Common use of Review of Payments Clause in Contracts

Review of Payments. For purposes of this Appendix B, the term “Control Documents” shall include all material documents or electronic records associated with each Life Spine Payment reflected in the Open Payments database for that calendar year. For example, the term “Control Documents” includes, but is not limited to, documents relating to the nature, purpose, and amount of the Payment; contracts relating to the Payment; documents relating to the occurrence of Payment; documents reflecting any work product generated in connection with the Payment; documents submitted by sales representatives or headquarters personnel to request approval for the Payment; and business rationale or justification forms relating to the Payment. a. For each Reporting Period, the OIG shall have the discretion to identify up to 15 Covered Recipients who received Payments from Life Spine during the prior calendar year and will be subject to the IRO review described below. If the OIG elects to exercise this discretion, it shall notify the IRO of the Covered Recipients subject to the IRO Review. If the OIG elects not to exercise its discretion, the IRO shall randomly select 15 Covered Recipients to be included in the review. b. For each selected Covered Recipient, the IRO shall review the Control Documents associated with the Payments to the Covered Recipient for all categories reflected in the Open Payments Data website except for the Food/Beverage and Travel/Lodging categories of Payments. Specifically, for each Covered Recipient selected as part of the sample, the IRO shall review the Control Documents identified by the IRO as necessary and sufficient to validate each Payment reported to CMS to evaluate the following: (i) whether Control Documents are available relating to each Payment; (ii) whether the Control Documents were completed and archived in accordance with the requirements set forth in Life Spine's policies; (iii) whether the aggregate value of the Payment as reflected in the Open Payments Database is consistent with the value of the Payment reflected in the Control Documents; and (iv) whether the Control Documents reflect that Life Spine's policies were followed in connection with the Payment(e.g., all required written approvals for the activity were obtained in accordance with Life Spine’s policies.)

Review of Payments. For purposes of this Appendix B, the term “Control Documents” shall include all material documents or electronic records associated with each Life Spine RMS Payment reflected in the Open Payments database for that calendar year. For example, the term “Control Documents” includes, but is not limited to, documents relating to the nature, purpose, and amount of the Payment; contracts relating to the Payment; documents relating to the occurrence of Payment; documents reflecting any work product generated in connection with the Payment; documents submitted by sales representatives or headquarters personnel to request approval for the Payment; and business rationale or justification forms relating to the Payment. a. For each Reporting Period, the OIG shall have the discretion to identify up to 15 30 Covered Recipients who received Payments from Life Spine RMS during the prior calendar year and will be subject to the IRO review described below. If the OIG elects to exercise this discretion, it shall notify the IRO of the Covered Recipients subject to the IRO Review. Review.‌ If the OIG elects not to exercise its discretion, the IRO shall randomly select 15 30 Covered Recipients to be included in the review. b. For each selected Covered Recipient, the IRO shall review the Control Documents associated with the Payments to the Covered Recipient for all categories reflected in the Open Payments Data website except for the Food/Beverage and Travel/Lodging categories of Payments. Specifically, for each Covered Recipient selected as part of the sample, the IRO shall review the Control Documents identified by the IRO as necessary and sufficient to validate each Payment reported to CMS to evaluate the following:following:‌ (i) i. whether Control Documents are available relating to each Payment; (ii) . whether the Control Documents were completed and archived in accordance with the requirements set forth in Life SpineRMS's policies; (iii) . whether the aggregate value of the Payment as reflected in the Open Payments Database is consistent with the value of the Payment reflected in the Control Documents; and (iv) . whether the Control Documents reflect that Life SpineRMS's policies were followed in connection with the Payment(e.g.Payment e.g., all required written approvals for the activity were obtained in accordance with Life Spine’s RMS's policies.)

Review of Payments. For purposes of this Appendix B, the term “Control Documents” shall include all material documents or electronic records associated with each Life Spine Biotronik Payment reflected in the Open Payments database for that calendar yeardatabase. For example, the term “Control Documents” includes, but is not limited to, documents relating to the nature, purpose, and amount of the Payment; contracts relating to the Payment; documents relating to the occurrence of Payment; documents reflecting any work product generated in connection with the Payment; documents submitted by sales representatives or headquarters personnel to request approval for the Payment; and business rationale or justification forms relating to the Payment. a. For each Reporting Period, the OIG shall have the discretion to identify up to 15 50 Covered Recipients who received Payments from Life Spine during Biotronik, as reflected in the prior calendar year and will be subject to most recent data available in the IRO review described belowOpen Payments database. If the OIG elects to exercise this discretion, it shall notify the IRO of the Covered Recipients subject to the IRO Review. If the OIG elects not to exercise its discretion, the IRO shall randomly select 15 50 Covered Recipients to be included in the review.review.‌ b. For each selected Covered Recipient, the IRO shall review the Control Documents associated with the Payments to the Covered Recipient for all categories reflected in the Open Payments Data website except for the Food/Beverage and Travel/Lodging categories of Payments. Specifically, Specifically,‌ for each Covered Recipient selected as part of the sample, the IRO shall review the Control Documents identified by the IRO as necessary and sufficient to validate each Payment reported to CMS to evaluate the following: (i) i. whether Control Documents are available relating to each Payment; (ii) . whether the Control Documents were completed and archived in accordance with the requirements set forth in Life Spine's Biotronik’s policies; (iii) . whether the aggregate value of the Payment as reflected in the Open Payments Database database is consistent with the value of the Payment reflected in the Control Documents; and (iv) . whether the Control Documents reflect that Life Spine's Biotronik’s policies were followed in connection with the Payment(e.g.Payment (e.g., all required written approvals for the activity were obtained in accordance with Life Spine’s Biotronik's policies.)

