Common use of Independence and Objectivity Certification Clause in Contracts

Independence and Objectivity Certification. The IRO shall include in its report(s) to Liberty a certification that the IRO has (a) evaluated its professional independence and objectivity with respect to the reviews required under this Section III.D and (b) concluded that it is, in fact, independent and objective, in accordance with the requirements specified in Appendix A to this CIA. The IRO’s certification shall include a summary of all current and prior engagements between Liberty and the IRO.‌ E. Risk Assessment and Internal Review Process‌ Within 120 days after the Effective Date, Liberty shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with Liberty’s participation in the Federal health care programs, including but not limited to the risks associated with the submission of claims for items and services furnished to Medicare and Medicaid program beneficiaries. The risk assessment and internal review process shall require compliance, legal, and department leaders, at least annually, to: (1) identify and prioritize risks, (2) develop internal audit work plans related to the identified risk areas, (3) implement the internal audit work plans, (4) develop corrective action plans in response to the results of any internal audits performed, and (5) track the implementation of the corrective action plans in order to assess the effectiveness of such plans. Liberty shall maintain the risk assessment and internal review process for the term of the CIA.

Independence and Objectivity Certification. The IRO shall include in its report(s) to Liberty Millcreek a certification that the IRO has (a) evaluated its professional independence and objectivity with respect to the reviews required under this Section III.D and (b) concluded that it is, in fact, independent and objective, in accordance with the requirements specified in Appendix A to this CIA. The IRO’s certification shall include a summary of all current and prior engagements between Liberty Millcreek and the IRO.‌ E. Risk X. Xxxx Assessment and Internal Review Process‌ Within 120 90 days after the Effective Date, Liberty Millcreek shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with LibertyXxxxxxxxx’s participation in the Federal health care programs, including but not limited to the risks associated with the submission of claims for items and services furnished to Medicare and Medicaid program beneficiaries. The risk assessment and internal review process shall require compliance, legal, and department leaders, at least annually, to: (1) identify and prioritize risks, (2) develop internal audit work plans related to the identified risk areas, (3) implement the internal audit work plans, (4) develop corrective action plans in response to the results of any internal audits performed, and (5) track the implementation of the corrective action plans in order to assess the effectiveness of such plans. Liberty Xxxxxxxxx shall maintain the risk assessment and internal review process for the term of the CIA.

Independence and Objectivity Certification. The IRO shall include in its report(s) to Liberty Sutter a certification that the IRO has (a) evaluated its professional independence and objectivity with respect to the reviews required under this Section III.D and (b) concluded that it is, in fact, independent and objective, in accordance with the requirements specified in Appendix A to this CIA. The IRO’s certification shall include a summary of all current and prior engagements between Liberty Sutter and the IRO.‌ E. Risk X. Xxxx Assessment and Internal Review Process‌ Within 120 90 days after the Effective Date, Liberty Sutter shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with Liberty’s Xxxxxx’x participation in the Federal health care programs, including but not limited to the risks associated with the submission of claims for items and services furnished to Medicare and Medicaid program beneficiaries, the Anti-Kickback Statute and Xxxxx Law risks associated with Arrangements (as defined in Section II.C.1 above), and the risks associated with obtaining risk adjustment data and submitting risk adjustment data to Medicare Advantage organizations or their contractors. The Compliance Committee shall be responsible for implementation and oversight of the risk assessment and internal review process. The risk assessment and internal review process shall require compliance, legal, and department leaders, be conducted at least annually, annually and shall require Sutter to: (1) identify and prioritize risks, (2) develop internal audit work plans related to the identified risk areas, (3) Xxxxxx Health Corporate Integrity Agreement implement the internal audit work plans, (4) develop corrective action plans in response to the results of any internal audits performed, and (5) track the implementation of the corrective action plans in order to assess the effectiveness of such plans. Liberty Sutter shall maintain the risk assessment and internal review process for the term of the CIA.

