Common use of Disclosure Program Clause in Contracts

Disclosure Program. ▇▇▇▇▇▇ currently has a disclosure program that ▇▇▇▇▇▇ represents is designed to facilitate communications relating to compliance with Federal health care program requirements and ▇▇▇▇▇▇’▇ policies (the (Disclosure Program”). ▇▇▇▇▇▇ shall continue to maintain a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line) to enable individuals to disclose, to the Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with ▇▇▇▇▇▇’▇ 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. ▇▇▇▇▇▇ shall appropriately publicize 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 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 Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The 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, ▇▇▇▇▇▇ shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-up is conducted. The Compliance Officer (or designee) shall maintain a disclosure 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. ▇▇▇▇▇▇ Medical Technology, Inc. — Corporate Integrity Agreement

Disclosure Program. ▇▇▇▇▇▇ currently has Ensign Group represents that, prior to the Effective Date, it established a disclosure program that ▇▇▇▇▇▇ represents is Disclosure Program designed to facilitate facilitated communications relating to compliance with Federal health care program requirements and ▇▇▇▇▇▇’▇ policies (Ensign Group’s Policies and Procedures. During the (Disclosure Program”). ▇▇▇▇▇▇ term of the CIA, Ensign Group shall continue to maintain a Disclosure Program Program, as required herein, that includes a mechanism (e.g., a toll-free compliance telephone line) to enable individuals to disclose, to the Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with ▇▇▇▇▇▇’▇ Ensign Group’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. ▇▇▇▇▇▇ Ensign Group shall appropriately publicize 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 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 Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The 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, ▇▇▇▇▇▇ Ensign Group shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-up is conducted. The Compliance Officer (or designee) shall maintain a disclosure 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. ▇▇▇▇▇▇ Medical Technology, Inc. — Corporate Integrity Agreement.

Disclosure Program. ▇▇▇▇▇▇ currently has a disclosure program that ▇▇▇▇▇▇ represents is designed Prior to facilitate communications relating to compliance with Federal health care program requirements and ▇▇▇▇▇▇’▇ policies (the (Disclosure Program”). ▇▇▇▇▇▇ shall continue to maintain Effective Date, Baxano Surgical established a Disclosure Program that includes a mechanism (e.g., a toll-toll free compliance Compliance telephone line) to enable individuals to disclose, to the Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with ▇▇▇▇▇▇’▇ Baxano Surgical’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. ▇▇▇▇▇▇ Baxano Surgical shall maintain such a Disclosure Program throughout the term of the CIA. Baxano Surgical shall appropriately publicize the existence of the disclosure mechanism Disclosure Program and the Compliance telephone line (e.g., via periodic e-mails to employees or and/or by posting the information in prominent common areas). The Disclosure Program shall 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 Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The 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 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, ▇▇▇▇▇▇ Baxano Surgical shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-up is conducted. The Compliance Officer (or designee) shall maintain maintain, a disclosure log, which shall include includes 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 This disclosure log shall be made available to OIG upon request. ▇▇▇▇▇▇ Medical Technology, Inc. — Corporate Integrity Agreement.

Disclosure Program. ▇▇▇▇▇▇ Exactech currently has a disclosure program that ▇▇▇▇▇▇ Exactech represents is designed to facilitate communications relating to compliance with Federal health care program requirements and ▇▇▇▇▇▇’▇ Exactech’s policies (the (Disclosure Program”). ▇▇▇▇▇▇ Exactech shall continue to maintain a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line) to enable individuals to disclose, to the Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with ▇▇▇▇▇▇’▇ Exactech’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. ▇▇▇▇▇▇ Exactech shall appropriately publicize 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 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 Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The 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 and (2) provides an opportunity for taking corrective action, ▇▇▇▇▇▇ Exactech shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-follow- up is conducted. The Compliance Officer (or designee) shall maintain a disclosure 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. ▇▇▇▇▇▇ Medical Technology, Inc. — Corporate Integrity Agreement.

Disclosure Program. ▇▇▇▇▇▇ currently Forest represents that it has a disclosure program that ▇▇▇▇▇▇ represents is designed to facilitate communications relating to compliance with Federal health care program and FDA requirements and ▇▇▇▇▇▇’▇ with Forest’s policies and procedures (the (“Disclosure Program”). ▇▇▇▇▇▇ During the term of the CIA, Forest shall continue to maintain a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone lineline and/or on-line electronic reporting) to enable individuals to disclose, to the Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with ▇▇▇▇▇▇’▇ Forest’s policies, conduct, practices, or procedures with respect to a any Federal health care program or FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. ▇▇▇▇▇▇ Forest shall continue to appropriately publicize the existence of the disclosure mechanism (e.g., via periodic e-e- mails to employees or by posting the information in prominent common areas). Corporate Integrity Agreement Forest Laboratories, Inc. The Disclosure Program shall 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 Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The 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, ▇▇▇▇▇▇ Forest shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-up is conducted. The Compliance Officer (or designee) shall maintain a disclosure 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. ▇▇▇▇▇▇ Medical Technology, Inc. — Corporate Integrity Agreement.

Disclosure Program. ▇▇▇▇▇▇ currently has Ensign Group represents that, prior to the Effective Date, it established a disclosure program that ▇▇▇▇▇▇ represents is Disclosure Program designed to facilitate facilitated communications relating to compliance with Federal health care program requirements and ▇▇▇▇▇▇’▇ policies (Ensign Group’s Policies and Procedures. During the (Disclosure Program”). ▇▇▇▇▇▇ term of the CIA, Ensign Group shall continue to maintain a Disclosure Program Program, as required herein, that includes a mechanism (e.g., a toll-free compliance telephone line) to enable individuals to disclose, to the Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with ▇▇▇▇▇▇’▇ Ensign Group’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. ▇▇▇▇▇▇ Ensign Group shall appropriately publicize 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 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 Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The 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 and (2) provides an opportunity for taking corrective action, ▇▇▇▇▇▇ Ensign Group shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-follow- up is conducted. The Compliance Officer (or designee) shall maintain a disclosure 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. ▇▇▇▇▇▇ Medical Technology, Inc. — Corporate Integrity Agreement.