Common use of Disclosure Program Clause in Contracts

Disclosure Program. Forest represents that it has a disclosure program 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 maintain a Disclosure Program that includes a mechanism (a toll-free compliance telephone line 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 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-mails to employees or by posting the information in prominent common areas). The Disclosure Program shall emphasize a 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.

Disclosure Program. Forest represents that it has a disclosure program designed to facilitate communications relating to compliance with Federal health care program and FDA requirements and with Forest’s policies and procedures (Within 90 days after the “Disclosure Program”). During the term of the CIAEffective Date, Forest SPD shall maintain establish a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line and/or on-line electronic reportingline) 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 ForestSPD’s policies, conduct, practices, or procedures with respect to any a Federal health care program or an FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Forest SPD shall continue to 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. The Disclosure Program also shall include a requirement that all of SPD’s Covered Persons shall be expected to report suspected violations of any Federal health care program or FDA requirements to the Compliance Officer or other appropriate individual designated by SPD. 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 SPD 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 loglog and shall record all disclosures (whether or not related to a potential violation of criminal, which civil, or administrative law related to the Federal health care programs or FDA requirements) in the disclosure log within two business days of receipt of the disclosure. The disclosure log shall include a record and summary of each disclosure received (whether anonymous or not), the individual or department responsible for reviewing the disclosure, the status of the respective internal reviewsreview, and any corrective action taken in response to the internal reviews. The disclosure log shall be made available to OIG upon requestreview.

Disclosure Program. Forest represents that it has a disclosure program designed to facilitate communications relating to compliance with Federal health care program and FDA requirements and with Forest’s policies and procedures (‌ Within 90 days after the “Disclosure Program”). During the term of the CIAEffective Date, Forest Flower Mound shall maintain establish a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line and/or on-line electronic reportingline) 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 ForestFlower Mound’s policies, conduct, practices, or procedures with respect to any a Federal health care program or FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Forest Flower Mound shall continue to 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). 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. The Disclosure Program also shall include a requirement that all of Flower Mound’s Covered Persons shall be expected to report suspected violations of any Federal health care program requirements to the Compliance Officer or other appropriate individual designated by Flower Mound. 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 Flower Mound 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 loglog and shall record all disclosures (whether or not related to a potential violation of criminal, which civil, or administrative law related to the Federal health care programs) in the disclosure log within two business days of receipt of the disclosure. The disclosure log shall include a record and summary of each disclosure received (whether anonymous or not), the individual or department responsible for reviewing the disclosure, the status of the respective internal reviewsreview, and any corrective action taken in response to the internal reviews. The disclosure log shall be made available to OIG upon requestreview.

Disclosure Program. Forest represents that it has a disclosure program 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 maintain a Disclosure Program that includes a mechanism (a toll-free compliance telephone line 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 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 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.

Disclosure Program. Forest represents that it has a disclosure program designed to facilitate communications relating to compliance with Federal health care program and FDA requirements and with Forest’s policies and procedures (Within 90 days after the “Disclosure Program”). During the term of the CIAEffective Date, Forest Xxxxxx Valley shall maintain establish a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line and/or on-line electronic reportingline) 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 ForestXxxxxx Valley’s policies, conduct, practices, or procedures with respect to any a Federal health care program or FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Forest Xxxxxx Valley shall continue to 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, policy and shall include a reporting mechanism for anonymous communications for which appropriate confidentiality shall be maintained. The Disclosure Program also shall include a requirement that all of Xxxxxx Valley’s Covered Persons shall be expected to report suspected violations of any Federal health care program requirements to the Compliance Officer or other appropriate individual designated by Xxxxxx Valley. 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 Xxxxxx Valley 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 log and shall record each disclosure in the disclosure log within two business days of receipt of the disclosure. The disclosure log 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. Forest Lilly represents that it has a disclosure program designed to facilitate communications relating to compliance with Federal health care program and FDA requirements and with ForestLilly’s policies and procedures (the “Disclosure Program”). During the term of the CIA, Forest Lilly shall maintain a Disclosure Program that includes a mechanism (a toll-free compliance telephone line and/or and/ or on-line electronic reporting) to enable individuals to disclose, to the Chief Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with ForestLilly’s policies, conduct, practices, or procedures with respect to any a Federal health care program or FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Forest Lilly shall continue to 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 nonretaliation policy, and shall include a reporting mechanism for anonymous communications for which appropriate confidentiality shall be maintained. Disclosures made by individuals residing outside the United States shall be in accordance with applicable laws, including the European Union Data Protection Directive. Upon receipt of a disclosure, the Chief Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The Chief 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 Lilly shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-up is conducted. The Chief 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.. Corporate Integrity Agreement Xxx Xxxxx Company