Independence and Objectivity Certification. The IRO shall include in its report(s) to Liberty LCCA a certification that the IRO has (a) evaluated its professional independence and objectivity with respect to the reviews required under this Section III.D and (b) concluded that it is, in fact, independent and objective, in accordance with the requirements specified in Appendix A to this CIA. The IRO’s certification shall include a summary of all current and prior engagements between Liberty LCCA and the IRO.‌ E. Risk X. Xxxx Assessment and Internal Review Process‌ Within 120 90 days after the Effective Date, Liberty LCCA shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with LibertyLCCA’s participation in the Federal health care programs, including but not limited to the risks associated with the submission of claims for items and services furnished to Medicare and Medicaid program beneficiaries. The risk assessment and internal review process shall require compliance, legal, and department leaders, at least annually, to: (1) identify and prioritize risks, (2) develop internal audit work plans related to the identified risk areas, (3) implement the internal audit work plans, (4) develop corrective action plans in response to the results of any internal audits performed, and (5) track the implementation of the any corrective action plans in order to assess the effectiveness of such plans. Liberty LCCA shall maintain the risk assessment and internal review process for the term of the CIA.

Independence and Objectivity Certification. The IRO shall include in its report(s) to Liberty Signature a certification that the IRO has (a) evaluated its professional independence and objectivity with respect to the reviews required under this Section III.D and (b) concluded that it is, in fact, independent and objective, in accordance with the requirements specified in Appendix A to this CIA. The IRO’s certification shall include a summary of all current and prior engagements between Liberty Signature and the IRO.‌ E. Risk Assessment and Internal Review Process‌ Within 120 days after the Effective Date, Liberty Signature shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with LibertySignature’s participation in the Federal health care programs, including but not limited to the risks associated with the submission of claims for items and services furnished to Medicare and Medicaid program beneficiaries. The risk assessment and internal review process shall require compliance, legal, and department leaders, at least annually, to: (1) identify and prioritize risks, (2) develop internal audit work plans related to the identified risk areas, (3) implement the internal audit work plans, (4) develop corrective action plans in response to the results of any internal audits performed, and (5) track the implementation of the corrective action plans in order to assess the effectiveness of such plans. Liberty Signature shall maintain the risk assessment and internal review process for the term of the CIA.CIA.‌

Independence and Objectivity Certification. The IRO shall include in its report(s) to Liberty Signature a certification that the IRO has (a) evaluated its professional independence and objectivity with respect to the reviews required under this Section III.D and (b) concluded that it is, in fact, independent and objective, in accordance with the requirements specified in Appendix A to this CIA. The IRO’s certification shall include a summary of all current and prior engagements between Liberty Signature and the IRO.‌ E. Risk X. Xxxx Assessment and Internal Review Process‌ Within 120 days after the Effective Date, Liberty Signature shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with LibertySignature’s participation in the Federal health care programs, including but not limited to the risks associated with the submission of claims for items and services furnished to Medicare and Medicaid program beneficiaries. The risk assessment and internal review process shall require compliance, legal, and department leaders, at least annually, to: (1) identify and prioritize risks, (2) develop internal audit work plans related to the identified risk areas, (3) implement the internal audit work plans, (4) develop corrective action plans in response to the results of any internal audits performed, and (5) track the implementation of the corrective action plans in order to assess the effectiveness of such plans. Liberty Signature shall maintain the risk assessment and internal review process for the term of the CIA.CIA.‌

Independence and Objectivity Certification. The IRO shall include in its report(s) to Liberty a certification that the IRO has (a) evaluated its professional independence and objectivity with respect to the reviews required under this Section III.D and (b) concluded that it is, in fact, independent and objective, in accordance with the requirements specified in Appendix A to this CIA. The IRO’s certification shall include a summary of all current and prior engagements between Liberty and the IRO.‌ E. Risk X. Xxxx Assessment and Internal Review Process‌ Within 120 days after the Effective Date, Liberty shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with Liberty’s participation in the Federal health care programs, including but not limited to the risks associated with the submission of claims for items and services furnished to Medicare and Medicaid program beneficiaries. The risk assessment and internal review process shall require compliance, legal, and department leaders, at least annually, to: (1) identify and prioritize risks, (2) develop internal audit work plans related to the identified risk areas, (3) implement the internal audit work plans, (4) develop corrective action plans in response to the results of any internal audits performed, and (5) track the implementation of the corrective action plans in order to assess the effectiveness of such plans. Liberty shall maintain the risk assessment and internal review process for the term of the CIA.

