for the 2nd and 4th Reporting Clause Samples

for the 2nd and 4th Reporting. Periods of the CIA, the Board shall retain an individual or entity with expertise in compliance with Federal health care program requirements (Compliance Expert) to perform a review of the effectiveness of Agendia’s Compliance Program (Compliance Program Review). The Compliance Expert shall create a work plan for the Compliance Program Review and prepare a written report about the Compliance Program Review. The written report (Compliance Program Review Report) shall include a description of the Compliance Program Review and any recommendations with respect to Agendia’s compliance program. The Board shall review the Compliance Program Review Report as part of its review and oversight of Agendia’s compliance program. A copy of the Compliance Program Review report shall be provided to OIG in each Annual Report submitted by Agendia. In addition, copies of any materials provided to the Board by the Compliance Expert, along with minutes of any meetings between the Compliance Expert and the Board, shall be made available to OIG upon request.‌‌‌ At minimum, the resolution shall include the following language: “The Board has made a reasonable inquiry into the operations of Agendia’s Compliance Program, including the performance of the Compliance Officer and the Compliance Committee. Based on its inquiry and review, the Board has concluded that, to the best of its knowledge, Agendia has implemented an effective Compliance Program to meet Federal health care program requirements and the obligations of the CIA.” If the Board is unable to provide such a conclusion in the resolution, the Board shall include in the resolution a written explanation of the reasons why it is unable to provide the conclusion and the steps it is taking to implement an effective Compliance Program at Agendia. Agendia shall report to OIG, in writing, any changes in the composition of the Board, or any actions or changes that would affect the Board’s ability to perform the duties necessary to meet the obligations in this CIA, within 15 business days after such a change.