Common use of EFFECTIVE AND BINDING AGREEMENT Clause in Contracts

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s obligations under this IA based on a certification by Center for Pain Management that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management is relieved of its IA obligations, Center for Pain Management shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents and warrants that she is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇▇▇ ▇▇▇▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management▇▇▇▇▇ Pharmacy’s obligations under this IA based on a certification by Center for Pain Management ▇▇▇▇▇ ▇▇▇▇▇▇▇▇ that he/it is no longer providing health care items or services that will be billed to any Federal health care program and he/it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇▇ Pharmacy is relieved of his/its IA obligations, Center for Pain Management ▇▇▇▇▇ Pharmacy shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇▇▇ Pharmacy plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management▇▇▇▇▇ Pharmacy’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ Pharmacy signatory represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 / ▇▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇ 3/27/2020_ DATE Counsel for ▇, M.D. DATE ▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇ /▇▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /3/27/2020 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇ DATE Chief Executive Officer ▇▇▇▇ ▇. Square Pharmacy, Inc. /▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇▇▇▇/ 3/27/2020 ▇▇▇▇▇ & ▇▇▇▇▇▇▇▇▇▇ DATE Counsel for ▇▇▇▇ Square Pharmacy, s.c. Inc. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇/ _ 03/30/2020_ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇_ 3/30/2020_ ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Counsel to the Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Toccoa and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementToccoa’s obligations under this IA CIA based on a certification by Center for Pain Management Toccoa that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Toccoa is relieved of its IA CIA obligations, Center for Pain Management Toccoa shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Toccoa plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementToccoa’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Toccoa signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IA.CIA.‌ F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇/T. ▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE M.D./‌‌‌‌‌ /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, M.D./‌‌‌‌ /▇▇▇/ 05/01/2020 ▇▇▇▇▇ ▇▇▇▇▇▇▇▇, M.D./‌ /▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇/‌‌‌‌‌‌ /▇▇▇▇▇ DATE Associate Counsel Office ▇▇▇▇▇▇▇/‌‌ APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ A. IRO Engagement‌ 1. Toccoa shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.8 of Inspector General U.S. Department the CIA or any additional information submitted by Toccoa in response to a request by OIG, whichever is later, OIG will notify Toccoa if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Toccoa may continue to engage the IRO.‌ 2. If Toccoa engages a new IRO during the term of Health and Human Services This Appendix contains the CIA, that IRO must also meet the requirements relating to of this Appendix. If a new IRO is engaged, Toccoa shall submit the Independent Review Organization (IRO) required by information identified in Section III.E V.A.8 of the IA.CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Toccoa at the request of OIG, whichever is later, OIG will notify Toccoa if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Toccoa may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ ▇▇▇▇, Village and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management▇▇▇▇’▇ or Village’s obligations under this IA based on a certification by Center for Pain Management ▇▇▇▇ or Village that he/it is is/are no longer providing health care items or services that will be billed to any Federal health care program and he/it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management is ▇▇▇▇ or Village are relieved of his/its IA obligations, Center for Pain Management ▇▇▇▇ or Village (as applicable) shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management plans ▇▇▇▇ or Village (as applicable) plan to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modifiedmodified with respect to ▇▇▇▇ or Village (as applicable). D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Managementthe Practice’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements.requirements.‌‌ E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents signatories for the Practice represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /ON BEHALF OF ▇▇. ▇▇▇ ▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇ ▇▇▇▇ AND VILLAGE DERMATOLOGY AND COSMETIC SURGERY, L.L.C.‌‌ ▇▇. ▇▇▇ ▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇ ▇▇▇▇ DATE on behalf of himself and on behalf of Village Dermatology and Cosmetic Surgery, LLC ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ DATE Counsel for ▇▇. ▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE and Village Dermatology and Cosmetic Surgery, LLC ▇▇▇▇▇▇ ▇▇▇▇▇▇▇ & 100 S.E. ▇▇▇ ▇▇▇▇▇▇, s.c. /▇▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇, ▇▇ ▇▇▇▇▇ ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌‌ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ BERLIN DATE Associate Senior Counsel Administrative and Civil Remedies Branch Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. The Practice shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by the Practice in response to a request by OIG, whichever is later, OIG will notify the Practice if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, the Practice may continue to engage the IRO.