Risk Assessment and Internal Review Process. Within 90 days after the Effective Date, Post Acute Medical shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with Arrangements (as defined in Section II.C.1 above) and Post Acute Medical’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. Post Acute Medical shall maintain the risk assessment and internal review process for the term of the CIA.
Risk Assessment and Internal Review Process. Within 90 days after the Effective Date, Healogics shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with Healogics’ 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. Healogics shall maintain the risk assessment and internal review process for the term of the CIA.
Risk Assessment and Internal Review Process. Within 90 days after the Effective Date, Good Shepherd shall develop and implement a centralized annual risk assessment and internal review process to identify and address 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 should include: (1) a process for identifying and prioritizing risks, (2) developing remediation plans in response to those risks, including internal auditing and monitoring of the identified risk areas, and (3) tracking results to assess the effectiveness of the remediation plans. The risk assessment and internal review process should require compliance, legal, and department leaders, at least annually, to evaluate and identify risks associated with the submission of claims for items and services furnished to Medicare and Medicaid program beneficiaries and develop and implement specific plans to address and mitigate the identified risks. The risk assessment and internal review work plans shall be developed annually. Good Shepherd shall implement the risk assessment and internal review work plans and track the implementation of the work plans. Good Shepherd shall maintain the risk assessment and internal review process for the term of the CIA. Copies of any internal audit reports developed pursuant to the risk assessment and internal review process shall be made available to OIG upon request.
Risk Assessment and Internal Review Process. Within 90 days after the Effective Date, OCOM shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with Arrangements (as defined in Section II.C.1 above) and OCOM’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 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 be conducted at least annually and shall require OCOM 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. OCOM shall maintain the risk assessment and internal review process for the term of the CIA.
Risk Assessment and Internal Review Process. Within 120 days after the Effective Date, CHN shall develop and implement a centralized annual risk assessment and internal review process to identify and address the Anti-Kickback Statute and Xxxxx Law risks associated with Arrangements and CHN’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 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 be conducted at least annually and shall require CHN to: (1) identify and prioritize risks; (2) develop work plans or audit plans (as appropriate) related to the identified risk areas; (3) implement the work plans and audit plans; (4) develop corrective action plans in response to the results of any internal audits performed; and (5) track the implementation of the work plans and any corrective action plans and assess the effectiveness of such plans.
Risk Assessment and Internal Review Process. To the extent not already accomplished, within 90 days after the Effective Date, Mylan shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with its Government Reimbursed Products. The risk assessment and internal review process shall require compliance, legal and department or business unit 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. Mylan shall maintain the risk assessment and internal review process for the duration of the CIA.
Risk Assessment and Internal Review Process. Within 90 days after the Effective Date, Progenity shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with Arrangements (as defined in Section II.C.1 above) and Progenity’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 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 be conducted at least annually and shall require Progenity 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. Progenity shall maintain the risk assessment and internal review process for the term of the CIA.
Risk Assessment and Internal Review Process. Within 90 days after the Effective Date, the Friendship Entities shall develop and implement a centralized annual risk assessment and internal review process to identify and address 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 should 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,
Risk Assessment and Internal Review Process. Within 90 days after the Effective Date, Orbit shall develop and implement a centralized annual risk assessment and internal review process to identify and address associated with the submission of claims for items and services furnished to Medicare and Medicaid program beneficiaries and develop and implement specific plans to address and mitigate the identified risks. The risk assessment and internal review work plans shall be developed annually. Orbit shall implement the risk assessment and internal review work plans and track the implementation of the work plans. Orbit shall maintain the risk assessment and internal review process for the term of the CIA. Copies of any internal audit reports developed pursuant to the risk assessment and internal review process shall be made available to OIG upon request.
Risk Assessment and Internal Review Process. Within 90 days after the Effective Date, Kindred shall develop and implement a centralized annual risk assessment and internal review process to identify and address risks associated with the provision of rehabilitation therapy information, items or services furnished to Medicare and Medicaid program beneficiaries for which claims may be submitted. The risk assessment and internal review process should 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. Kindred shall maintain the risk assessment and internal review process for the term of the CIA.
