Internal Audit and Review Functions. To the extent not already accomplished, Vencor shall, within ninety (90) days of the Effective Date of this CIA, establish a program for performing internal audits and reviews. The internal audits and reviews shall:
a. make findings of whether the cost reports, claims, and submissions to Federal health care programs that affect reimbursement are accurate and in accordance with applicable law;
b. make findings of whether the systems are in place and functioning effectively to ensure that patients and residents at Vencor facilities are receiving the quality of care and quality of life consistent with basic care, treatment and protection from harm standards, as required by applicable law, including 42 C.F.R. Parts 482 and 483 and any other Federal and state statutes, regulations, guidelines, and directives;
c. conduct an annual Minimum Data Set ("MDS") billing review of claims submitted by Vencor's long term care facilities; and
d. perform such other internal audits and reviews as necessary to ensure that this CIA is being appropriately implemented and to ensure that Vencor is meeting its obligations under applicable law.
Internal Audit and Review Functions. Within 120 days of the Effective Date of this CIA, Sun shall review the adequacy of its system of internal financial controls, accounting policies, financial reporting practices and its other internal audit and review functions, as they relate to the Federal health care programs, and shall continue to perform, or if necessary establish a program for performing, internal audits and reviews that shall:
a. make findings of whether the cost reports, claims and submissions to Federal health care programs that affect reimbursement are accurate and in accordance with applicable law;
b. make findings of whether the systems are in place and functioning effectively to ensure that patients and residents at Sun facilities are receiving the quality of care and quality of life consistent with basic care, treatment and protection from harm standards, as required by applicable law, including 42 C.F.R. Parts 482 and 483 and any other applicable law;
c. conduct an annual Minimum Data Set ("MDS") billing review of claims submitted by Sun's nursing facilities; and
d. perform such other internal audits and reviews as necessary to ensure that this CIA is being appropriately implemented and to ensure that Sun is meeting its obligations under applicable law.
Internal Audit and Review Functions. Mariner has a program for performing internal audits and reviews. The internal audits and reviews:
a. make findings of whether the cost reports, claims, and submissions to Federal health care programs that affect reimbursement are accurate and in accordance with applicable law;
b. make findings of whether the patients and residents at Mariner facilities are receiving the quality of care and quality of life consistent with basic care, treatment and protection from harm standards; including, but not limited to, 42 C.F.R. Parts 482 and 483 and any other Federal and state statutes, regulations, guidelines, and directives;
c. conduct an annual Minimum Data Set ("MDS") billing review of claims submitted by Mariner's long term care facilities; and
d. perform such other internal audits and reviews as necessary to ensure that this CIA is being appropriately implemented and to ensure that Mariner is meeting its obligations under applicable law.