‌ 2. If the Practice engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, the Practice shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by the Practice at the request of OIG, whichever is later, OIG will notify the Practice if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, the Practice may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Quarterly Claims Review who have expertise in the Medicare and state Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Quarterly Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Quarterly Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professional acting within their scope of practice and specialized expertise) to make the medical necessity determinations required by the Quarterly Claims Review; and‌ 5. have sufficient staff and resources to conduct the reviews required by the IA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Quarterly Claims Review in accordance with the specific requirements of the IA;‌ 2. follow all applicable Medicare and state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare or state Medicaid program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the IA. D. The Practice Responsibilities‌ The Practice shall ensure that the IRO has access to all records and personnel necessary to complete the reviews listed in Section III.C of this IA and that all records furnished to the IRO are accurate and complete.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management BPMC and OIG agree as follows: A. This IA RCA shall become final and binding on the date the final signature is obtained on the IARCA. B. This IA RCA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IARCA. C. OIG may agree to a suspension of Center for Pain ManagementBPMC’s obligations under this IA RCA based on a certification by Center for Pain Management BPMC that it is no longer providing health care items or services that will be billed to any a recipient of HHS Federal health care program awards and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any receives of applies for HHS Federal health care programawards. If Center for Pain Management BPMC is relieved of its IA RCA obligations, Center for Pain Management BPMC shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management BPMC plans to resume providing health care items or services that are billed to any apply for HHS Federal health care program awards or to obtain an ownership or control interest in any entity that bills any receives or applies for HHS Federal health care programawards. At such time, OIG shall evaluate whether the IA RCA will be reactivated or modified. D. All requirements and remedies set forth in this IA RCA are in addition to and do not affect: affect (1) Center for Pain ManagementBPMC’s responsibility to follow all applicable Federal award requirements and Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal award requirements and Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents BPMC signatories represent and warrants warrant that she is they are authorized to execute this IARCA. The undersigned OIG signatories represent that they are signing this IA RCA in their official capacity capacities and that they are authorized to execute this IARCA. F. This IA RCA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IARCA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IARCA. /▇▇▇▇▇▇▇ ▇▇▇▇▇▇-▇▇▇▇▇▇▇/_ 4/29/20 7/10/2020 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. ▇-▇▇▇▇▇▇▇ DATE Chairwoman of the Board of Directors /▇▇▇▇ ▇. ▇▇/ _ 07/14/2020_ ▇▇▇▇ ▇. Re DATE Assistant Inspector General for Legal Affairs Office of Inspector General U.S. Department of Health and Human Services /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20/_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇7/10/2020_ ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇ DATE Senior Counsel Office of Inspector General U.S. Department of Health and Human Services ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) and the Compliance Expert required by Section III.E III.D of the IARCA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Practitioner and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementPractitioner’s obligations under this IA based on a certification by Center for Pain Management Practitioner that it he is no longer providing health care items or services that will be billed to any Federal health care program and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Practitioner is relieved of its his IA obligations, Center for Pain Management Practitioner shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Practitioner plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementPractitioner’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ Practitioner signatory represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇// 6/24/2020_ 4/29/20 ▇▇▇▇▇▇▇ ▇. ▇▇▇▇, M.D. MD DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20__ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ 6/24/2020_ ▇▇▇▇▇▇▇ & ▇▇ ▇▇▇▇, s.c. MD DATE President Medscan, PSC /▇▇▇▇ ▇. Re/ 05/01/2020 Re/_ 6/30/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇6 July 2020 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Practitioner and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementPractitioner’s obligations requirements under this IA based on a certification by Center for Pain Management Practitioner that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Practitioner is relieved of its IA obligationsrequirements, Center for Pain Management Practitioner shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Practitioner plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementPractitioner’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ Practitioner signatory represents and warrants that she it is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA.IA.‌‌ F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. ON BEHALF OF PRACTITIONER‌‌ /▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇/_ 4/29/20 _ ▇▇. ▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇ 11/30/2021_ DATE 11/30/2021_ DATE ▇▇▇▇ ▇. ▇▇▇▇▇ ▇▇▇▇ ▇▇▇▇▇ & ▇▇▇▇ PLC COUNSEL FOR BELLAMAH VEIN CENTER AND ▇▇. ▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ 11/30/21 _ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌‌ /▇▇▇▇ ▇. Re/ 05/01/2020 12/14/2021_ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. U.S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 _ 12/14/2021_ _ ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. Practitioner shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by Practitioner in response to a request by OIG, whichever is later, OIG will notify Practitioner if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Practitioner may continue to engage the IRO.