Review of Payments. For purposes of this Appendix B, the term “Control Documents” shall include all material documents or electronic records associated with each Life Spine Arthrex Payment reflected in the Open Payments database for that calendar year. For example, the term “Control Documents” includes, but is not limited to, documents relating to the nature, purpose, and amount of the Payment; contracts relating to the Payment; documents relating to the occurrence of Payment; documents reflecting any work product generated in connection with the Payment; documents submitted by sales representatives or headquarters personnel to request approval for the Payment; and business rationale or justification forms relating to the Payment. a. For each Reporting Period, the OIG shall have the discretion to identify up to 15 50 Covered Recipients who received Payments from Life Spine Arthrex during the prior calendar year and will be subject to the IRO review described below. If the OIG elects to exercise this discretion, it shall notify the IRO of the Covered Recipients subject to the IRO Review. If the OIG elects not to exercise its discretion, the IRO shall randomly select 15 50 Covered Recipients to be included in the review.review.‌ b. For each selected Covered Recipient, the IRO shall review the Control Documents associated with the Payments to the Covered Recipient for all categories reflected in the Open Payments Data website except for the Food/Beverage and Travel/Lodging categories of Payments. Specifically, for each Covered Recipient selected as part of the sample, the IRO shall review the Control Documents identified by the IRO as necessary and sufficient to validate each Payment reported to CMS to evaluate the following:following:‌ (i) i. whether Control Documents are available relating to each Payment; (ii) . whether the Control Documents were completed and archived in accordance with the requirements set forth in Life Spine's Arthrex’s policies; (iii) . whether the aggregate value of the Payment as reflected in the Open Payments Database is consistent with the value of the Payment reflected in the Control Documents; and (iv) . whether the Control Documents reflect that Life Spine's Arthrex’s policies were followed in connection with the Payment(e.g.Payment (e.g., all required written approvals for the activity were obtained in accordance with Life SpineArthrex’s policies.)policies.)‌

Review of Payments. For purposes of this Appendix B, the term “Control Documents” shall include all material documents or electronic records associated with each Life Spine RMS Payment reflected in the Open Payments database for that calendar year. For example, the term “Control Documents” includes, but is not limited to, documents relating to the nature, purpose, and amount of the Payment; contracts relating to the Payment; documents relating to the occurrence of Payment; documents reflecting any work product generated in connection with the Payment; documents submitted by sales representatives or headquarters personnel to request approval for the Payment; and business rationale or justification forms relating to the Payment. a. For each Reporting Period, the OIG shall have the discretion to identify up to 15 30 Covered Recipients who received Payments from Life Spine RMS during the prior calendar year and will be subject to the IRO review described below. If the OIG elects to exercise this discretion, it shall notify the IRO of the Covered Recipients subject to the IRO Review. If the OIG elects not to exercise its discretion, the IRO shall randomly select 15 30 Covered Recipients to be included in the review. b. For each selected Covered Recipient, the IRO shall review the Control Documents associated with the Payments to the Covered Recipient for all categories reflected in the Open Payments Data website except for the Food/Beverage and Travel/Lodging categories of Payments. Specifically, for each Covered Recipient selected as part of the sample, the IRO shall review the Control Documents identified by the IRO as necessary and sufficient to validate each Payment reported to CMS to evaluate the following: (i) i. whether Control Documents are available relating to each Payment; (ii) . whether the Control Documents were completed and archived in accordance with the requirements set forth in Life SpineRMS's policies; (iii) . whether the aggregate value of the Payment as reflected in the Open Payments Database is consistent with the value of the Payment reflected in the Control Documents; and (iv) . whether the Control Documents reflect that Life SpineRMS's policies were followed in connection with the Payment(e.g.Payment e.g., all required written approvals for the activity were obtained in accordance with Life Spine’s RMS's policies.)

Review of Payments. For purposes of this Appendix B, the term “Control Documents” shall include all material documents or electronic records associated with each Life Spine Merit Payment reflected in the Open Payments database for that calendar year. For example, the term “Control Documents” includes, but is not limited to, documents relating to the nature, purpose, and amount of the Payment; contracts relating to the Payment; documents relating to the occurrence of Payment; documents reflecting any work product generated in connection with the Payment; documents submitted by sales representatives or headquarters personnel to request approval for the Payment; and business rationale or justification forms relating to the Payment. a. For each Reporting Period, the OIG shall have the discretion to identify up to 15 Covered Recipients who received Payments from Life Spine Merit during the prior calendar year and will be subject to the IRO review described below. If the OIG elects to exercise this discretion, it shall notify the IRO of the Covered Recipients subject to the IRO Review. If the OIG elects not to exercise its discretion, the IRO shall randomly select 15 Covered Recipients to be included in the review. b. For each selected Covered Recipient, the IRO shall review the Control Documents associated with the Payments to the Covered Recipient for all categories reflected in the Open Payments Data website except for the Food/Beverage and Travel/Lodging categories of Payments. Specifically, for each Covered Recipient selected as part of the sample, the IRO shall review the Control Documents identified by the IRO as necessary and sufficient to validate each Payment reported to CMS to evaluate the following: (i) i. whether Control Documents are available relating to each Payment; (ii) . whether the Control Documents were completed and archived in accordance with the requirements set forth in Life SpineMerit's policies; (iii) . whether the aggregate value of the Payment as reflected in the Open Payments Database is consistent with the value of the Payment reflected in the Control Documents; and (iv) . whether the Control Documents reflect that Life SpineMerit's policies were followed in connection with the Payment(e.g.Payment (e.g., all required written approvals for the activity were obtained in accordance with Life Spine’s Merit's policies.)