Common use of Specific Training Clause in Contracts

Specific Training. Within 120 days of the effective date of this CCA, each Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program shall receive at least four (4) hours of training (the "Specific Training") in addition to the General Training required above. CHS shall ensure that, pursuant to the Corporate Compliance Program, and as appropriate to the Covered Person's individual responsibilities, the Specific Training includes a discussion of: a. the submission of accurate bills for services rendered to Federal health care program patients; b. policies, procedures and other requirements applicable to the documentation of medical records; c. the personal obligation of each individual involved in the billing process to ensure that such ▇▇▇▇▇▇▇▇ are accurate; d. applicable reimbursement statutes, regulations, and program requirements and directives; e. the legal sanctions for improper ▇▇▇▇▇▇▇▇; and f. examples of proper and improper billing practices. Persons providing the Specific Training must be knowledgeable about the subject area. Affected new Covered Persons shall receive the Specific Training within 30 days of becoming a Covered Person or within 120 days of the effective date of this CCA, whichever is later. If a new Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program has any responsibility for the delivery of patient care, the preparation or submission of claims, and/or the assignment of procedure codes prior to completing this Specific Training, a Covered Person who has completed the Specific Training shall review all of the untrained person's work regarding the delivery of patient care, the preparation or submission of claims, and the assignment of procedure codes. Covered Persons who have received the above-required Specific Training, or its equivalent, within 12 months prior to the effective date of this CCA are exempted from the above four (4) hour Specific Training requirement for the first year of this CCA only. CHS shall maintain records sufficient to support a listing of those Covered Persons for whom CHS is claiming such an exemption as well as the date(s) and topics of the training received by those Covered Persons. Every Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program shall receive at least four (4) hours of such Specific Training on an annual basis. All training materials used for the Specific Training shall be made available to OIG upon request.

Specific Training. Within 120 90 days of after the effective date of this CCAEffective Date, each Relevant Promotional and Product Services Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program shall receive at least four (4) hours of training (the "Specific Training") Promotional and Product Services Training in addition to the General Training required above. CHS shall ensure that, pursuant to the Corporate Compliance Program, and as appropriate to the Covered Person's individual responsibilities, the This Specific Training includes shall include a discussion of:: CORPORATE INTEGRITY AGREEMENT ATRICURE, INC. a. the submission of accurate bills for services rendered to all applicable Federal health care program patientsand FDA requirements relating to Promotional and Product Services Related Functions; b. policiesall AtriCure, procedures Inc. Policies and Procedures and other requirements applicable to the documentation of medical recordsPromotional and Product Services Related Functions; c. the personal obligation of each individual involved in the billing process Promotional and Product Services Related Functions to ensure that such ▇▇▇▇▇▇▇▇ are accuratecomply with all applicable Federal health care program and FDA requirements and all other applicable legal requirements, as well as AtriCure, Inc.’s Policies and Procedures; d. applicable reimbursement statutes, regulations, and program requirements and directives; e. the legal sanctions for improper ▇▇▇▇▇▇▇▇; andviolations of the applicable Federal health care program and FDA requirements, the False Claims Act, and the Anti-kickback statute; f. e. examples of proper and improper billing practicespractices related to Promotional and Product Services Related Functions; f. the dissemination of information regarding Federal health care program requirements concerning the accurate coding and submission of claims; and g. the legal sanctions to both AtriCure, Inc. and Relevant Covered Promotional and Product Services Persons of failure to comply with Federal health care program and FDA requirements and with AtriCure Inc.’s own Policies and Procedures and the failure to report such non-compliance. Persons providing the Specific Training must be knowledgeable about the subject area. Affected new New Relevant Promotional and Product Services Covered Persons shall receive this training within 90 days after the Specific Training within 30 days beginning of their employment or becoming a Relevant Promotional and Product Services Covered Person Person, or within 120 90 days of after the effective date of this CCAEffective Date, whichever is later. If a new Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (includingAn AtriCure, but not limited to, coding and billing) from any Federal health care program has any responsibility for the delivery of patient care, the preparation or submission of claims, and/or the assignment of procedure codes prior to completing this Specific Training, a Covered Person Inc. employee who