‌ 2. If Practitioner engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Practitioner shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by Practitioner at the request of OIG, whichever is later, OIG will notify Practitioner if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Practitioner may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Quarterly Claims Review who have expertise in the Medicare, state Medicaid, TRICARE and the Department of Veterans Affairs, Veterans Health Administration program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Quarterly Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Quarterly Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professional acting within their scope of practice and specialized expertise) to make the medical necessity determinations required by the Quarterly Claims Review; and‌‌‌ 5. have sufficient staff and resources to conduct the reviews required by the IA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Quarterly Claims Review in accordance with the specific requirements of the IA;‌ 2. follow all applicable Medicare, state Medicaid, TRICARE and the Department of Veterans Affairs, Veterans Health Administration program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare, state Medicaid, TRICARE or Department of Veterans Affairs, Veterans Health Administration program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management MMW and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementMMW’s obligations under this IA based on a certification by Center for Pain Management MMW that it [he/she] is no longer providing health care items or services that will be billed to any Federal health care program and it [he/she] does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management MMW is relieved of its [his/her] IA obligations, Center for Pain Management MMW shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management MMW plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementMMW’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ MMW signatory represents and warrants that she [he/she] is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/ ▇▇▇▇▇ ▇. ▇▇▇▇▇ 3/28/2017 DATE /_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇/ ▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center ▇ Partner, ▇▇▇▇▇ ▇▇▇▇▇▇ LLP Counsel for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇ 5/1/17 DATE /▇▇▇▇▇ ▇▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ Mobility Metabolism and Wellness, P.C. 3/28/2017 DATE /▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & / ▇▇▇▇▇▇ ▇▇▇▇▇▇ Partner, s.c. ▇▇▇▇▇ ▇▇▇▇▇▇ LLP Counsel for Mobility Metabolism and Wellness, P.C. DATE /▇▇▇▇ ▇. Re/ 05/01/2020 5/8/17 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇5/2/2017 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ LCPCC and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementLake Country Pharmacy and Compounding Center’s obligations and/or ▇▇▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇’▇ obligations and/or ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇’▇ obligations under this IA based on a certification by Center for Pain Management LCPCC, ▇▇▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇, or ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ that it it/he/she is no longer providing health care items or services that will be billed to any Federal health care program and it program. It/he/she must also certify that it/he/she does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Lake Country Pharmacy and Compounding Center, ▇▇▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇, and/or ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ is relieved of its IA obligations, Center for Pain Management it/he/she shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management it/he/she plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. . All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s LCPCCs responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. D. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ LCPCC signatory represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. E. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. ON BEHALF OF LAKE COUNTRY PHARMACY AND COMPOUNDING CENTER‌ /▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇/ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ Lake Country Pharmacy And Compounding Center DATE ▇.▇. ▇▇▇▇▇ Counsel for LCPCC DATE /_ 4/29/20 ▇▇▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇, M.D. DATE /▇▇▇/ 6/6/19 ‌‌ ▇▇▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ DATE /▇.▇. ▇▇▇▇▇/ 4/29/20 Center 6/7/19 ‌‌ Counsel for Pain Management, S.C. ▇▇▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ 6/6/19 ‌‌ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ DATE /▇.▇. ▇▇▇▇▇/ 6/7/19 ‌‌ Counsel for ▇▇▇▇▇ DATE ▇▇▇ . ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 DATE ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General Generl U.S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. LCPCC shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by LCPCC in response to a request by OIG, whichever is later, OIG will notify LCPCC if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, LCPCC may continue to engage the IRO.‌ 2. If LCPCC engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged LCPCC shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by LCPCC at the request of OIG, whichever is later, OIG will notify LCPCC if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, LCPCC may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Dr. Uradu and UTC and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementDr. Uradu and UTC’s obligations under this IA based on a certification by Center for Pain Management Dr. Uradu and UTC that it is they are no longer providing health care items or services that will be billed to any Federal health care program and it does they do not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management is Dr. Uradu and UTC are relieved of its their IA obligations, Center for Pain Management Dr. Uradu and UTC shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management plans Dr. Uradu and/or UTC plan to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementDr. Uradu and UTC’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ Dr. Uradu and UTC signatory represents and warrants that she is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. ON BEHALF OF DR. URADU AND UTC‌‌ /▇▇▇▇ ▇▇▇▇▇/ ▇▇▇▇ ▇. ▇▇▇▇▇, M.D. DATE a/k/a ▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇ Uradu Personally and on behalf of Ultimate Care Medical Services, LLC d/b/a Ultimate Treatment Center ▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇Counsel for: ▇▇▇▇ ▇. ▇▇▇▇▇▇ , M.D. a/k/a ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE Uradu and Ultimate Care Medical Services, LLC d/b/a Ultimate Treatment Center ▇▇▇▇ ▇▇▇▇▇▇▇▇▇ & ▇▇▇▇ ▇▇▇▇▇ ▇▇▇▇ ▇ ▇▇▇▇▇▇▇▇▇▇, s.c. /▇▇ ▇▇▇▇▇ ▇. Re/ 05/01/2020 ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌‌ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ BERLIN DATE Associate Senior Counsel Administrative and Civil Remedies Branch Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. Dr. Uradu and UTC shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by Dr. Uradu and UTC in response to a request by OIG, whichever is later, OIG will notify Dr. Uradu and UTC if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Dr. Uradu and UTC may continue to engage the IRO.‌ 2. If Dr. Uradu and UTC engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Dr. Uradu and UTC shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by Dr. Uradu and UTC at the request of OIG, whichever is later, OIG will notify Dr. Uradu and UTC if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Dr. Uradu and UTC may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Quarterly Claims Review who have expertise in the Medicare and state Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Quarterly Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Quarterly Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professional acting within their scope of practice and specialized expertise) to make the medical necessity determinations required by the Quarterly Claims Review; and‌ 5. have sufficient staff and resources to conduct the reviews required by the IA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Quarterly Claims Review in accordance with the specific requirements of the IA;‌ 2. follow all applicable Medicare and state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare or state Medicaid program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management SOS and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementSOS’s obligations under this IA based on a certification by Center for Pain Management SOS that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management SOS is relieved of its IA obligations, Center for Pain Management SOS shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management SOS plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementSOS’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents SOS signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇ ▇▇▇▇/ 6/30/2020 ▇▇▇▇▇ ▇▇▇▇, D.O. DATE Chairman, Executive Committee /▇/_ 4/29/20 . ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇/ 7/2/20 ▇. ▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center ▇▇ DATE McAfee & ▇▇▇▇ Counsel for Pain ManagementSouthwest Orthopaedic Specialists, S.C. DATE PLLC /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 07/07/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. U.S. Department of Health and Human Services /▇▇▇▇▇ ▇▇▇▇▇▇▇▇/ _ 07/07/2020 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.F of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Vanguard and OIG agree as follows: A. This IA CIA shall be binding on the successors, assigns, and transferees of Vanguard; B. This CIA shall become final and binding on the date the final signature is obtained on the IA.CIA; B. C. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA.CIA; C. D. OIG may agree to a suspension of Center for Pain ManagementVanguard’s obligations under this IA CIA based on a certification by Center for Pain Management Vanguard that it is no longer providing health care items or services that will be billed to any Federal health care program and that it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Vanguard is relieved of its IA CIA obligations, Center for Pain Management shall Vanguard will be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Vanguard plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents and warrants that she is authorized to execute this IA. The undersigned OIG Vanguard signatories represent that they are signing this IA in their official capacity and warrant that they are authorized to execute this IACIA. The undersigned OIG signatory represents that he is signing this CIA in his official capacity and that he is authorized to execute this CIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇. ▇▇▇▇/_ 4/29/20 ▇/ 10/5/2011 ▇▇▇▇▇▇▇ ▇. ▇▇▇▇, M.D. ▇ President and Chief Executive Officer DATE /▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /10/7/2011 ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇▇▇-JCA and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by prior written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management▇▇▇▇▇-JCA’s obligations under this IA based on a certification by Center for Pain Management ▇▇▇▇▇-JCA that it is no longer providing health care items or services that will be billed to any Federal health care program programs and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, interest in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇▇-JCA is relieved of its IA obligations, Center for Pain Management ▇▇▇▇▇-JCA shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇▇▇-JCA plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, the OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to to, and do not affect: affect (1) Center for Pain Management▇▇▇▇▇-JCA’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ -JCA signatory represents and warrants that she it is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇ ▇▇▇ . ▇▇▇▇▇/_ 4/29/20 , ▇.▇./ 5/9/13 ▇▇▇▇▇ ▇. ▇▇▇▇▇, ▇.