufficiently specific so that it reasonably: (1) permits a determination of the appropriateness of the alleged improper practice; and (2) provides an opportunity for taking corrective action, Dignity Health BIPI shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-up is conducted. The Corporate Compliance Officer (or designee) BIPI shall maintain maintain, a disclosure log log, which includes a record and shall record each disclosure in the disclosure log within 48 hours of receipt of the Corporate Integrity Agreement Dignity Health disclosure. The disclosure log shall include a summary of each disclosure received (whether anonymous or not), the status of the respective internal reviews, and any corrective action taken in response to the internal reviews. This disclosure log shall be made available to OIG upon request.

Disclosure Program. Dignity Health has Prior to the Effective Date, CVS Caremark established a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line) to enable individuals to disclose disclose, to the Corporate Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with Dignity HealthCVS Caremark’s policies, conduct, practices, or procedures with respect to a Federal health care program believed by the individual to be a potential violation of criminal, civil, or administrative law. Dignity Health CVS Caremark shall continue to maintain this Disclosure Program for the duration of the CIA. Dignity Health shall continue to appropriately publicize appropriately the existence of the disclosure mechanism (e.g., via periodic e-mails to employees employees, through a posting on CVS Caremark’s intranet or other internal website available to all Covered Persons, or by posting the information in prominent common areas). The Disclosure Program shall continue to emphasize a nonretribution, nonretaliation policy, and shall continue to include a reporting mechanism for anonymous communications for which appropriate confidentiality shall be maintained. Upon receipt of a disclosure, the Corporate Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The Corporate Compliance Officer (or designee) shall make a preliminary, good faith inquiry into the allegations set forth in every disclosure to ensure that he or she has obtained all of the information necessary to determine whether a further review should be conducted. For any disclosure that is sufficiently specific so that it reasonably: (1) permits a determination of the appropriateness of the alleged improper practice; and (2) provides an opportunity for taking corrective action, Dignity Health CVS Caremark shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-up is conducted. The Corporate Compliance Officer (or designee) shall maintain a disclosure log and shall record each disclosure in the disclosure log within 48 hours of receipt of the Corporate Integrity Agreement Dignity Health disclosure. The disclosure log log, which shall include a record and summary of each disclosure received (whether anonymous or not), the status of the respective internal reviews, and any corrective action taken in response to the internal reviews.

Disclosure Program. Dignity Health has Prior to the Effective Date of this CIA, CVS established a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line) to enable individuals to disclose disclose, to the Corporate Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with Dignity HealthCVS’s policies, conduct, practices, or procedures with respect to a Federal health care program believed by the individual to be a potential violation of criminal, civil, or administrative law. Dignity Health CVS shall continue to maintain this Disclosure Program for the duration of the CIA. Dignity Health shall continue to appropriately publicize appropriately the existence of the disclosure mechanism (e.g., via periodic e-mails to employees employees, posting on CVS’s intranet or other internal website available to all Covered Persons, or by posting the information in prominent common areas). The Disclosure Program shall continue to emphasize a nonretribution, nonretaliation policy, and shall continue to include a reporting mechanism for anonymous communications for which appropriate confidentiality shall be maintained. Upon receipt of a disclosure, the Corporate Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The Corporate Compliance Officer (or designee) shall make a preliminary, good faith inquiry into the allegations set forth in every disclosure to ensure that he or she has obtained all of the information necessary to determine whether a further review should be conducted. For any disclosure that is sufficiently specific so that it reasonably: (1) permits a determination of the appropriateness of the alleged improper practice; and (2) provides an opportunity for taking corrective action, Dignity Health CVS shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-up is conducted. The Corporate Compliance Officer (or designee) shall maintain a disclosure log and shall record each disclosure in the disclosure log within 48 hours of receipt of the Corporate Integrity Agreement Dignity Health disclosure. The disclosure log log, which shall include a record and summary of each disclosure received (whether anonymous or not), the status of the respective internal reviews, and any corrective action taken in response to the internal reviews. The disclosure log shall be made available to OIG upon request.

Disclosure Program. Dignity Health has Prior to the Effective Date, InterMune established a disclosure program designed to facilitate communications relating to compliance with Federal health care program and FDA requirements and with InterMune’s policies (Disclosure Program). During the term of this CIA, InterMune shall continue to maintain a Disclosure Program that includes a mechanism (e.g., a the toll-free compliance telephone lineCode of Conduct Ethics Helpline) to to’ enable individuals to disclose disclose, to the Corporate Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with Dignity HealthInterMune’s policies, conduct, practices, or procedures with respect to a Federal health care program or FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Dignity Health InterMune shall continue to maintain this Disclosure Program for the duration of the CIA. Dignity Health shall continue to appropriately publicize appropriately the existence of the disclosure mechanism (e.g., via periodic e-mails to employees or by posting the information in prominent common areas). The Disclosure Program shall continue to emphasize a nonretribution, nonretaliation policy, and shall continue to include a reporting mechanism for anonymous communications for which appropriate confidentiality shall be maintained. Upon receipt of a disclosure, the Corporate Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The Corporate Compliance Officer (or designee) shall make a preliminary, good faith inquiry into the allegations set forth in every disclosure to ensure that he or she has obtained all of the information necessary to determine whether a further review should be conducted. For any disclosure that is sufficiently specific so that it reasonably: (1) permits a determination of the appropriateness of the alleged improper practice; and (2) provides an opportunity for taking corrective action, Dignity Health InterMune shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-up is conducted. The Corporate Compliance Officer (or designee) shall continue to maintain a disclosure log and shall record each disclosure in the disclosure log within 48 hours of receipt of the Corporate Integrity Agreement Dignity Health disclosure. The disclosure log log, which shall include a record and summary of each disclosure received (whether anonymous or not), the status of the respective internal reviews, and any corrective action taken in response to the internal reviews. The disclosure log shall be made available to OIG upon request.