has completed the Specific Training shall review all of or supervise (as applicable) a new Relevant Promotional and Product Services Covered Person’s work, to the untrained person's extent that the work regarding relates to CORPORATE INTEGRITY AGREEMENT ATRICURE, INC. Promotional and Product Services Related Functions, until such time as the delivery of patient care, the preparation new Relevant Promotional and Product Services Covered Person completes his or submission of claims, and the assignment of procedure codes. Covered Persons who have received the above-required her Specific Training, or its equivalent, within 12 months prior to . After receiving the effective date of this CCA are exempted from the above four (4) hour initial Specific Training requirement for the first year of described in this CCA only. CHS shall maintain records sufficient to support a listing of those Covered Persons for whom CHS is claiming such an exemption as well as the date(s) Section, each Relevant Promotional and topics of the training received by those Covered Persons. Every Product Services Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program shall receive at least four (4) three hours of such Specific Training on an annual basis. All training materials used for the Specific Training shall be made available to OIG upon requestin each subsequent Reporting Period.

Specific Training. Within 120 days of after the effective date of this CCAEffective Date, each Relevant Covered Person who is a physician or is involved engaged in the preparation or submission of claims for reimbursement (including, but not limited to, coding Promotional and billing) from any Federal health care program Product Related Functions shall receive at least four (4) three hours of training (the "Specific Training") Training applicable to their specific job functions in addition to the General Training required above. CHS shall ensure that, pursuant to the Corporate Compliance Program, and as appropriate to the Covered Person's individual responsibilities, the This Specific Training includes shall include a discussion of: a. the submission of accurate bills for services rendered to all applicable Federal health care program patientsrequirements relating to Promotional and Product Related Functions, including but not limited to the requirements of the Federal anti-kickback statute, the Civil Monetary Penalties Law, and the Civil False Claims Act; b. policiesall applicable FDA requirements relating to Promotional and Product Related Functions; Corporate Integrity Agreement Forest Laboratories, procedures Inc. c. all Forest Policies and Procedures and other requirements applicable to the documentation of medical recordsPromotional and Product Related Functions; c. d. the personal obligation of each individual involved in the billing process Promotional and Product Related Functions to ensure that such ▇▇▇▇▇▇▇▇ are accurate; d. comply with all applicable reimbursement statutes, regulations, Federal health care program and program FDA requirements and directivesall other applicable legal requirements; e. the legal sanctions for improper ▇▇▇▇▇▇▇▇violations of the applicable Federal health care program and FDA requirements; and f. examples of proper and improper billing practicespractices related to Promotional and Product Related Functions. Persons providing Within 120 days after the Effective Date, each Relevant Covered Person engaged in Regulatory Related Functions shall receive at least three hours of Specific Training must be knowledgeable about applicable to their specific job functions in addition to the subject areaGeneral Training required above. Affected new This Specific Training shall include a discussion of: a. all applicable Federal health care program requirements relating to Regulatory Related Functions; b. all applicable FDA requirements relating to Regulatory Related Functions; c. all Forest Policies and Procedures and other requirements applicable to Regulatory Related Functions; d. the personal obligation of each individual involved in Regulatory Related Functions to comply with all applicable Federal health care program and FDA requirements and all other applicable legal requirements; e. the legal sanctions for violations of the applicable Federal health care program and FDA requirements; and Corporate Integrity Agreement Forest Laboratories, Inc. f. examples of proper and improper practices related to Regulatory Related Functions. To the extent that Forest provided Specific Training to Relevant Covered Persons during the 180 days immediately prior to the Effective Date that satisfied the requirements set forth in this Section III.C.2 above, the OIG shall credit that training for purposes of satisfying Forest’s Specific Training obligations of this Section III.C.2 for the first Reporting Period. New Relevant Covered Persons shall receive the applicable Specific Training training within 30 days after the beginning of their employment or becoming a Relevant Covered Person Persons, or within 120 days of after the effective date of this CCAEffective Date, whichever is later. If a new Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program has any responsibility for the delivery of patient care, the preparation or submission of claims, and/or the assignment of procedure codes prior to completing this Specific Training, a Covered Person A Forest employee who has completed the Specific Training shall review all of or supervise (as applicable) a new Relevant Covered Person’s work, to the untrained person's extent that the work regarding relates to Promotional and Product Related Functions or Regulatory Related Functions (as applicable), until such time as the delivery of patient care, the preparation new Relevant Covered Person completes his or submission of claims, and the assignment of procedure codes. Covered Persons who have received the above-required her Specific Training, or its equivalent, within 12 months prior to . After receiving the effective date of this CCA are exempted from the above four (4) hour initial Specific Training requirement for the first year of described in this CCA only. CHS shall maintain records sufficient to support a listing of those Covered Persons for whom CHS is claiming such an exemption as well as the date(s) and topics of the training received by those Covered Persons. Every Section, each Relevant Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program shall receive at least four (4) three hours of such the applicable Specific Training on an annual basis. All training materials used for the Specific Training shall be made available to OIG upon requestin each subsequent Reporting Period.

Specific Training. Within 120 90 days of after the effective date of this CCAEffective Date, each Relevant Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program shall receive at least four (4) hours of training (the "Specific Training") Training in addition to the General Training required above. CHS . a. Relevant Hospice Benefit Covered Persons shall ensure that, pursuant to the Corporate Compliance Program, and as appropriate to the Covered Person's individual responsibilities, the receive three hours of Specific Training includes a discussion ofthat covers the following topics: a. i. the submission of accurate bills for services rendered to Federal health care program patientsrequirements regarding the hospice benefit, including eligibility, certification, and recertification, with specific focus on the requirements for continuous care services; b. ii. policies, procedures procedures, and other requirements applicable to the documentation of medical records; c. iii. the personal obligation of each individual involved in the billing claims submission process to ensure that such ▇▇▇▇▇▇▇▇ claims are accurate; d. iv. applicable reimbursement statutes, regulations, and program requirements and directives; e. v. the legal sanctions for improper ▇▇▇▇▇▇▇▇violations of the Federal health care program requirements; and f. vi. examples of proper and improper billing claims submission practices. Persons providing After receiving the initial Specific Training must be knowledgeable about described in this section, each Relevant Hospice Benefit Covered Person shall receive at least two hours of Specific Training, in addition to the subject areaGeneral Training, in each subsequent Reporting Period. Affected new Odyssey Corporate Integrity Agreement b. Relevant Hospice Marketing Covered Persons shall receive the two hours of Specific Training within 30 days of becoming a Covered Person or within 120 days of that covers the effective date of this CCA, whichever is later. If a new Covered Person who is a physician or is involved in following topics: i. the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program has any responsibility requirements regarding the hospice benefit, including eligibility, certification, and recertification, with specific focus on the requirements for continuous care services; ii. applicable reimbursement statutes, regulations, and program requirements and directives; iii. the delivery requirements of patient careAnti-Kickback Statute; iv. examples of violations of the Anti-Kickback Statute; and v. the legal sanctions for violations of the Federal health care program requirements. After receiving the initial Specific Training described in this section, the preparation or submission each Relevant Hospice Marketing Covered Person shall receive at least one hour of claims, and/or the assignment of procedure codes prior to completing this Specific Training, a Covered Person who has completed in addition to the Specific Training shall review all of the untrained person's work regarding the delivery of patient careGeneral Training, the preparation or submission of claims, and the assignment of procedure codes. in each subsequent Reporting Period. c. Relevant Covered Persons who have received the above-required pertinent Specific TrainingTraining no earlier than 60 days before the Effective Date shall be deemed to have satisfied this requirement. New Relevant Covered Persons shall receive Specific Training within 30 days after the beginning of their employment or becoming Relevant Covered Persons, or its equivalentwithin 90 days after the Effective Date, within 12 months prior to the effective date of this CCA are exempted from the above four (4) hour Specific Training requirement for the first year of this CCA only. CHS shall maintain records sufficient to support a listing of those Covered Persons for whom CHS whichever is claiming such an exemption as well as the date(s) and topics of the training received by those Covered Persons. Every Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program shall receive at least four (4) hours of such Specific Training on an annual basis. All training materials used for the Specific Training shall be made available to OIG upon requestlater.