▇. ▇▇▇▇ ▇▇▇▇▇, M.D. DATE ▇▇ Cardiology Associates /▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇/ 4/29/20 Center 5/9/13 ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇ Counsel for Pain Management, S.C. DATE ▇▇▇▇▇-JCA Date /▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ 6/3/13 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Counsel to the Inspector General Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇6/4/2013 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Healogics and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain Management’s Healogics’ obligations under this IA CIA based on a certification by Center for Pain Management Healogics that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Healogics is relieved of its IA CIA obligations, Center for Pain Management Healogics shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Healogics plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain Management’s Healogics’ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Healogics signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE 06/05/2018 /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services 06/05/2018 /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services 06/05/2018 This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. Healogics shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.7 of the CIA or any additional information submitted by Healogics in response to a request by OIG, whichever is later, OIG will notify Healogics if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Healogics may continue to engage the IRO.‌ 2. If Healogics engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Healogics shall submit the information identified in Section V.A.7 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Healogics at the request of OIG, whichever is later, OIG will notify Healogics if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Healogics may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review who have expertise in the Medicare and state Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌‌ 4. assign licensed nurses or physicians with relevant education, training, and specialized expertise (or other licensed health care professionals acting within their scope of practice and specialized expertise) to make the medical necessity determinations required by the Claims Review; and‌ 5. have sufficient staff and resources to conduct the reviews required by the CIA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Claims Review and Independent Practitioners’ Review in accordance with the specific requirements of the CIA;‌ 2. follow all applicable Medicare and state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. follow all applicable standards of practice in making assessments in the Independent Practitioners’ Review;‌ 4. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare or state Medicaid program policy or regulation;‌‌ 5. respond to all OIG inquires in a prompt, objective, and factual manner; and 6. prepare timely, clear, well-written reports that include all the information required by Appendices B and C to the CIA. ▇. ▇▇▇▇▇▇▇▇▇ Responsibilities‌ Healogics shall ensure that the IRO has access to all records and personnel necessary to complete the reviews listed in III.D of this CIA and that all records furnished to the IRO are accurate and complete.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by prior written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s ▇▇▇▇▇’ obligations under this IA based on a certification by Center for Pain Management ▇▇▇▇▇ that it is no longer providing health care items or services that will be billed to any Federal health care program and it programs ▇▇▇▇▇ does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, interest in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇▇ is relieved of its IA obligations, Center for Pain Management ▇▇▇▇▇ shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, the OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to to, and do not affect: affect (1) Center for Pain Management’s ▇▇▇▇▇’ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇ ▇▇ ▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇ ▇▇▇▇▇▇ ▇▇▇▇, ▇▇ ▇▇▇▇▇-▇▇▇▇ Date ▇▇▇ ▇▇ ▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇ ▇▇▇▇▇▇ ▇▇▇▇, ▇▇ ▇▇▇▇▇-▇▇▇▇ Date PERFECT SENSE EYE CENTER ST. ▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇ ▇▇. ▇▇▇▇▇▇, MO 64506 Date /▇▇▇▇ ▇. ▇▇▇▇▇▇/ Counsel for ▇▇. ▇▇▇▇▇, M.D. DATE /▇▇▇▇for Perfect Sense Eye Center, PC, and for Perfect Sense Eye Center St. ▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. & ▇▇▇▇▇▇ ▇▇▇▇ DATE LLP ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇, s.c. /▇▇ ▇▇▇▇▇▇▇▇▇▇, ▇▇ ▇▇▇▇▇-▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services Date 9/8/14 /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Assistant Inspector General for Legal Affairs Office of Counsel to the Inspector General Office of Inspector General U.S. U. S. Department of Health and Human Services 9/12/14 DATE /▇▇▇▇ ▇▇▇▇▇▇▇▇▇/ ▇▇▇▇ ▇▇▇▇▇▇▇▇▇ Senior Counsel September 9, 2014 DATE This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s ▇▇▇▇▇’▇ obligations under this IA based on a certification by Center for Pain Management ▇▇▇▇▇ that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇▇ is relieved of its IA obligations, Center for Pain Management ▇▇▇▇▇ shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain Management’s ▇▇▇▇▇’▇ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇ ▇▇▇▇▇/_ 3/16/2020_ _ ▇▇▇▇ ▇▇▇▇▇ DATE Chief Executive Officer ▇▇▇▇▇ Laboratories, LLC /▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 _ 3/16/2020 _ ▇▇▇▇ ▇▇▇▇▇ DATE Counsel for ▇▇▇▇▇ Laboratories, LLC ▇▇▇▇▇▇▇▇▇ Will & ▇▇▇▇▇ LLP ▇▇▇ ▇▇▇▇▇▇▇ ▇▇▇▇▇▇ New York, M.D. DATE NY 10173-1922 /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 3/06/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. U.S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇ Berlin/ 3/5/2020_ ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ BERLIN DATE Associate Senior Counsel Administrative and Civil Remedies Branch Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ ▇▇▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementSkyline’s obligations under this IA based on a certification by Center for Pain Management Skyline that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Skyline is relieved of its IA obligations, Center for Pain Management Skyline shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Skyline plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementSkyline’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Skyline signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Home Bound and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementHome Bound’s obligations under this IA CIA based on a certification by Center for Pain Management Home Bound that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Home