Independence and Objectivity Certification. The IRO shall include in its report(s) to Liberty the Rush Organization a certification that the IRO has (a) evaluated its professional independence and objectivity with respect to the reviews required under this Section III.D and (b) concluded that it is, in fact, independent and objective, in accordance with the requirements specified in Appendix A to this CIA. The IRO’s certification shall include a summary of all current and prior engagements between Liberty the Rush Organization and the IRO.‌ E. Risk X. Xxxx Assessment and Internal Review Process‌ Within 120 90 days after the Effective Date, Liberty the Rush Organization shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with Liberty’s the Rush Organization participation in the Federal health care programs, including but not limited to the risks associated with the submission of claims for items and services furnished to Medicare and Medicaid program beneficiaries. The risk assessment and internal review process shall require compliance, legal, and department leaders, at least annually, to: (1) identify and prioritize risks, (2) develop internal audit work plans related to the identified risk areas, (3) implement the internal audit work plans, (4) develop corrective action plans in response to the results of any internal audits performed, and (5) track the implementation of the corrective action plans in order to assess the effectiveness of such plans. Liberty The Rush Organization shall maintain the risk assessment and internal review process for the term of the CIA.

Independence and Objectivity Certification. The IRO shall include in its report(s) to Liberty EAP a certification that the IRO has (a) evaluated its professional independence and objectivity with respect to the reviews required under this Section III.D and (b) concluded that it is, in fact, independent and objective, in accordance with the requirements specified in Appendix A to this CIA. The IRO’s certification shall include a summary of all current and prior engagements between Liberty EAP and the IRO.‌ E. Risk Assessment and Internal Review Process‌ Within 120 days after the Effective Date, Liberty EAP shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with LibertyEAP’s participation in the Federal health care programs, including but not limited to the risks associated with the submission of claims for items and services furnished to Medicare Medicaid and Medicaid TRICARE program beneficiaries. The risk assessment and internal review process shall require compliance, legal, and department leaders, at least annually, to: (1) identify and prioritize risks, (2) develop internal audit work plans related to the identified risk areas, (3) implement the internal audit work plans, (4) develop corrective action plans in response to the results of any internal audits performed, and (5) track the implementation of the corrective action plans in order to assess the effectiveness of such plans. Liberty EAP shall maintain the risk assessment and internal review process for the term of the CIA.CIA.‌‌

Independence and Objectivity Certification. The IRO shall include in its report(s) to Liberty Millcreek a certification that the IRO has (a) evaluated its professional independence and objectivity with respect to the reviews required under this Section III.D and (b) concluded that it is, in fact, independent and objective, in accordance with the requirements specified in Appendix A to this CIA. The IRO’s certification shall include a summary of all current and prior engagements between Liberty Millcreek and the IRO.‌ E. Risk Assessment and Internal Review Process‌ Within 120 90 days after the Effective Date, Liberty Millcreek shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with LibertyXxxxxxxxx’s participation in the Federal health care programs, including but not limited to the risks associated with the submission of claims for items and services furnished to Medicare and Medicaid program beneficiaries. The risk assessment and internal review process shall require compliance, legal, and department leaders, at least annually, to: (1) identify and prioritize risks, (2) develop internal audit work plans related to the identified risk areas, (3) implement the internal audit work plans, (4) develop corrective action plans in response to the results of any internal audits performed, and (5) track the implementation of the corrective action plans in order to assess the effectiveness of such plans. Liberty Xxxxxxxxx shall maintain the risk assessment and internal review process for the term of the CIA.