Disclosure Program. Forest represents that it Allergan currently has a disclosure program that Allergan represents is designed to facilitate communications relating to compliance with Federal health care program and FDA requirements and with ForestAllergan’s policies and procedures (the “Disclosure Program”). During the term of the CIA, Forest Allergan shall maintain a Disclosure Program that includes a mechanism (a toll-free compliance telephone line and/or on-line electronic reporting) to enable individuals to disclose, to the Chief Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with ForestAllergan’s policies, conduct, practices, or procedures with respect to any a Federal health care program or FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Forest Allergan shall continue to 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 nonretaliation policy, and shall include a reporting mechanism for anonymous communications for which appropriate confidentiality shall be maintained. Upon receipt of a disclosure, the Chief Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The Chief 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 Allergan shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-up is conducted. The Chief 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.

Disclosure Program. Forest represents that it GGNSC has a disclosure program 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 shall maintain during the term of the CIA, Forest shall maintain CIA a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line and/or on-line electronic reportingline) to enable individuals to disclose, to the Chief Compliance Officer or some other person who is not in the disclosing individual’s chain of command, any identified issues or questions associated with ForestGGNSC’s policies, conduct, practices, or procedures with respect to any quality of care or a Federal health care program or FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Forest GGNSC shall continue to 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 Chief Compliance Officer (or designee) shall gather all relevant information from the disclosing individual. The Chief 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 GGNSC shall conduct an internal review of the allegations set forth in the disclosure and ensure that proper follow-up is conducted. If the inappropriate or improper practices places residents at risk of harm, then GGNSC will ensure that that practice ceases immediately and that appropriate action is taken. The Chief Compliance Officer (or designee) shall maintain a disclosure log, which shall include a record and summary of each disclosure received with respect to District 63 (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 sent to OIG upon requestthe Monitor not less than monthly.

Disclosure Program. Forest Cephalon represents that it has a disclosure program designed to facilitate communications relating to compliance with Federal health care program and FDA requirements and with ForestCephalon’s policies and procedures (the “Disclosure Program”). During the term of the CIA, Forest Cephalon shall maintain a Disclosure Program that includes a mechanism (a toll-toll- free compliance telephone line and/or on-line electronic reportingline) 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 ForestCephalon’s policies, conduct, practices, or procedures with respect to any a Federal health care program or FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Forest Cephalon shall continue to 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 nonretaliation policy, and shall include a reporting mechanism for anonymous communications for which appropriate confidentiality shall be maintained. Disclosures made by individuals residing outside the United States shall be in accordance with applicable laws, including the European Union Data Protection Directive. 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 Cephalon 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.

Disclosure Program. Forest represents that it has a disclosure program designed to facilitate communications relating to compliance with Federal health care program and FDA requirements and with Forest’s policies and procedures (Within 90 days after the “Disclosure Program”). During the term of the CIAEffective Date, Forest Hope Hospice shall maintain establish a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line and/or on-line electronic reportingline) 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 ForestHope Hospice’s policies, conduct, practices, or procedures with respect to any a Federal health care program or FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Forest Hope Hospice shall continue to 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, policy and shall include a reporting mechanism for anonymous communications for which appropriate confidentiality shall be maintained. The Disclosure Program also shall include a requirement that all of Hope Hospice’s Covered Persons shall be expected to report suspected violations of any Federal health care program requirements to the Compliance Officer or other appropriate individual designated by Hope Hospice. 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 Hope Hospice 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 loglog and shall at a minimum record all disclosures, which whether or not related to a potential violation of criminal, civil, or administrative law related to the Federal health care programs, in the disclosure log within two business days of receipt of the disclosure. The disclosure log shall include a record and summary of each disclosure received (whether anonymous or not), the individual or department responsible for reviewing the disclosure, the status of the respective internal reviewsreview, and any corrective action taken in response to the internal reviews. The disclosure log shall be made available to OIG upon requestreview.