Bound is relieved of its IA CIA obligations, Center for Pain Management Home Bound shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Home Bound plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementHome Bound’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Home Bound signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇// _ 4/29/20 08/17/2016 _ ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇ and Chief Executive Officer Home Bound DATE /▇▇▇▇ ▇▇▇▇▇▇▇▇/ 4/29/20 Center for Pain Management_ 08-17-2016 _ ▇▇▇▇ ▇▇▇▇▇▇▇▇, S.C. ▇▇.Owner Home DATE Bound /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ 8/17/16 _ ▇▇▇▇▇ ▇. SpevackMonico & ▇▇▇▇▇▇▇ Counsel for Home Bound DATE /▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇/ _ 8-17-16 _ ▇▇▇▇▇▇ ▇. KulwinKulwin, ▇▇▇▇▇▇▇▇▇▇▇ & ▇▇▇▇▇▇, s.c. L.L.P. DATE Counsel for Home Bound /▇▇▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇▇▇▇/ _ 8/16/16 _ ▇▇▇▇▇▇ ▇. RE ▇▇▇▇▇▇▇ DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇_ 8-15-2016 _ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Counsel to the Inspector General Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management First Call and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementFirst Call’s obligations under this IA CIA based on a certification by Center for Pain Management First Call that it is no longer providing health care items or services that will be billed to any Federal health care program and that it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management First Call is relieved of its IA CIA obligations, Center for Pain Management shall First Call will be required to notify OIG in writing at least 30 days in advance if Center for Pain Management First Call plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents First Call signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. E. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇. ▇▇▇▇/_ 4/29/20 / ▇▇▇▇▇▇▇ ▇. ▇▇▇▇, M.D. DATE ▇ Chief Executive Officer 5/27/2014 Date /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center ▇▇▇▇▇ ▇▇▇▇▇ Counsel for Pain ManagementFirst Call Ambulance Service, S.C. DATE LLC May 27, 2014 Date /▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇ ▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇ ▇▇▇▇▇ DATE Associate Senior Counsel Office of Counsel to the Inspector General Office of Inspector General U.S. Department of Health and Human Services 5/28/14 Date 5/28/14 Date This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ ▇▇▇▇▇▇▇▇ Clinic and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management▇▇▇▇▇▇▇▇ Clinic’s obligations requirements under this IA based on a certification by Center for Pain Management ▇▇. ▇▇▇▇ ▇. Escandon, Jr. that it ▇▇▇▇▇▇▇▇ Clinic is no longer providing health care items or services that will be billed to any Federal health care program and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇▇▇▇▇ Clinic is relieved of its IA obligationsrequirements, Center for Pain Management ▇▇▇▇▇▇▇▇ Clinic shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇▇▇▇▇▇ Clinic plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified.modified.‌ D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management▇▇▇▇▇▇▇▇ Clinic’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements.requirements.‌ E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ Clinic signatory represents and warrants that she [he/she] is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA.IA.‌ F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IAIA.‌ /▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇/ 02/07/22 ▇▇. ▇▇▇▇ ▇. ESCANDON, JR. DATE President and Owner, ▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇, M.D., P.A., d/b/a ▇▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE Diagnostic Clinic /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇/_ 02/07/22 ‌‌ ▇▇▇▇▇▇ ▇. ▇▇▇▇▇ DATE ▇▇▇▇▇ ▇▇▇▇/ _4/29/20▇▇ Counsel for ▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇, M.D., P.A., d/b/a ▇▇▇▇▇▇▇▇ Diagnostic Clinic /▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇/_ _ 02/07/22 ‌‌ ▇▇. ▇▇▇▇ ▇. ESCANDON, JR. DATE /▇▇▇▇▇▇ ▇. ▇▇▇▇▇/_ 02/07/22 ‌‌ ▇▇▇▇▇▇ ▇. ▇▇▇▇▇ DATE ▇▇▇▇▇ ▇▇▇▇▇▇ Counsel for ▇▇ & ▇. ▇▇▇▇ ▇▇. Escandon, s.c. Jr. /▇▇▇▇ ▇. Re/ 05/01/2020 02/14/2022_ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇/_ 02/08/2022 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. ▇▇▇▇▇▇▇▇ Clinic shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by ▇▇▇▇▇▇▇▇ Clinic in response to a request by OIG, whichever is later, OIG will notify ▇▇▇▇▇▇▇▇ Clinic if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇▇▇▇▇▇▇ Clinic may continue to engage the IRO.‌ 2. If ▇▇▇▇▇▇▇▇ Clinic engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, ▇▇▇▇▇▇▇▇ Clinic shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by ▇▇▇▇▇▇▇▇ Clinic at the request of OIG, whichever is later, OIG will notify ▇▇▇▇▇▇▇▇ Clinic if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇▇▇▇▇▇▇ Clinic may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Quarterly Claims Review who have expertise in the Medicare and state Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Quarterly Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Quarterly Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professional acting within their scope of practice and specialized expertise) to make the medical necessity determinations required by the Quarterly Claims Review; and‌‌‌ 5. have sufficient staff and resources to conduct the reviews required by the IA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Quarterly Claims Review in accordance with the specific requirements of the IA;‌ 2. follow all applicable Medicare and state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare or state Medicaid program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the IA. ▇. ▇▇▇▇▇▇▇▇ Clinic Responsibilities‌ ▇▇▇▇▇▇▇▇ Clinic shall ensure that the IRO has access to all records and personnel necessary to complete the reviews listed in Section III.C of this IA and that all records furnished to the IRO are accurate and complete.