Specific Training. Within 120 90 days of after the effective date of this CCAEffective Date, each WellCare shall require that Relevant Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program shall Persons receive at least four (4) three hours of training (the "Specific Training") Training in addition to the General Training required above. CHS shall ensure that, pursuant to the Corporate Compliance Program, and as appropriate to the Covered Person's individual responsibilities, the This Specific Training includes shall include a discussion of: a. all applicable Federal health care program requirements related to Reimbursement Related Functions; b. all WellCare policies, procedures, and other requirements related to Reimbursement Related Functions; c. the personal obligation of each individual in Reimbursement Related Functions to comply with all applicable Federal health care program requirements and all other applicable legal requirements; d. the accurate and complete accounting and reporting of all revenues, expenditures and costs incurred in providing any service to any Federal health care program beneficiary or submitted to any Federal health care program; e. the accurate and complete reporting of all Federal health care program information; f. the accurate and complete preparation, certification, and submission of accurate bills for services rendered bids to Federal health care program patientsprograms; b. g. policies, procedures procedures, and other requirements applicable to the documentation of medical records; c. h. Federal health care program requirements regarding the personal obligation accurate coding and submission of each individual involved in the billing process to ensure that such ▇▇▇▇▇▇▇▇ are accurateclaims; d. i. all applicable reimbursement statutes, regulations, and program requirements and directives; e. j. the legal sanctions for improper ▇▇▇▇▇▇▇▇violations of the Federal health care program requirements; andand Corporate Integrity Agreement WellCare Health Plans, Inc. f. k. examples of proper and improper billing accounting and reporting of expenditures and other information to Federal health care programs, and proper and improper claims submission practices. Persons providing To the extent that WellCare provided Specific Training must be knowledgeable about to Relevant Covered Persons during the subject area180 days immediately prior to the Effective Date that satisfied the requirement set forth in Section III.C.2 above, WellCare is not required to repeat initial Specific Training for those individuals for the first Reporting Period. Affected new New Relevant Covered Persons shall receive the Specific Training this training within 30 days after the beginning of their employment or becoming a Relevant Covered Person Persons, or within 120 90 days of after the effective date of this CCAEffective Date, whichever is later. If a A new Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program has any responsibility for the delivery of patient care, the preparation or submission of claims, and/or the assignment of procedure codes prior to completing this Specific Training, a Relevant Covered Person who has not completed the Specific Training shall review all of the untrained person's work regarding the delivery of patient care, the preparation not perform Reimbursement Related Functions until such time as he or submission of claims, and the assignment of procedure codes. Covered Persons who have received the above-required Specific Training, she completes his or its equivalent, within 12 months prior to the effective date of this CCA are exempted from the above four (4) hour her Specific Training requirement for consistent with categories of work that trigger training in this Section. After receiving the first year of initial Specific Training described in this CCA only. CHS shall maintain records sufficient to support a listing of those Covered Persons for whom CHS is claiming such an exemption as well as the date(s) and topics of the training received by those Covered Persons. Every Section, each Relevant Covered Person who is a physician or is involved in the preparation or submission of claims for reimbursement (including, but not limited to, coding and billing) from any Federal health care program shall receive at least four (4) two hours of such Specific Training on an annual basis. All training materials used for the Specific Training shall be made available to OIG upon requestin each subsequent Reporting Period.