Disclosure Program. Forest represents that it has a disclosure program designed to facilitate communications relating to compliance with Federal health care program and FDA requirements and with Forest’s policies and procedures (Within 90 days after the “Disclosure Program”). During the term of the CIAEffective Date, Forest Diversicare shall maintain establish a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line and/or on-line electronic reportingline) 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 ForestDiversicare’s policies, conduct, practices, or procedures with respect to any a Federal health care program or FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Forest Diversicare shall continue to 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, policy and shall include a reporting mechanism for anonymous communications for which appropriate confidentiality shall be maintained. The Disclosure Program also shall include a requirement that all of Diversicare’s Covered Persons shall be expected to report suspected violations of any Federal health care program requirements to the Compliance Officer or other appropriate individual designated by Diversicare. 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 Diversicare 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 loglog and shall record all disclosures, which whether or not related to a potential violation of criminal, civil, or administrative law related to the Federal health care programs, in the disclosure log within two business days of receipt of the disclosure. The disclosure log shall include a record and summary of each disclosure received (whether anonymous or not), the individual or department responsible for reviewing the disclosure, the status of the respective internal reviewsreview, and any corrective action taken in response to the internal reviews. The disclosure log shall be made available to OIG upon requestreview.

Disclosure Program. Forest represents that it has a disclosure program designed to facilitate communications relating to compliance with Federal health care program and FDA requirements and with Forest’s policies and procedures (Within 90 days after the “Disclosure Program”). During the term of the CIAEffective Date, Forest Radeas shall maintain establish a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line and/or on-line electronic reportingline) 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 ForestRadeas’s policies, conduct, practices, or procedures with respect to any a Federal health care program or FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Forest Radeas shall continue to 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. The Disclosure Program also shall include a requirement that all of Radeas’s Covered Persons shall be expected to report suspected violations of any Federal health care program requirements to the Compliance Officer or other appropriate individual designated by Radeas. 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 Radeas 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 loglog and shall record all disclosures, which whether or not related to a potential violation of criminal, civil, or administrative law related to the Federal health care programs, in the disclosure log within two business days of receipt of the disclosure. The disclosure log shall include a record and summary of each disclosure received (whether anonymous or not), the individual or department responsible for reviewing the disclosure. the status of the respective internal reviewsreview, and any corrective action taken in response to the internal reviews. The disclosure log shall be made available to OIG upon requestreview.

Disclosure Program. Forest represents that it has a disclosure program designed to facilitate communications relating to compliance with Federal health care program and FDA requirements and with Forest’s policies and procedures (Within 90 days after the “Disclosure Program”). During the term of the CIAEffective Date, Forest TPRC shall maintain establish a Disclosure Program that includes a mechanism (e.g., a toll-free compliance telephone line and/or on-line electronic reportingline) 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 ForestTPRC’s policies, conduct, practices, or procedures with respect to any a Federal health care program or FDA requirement believed by the individual to be a potential violation of criminal, civil, or administrative law. Forest TPRC shall continue to 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. The Disclosure Program also shall include a requirement that all of TPRC’s Covered Persons shall be expected to report suspected violations of any Federal health care program requirements to the Compliance Officer or other appropriate individual designated by TPRC. 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 TPRC 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 loglog and shall record all disclosures, which whether or not related to a potential violation of criminal, civil, or administrative law related to the Federal health care programs, in the disclosure log within two business days of receipt of the disclosure. The disclosure log shall include a record and summary of each disclosure received (whether anonymous or not), the individual or department responsible for reviewing the disclosure, the status of the respective internal reviewsreview, and any corrective action taken in response to the internal reviews. The disclosure log shall be made available to OIG upon requestreview.