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ ▇▇. ▇▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s ▇▇. ▇▇▇▇▇▇’▇ obligations under this IA based on a certification by Center for Pain Management ▇▇. ▇▇▇▇▇▇ that it he is no longer providing health care items or services that will be billed to any Federal health care program and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇. ▇▇▇▇▇▇ is relieved of its his IA obligations, Center for Pain Management ▇▇. ▇▇▇▇▇▇ shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇. ▇▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management▇▇. ▇▇▇▇▇▇ and MRA’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned signatory on behalf of ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ and MRA represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇/ ▇▇. ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. . FELDER DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. METROPOLITAN RETINA ASSOCIATES DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇▇ DATE ▇▇▇▇▇ ▇▇▇▇▇▇ Counsel for ▇▇ & ▇. ▇▇▇▇▇, s.c. ▇ and MRA DATE /▇▇▇▇ ▇. Re/ 05/01/2020 10/03/2018 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇10/03/2018 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Preferred Imaging and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementPreferred Imaging’s obligations under this IA CIA based on a certification by Center for Pain Management Preferred Imaging that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Preferred Imaging is relieved of its IA CIA obligations, Center for Pain Management Preferred Imaging shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Preferred Imaging plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified.. Preferred Imaging Centers, LLC Corporate Integrity Agreement D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementPreferred Imaging’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Preferred Imaging signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇Preferred Imaging Centers, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE LLC Corporate Integrity Agreement 6/21/16 /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇6-21-16 Preferred Imaging Centers, s.c. LLC Corporate Integrity Agreement /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇6/23/16 /▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services / 6/29/16 APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. Preferred Imaging shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.7 of the CIA or any additional information submitted by Preferred Imaging in response to a request by OIG, whichever is later, OIG will notify Preferred Imaging if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Preferred Imaging may continue to engage the IRO.‌ 2. If Preferred Imaging engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Preferred Imaging shall submit the information identified in Section V.A.7 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Preferred Imaging at the request of OIG, whichever is later, OIG will notify Preferred Imaging if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Preferred Imaging may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review who have expertise in the Medicare and state Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements); and‌‌ 4. have sufficient staff and resources to conduct the reviews required by the CIA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Claims Review in accordance with the specific requirements of the CIA;‌ 2. follow all applicable Medicare and state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare or state Medicaid program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the CIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Healogics and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain Management’s Healogics’ obligations under this IA CIA based on a certification by Center for Pain Management Healogics that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Healogics is relieved of its IA CIA obligations, Center for Pain Management Healogics shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Healogics plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain Management’s Healogics’ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Healogics signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE 06/05/2018 /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services 06/05/2018 /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services 06/05/2018 /▇▇▇▇ ▇. Re/ 6/5/18 /▇▇▇▇▇▇ ▇▇▇▇▇▇ Berlin/ 5/31/18 This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. Healogics shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.7 of the CIA or any additional information submitted by Healogics in response to a request by OIG, whichever is later, OIG will notify Healogics if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Healogics may continue to engage the IRO.‌ 2. If Healogics engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Healogics shall submit the information identified in Section V.A.7 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Healogics at the request of OIG, whichever is later, OIG will notify Healogics if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Healogics may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review who have expertise in the Medicare and state Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌‌ 4. assign licensed nurses or physicians with relevant education, training, and specialized expertise (or other licensed health care professionals acting within their scope of practice and specialized expertise) to make the medical necessity determinations required by the Claims Review; and‌ 5. have sufficient staff and resources to conduct the reviews required by the CIA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Claims Review and Independent Practitioners’ Review in accordance with the specific requirements of the CIA;‌ 2. follow all applicable Medicare and state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. follow all applicable standards of practice in making assessments in the Independent Practitioners’ Review;‌ 4. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare or state Medicaid program policy or regulation;‌‌ 5. respond to all OIG inquires in a prompt, objective, and factual manner; and 6. prepare timely, clear, well-written reports that include all the information required by Appendices B and C to the CIA. D. Healogics Responsibilities‌ Healogics shall ensure that the IRO has access to all records and personnel necessary to complete the reviews listed in III.D of this CIA and that all records furnished to the IRO are accurate and complete.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Provider and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementProvider’s obligations requirements under this IA based on a certification by Center for Pain Management Provider that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Provider is relieved of its IA obligationsrequirements, Center for Pain Management Provider shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Provider plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementProvider’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Provider signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. OLIVE STREET PHARMACY, LLC /▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇▇/ BY: ▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇▇ Manager BY: /▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇▇▇/ ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇ LLP Counsel for Olive Street Pharmacy, LLC 9/28/21 DATE: DATE: 9-27-21 BY: /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 / DATE: 9-27-21 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. P.C. Counsel for Olive Street Pharmacy, LLC /▇▇▇▇ ▇. Re/ 05/01/2020 9/30/21 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇9.30.2021 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management LFAC and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementLFAC’s obligations under this IA based on a certification by Center for Pain Management LFAC that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management LFAC is relieved of its IA obligations, Center for Pain Management LFAC shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management LFAC plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementLFAC’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents LFAC signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇/ 04-30-2020 ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇, DPM DATE /_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE ▇/_ 4-30-20 ▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. Counsel for LFAC /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇4-29-2020 ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Princeton Pathology and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementPrinceton Pathology’s obligations requirements under this IA based on a certification by Center for Pain Management Princeton Pathology that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Princeton Pathology is relieved of its IA obligationsrequirements, Center for Pain Management Princeton Pathology shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Princeton Pathology plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementPrinceton Pathology’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Princeton Pathology signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇ President Princeton Pathology Services, P.A. DATE /▇▇▇▇ ▇. ▇▇▇▇▇/__ ▇▇▇▇ ▇. ▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇, ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇, s.c. P.A. Counsel for Princeton Pathology DATE /▇▇▇▇ ▇. Re/ 05/01/2020 12/03/2021 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇ ▇. ▇▇▇▇▇▇/_ 12/07/2021_ ▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA. A. IRO Engagement‌ 1. Princeton Pathology shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.4 of the IA or any additional information submitted by Princeton Pathology in response to a request by OIG, whichever is later, OIG will notify Princeton Pathology if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Princeton Pathology may continue to engage the IRO.‌ 2. If Princeton Pathology engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Princeton Pathology shall submit the information identified in Section V.A.4 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Princeton Pathology at the request of OIG, whichever is later, OIG will notify Princeton Pathology if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Princeton Pathology may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Quarterly Claims Review who have expertise in the billing, coding, claims submission and other applicable Medicare and state Medicaid program requirements;‌ 2. assign individuals to design and select the Quarterly Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Quarterly Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professionals acting within their scope of practice and specialized expertise) to make the medical necessity determinations required by the Quarterly Claims Review; and‌‌‌ 5. have sufficient staff and resources to conduct the reviews required by the IA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Quarterly Claims Review in accordance with the specific requirements of the IA;‌ 2. follow all applicable Medicare and state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare or state Medicaid program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the IA. D. Princeton Pathology Responsibilities‌ Princeton Pathology shall ensure that the IRO has access to all records and personnel necessary to complete the reviews listed in Section III.E of this IA and that all records furnished to the IRO are accurate and complete.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Gonzaga and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementGonzaga’s obligations requirements under this IA based on a certification by Center for Pain Management Gonzaga that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Gonzaga is relieved of its IA obligationsrequirements, Center for Pain Management Gonzaga shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Gonzaga plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementGonzaga’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Gonzaga signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇, MD/ ▇▇▇▇▇▇ ▇▇▇▇▇▇▇, M.D. _7/22/2022 _ DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for ▇▇, MD/_ ▇▇▇▇▇▇ ▇▇▇▇▇▇▇, M.D. For Gonzaga Interventional Pain Management and ▇▇▇▇▇▇▇ Anesthesia and Pain Management, S.C. P.A. __7/22/2022 _ DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20/_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇ ▇▇▇▇▇▇▇ MCGUIREWOODS LLP Counsel for ▇▇▇▇▇▇ ▇▇▇▇▇▇▇, s.c. M.D., Gonzaga Interventional Pain Management, and ▇▇▇▇▇▇▇ Anesthesia and Pain Management, P.A. DATE /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services DATE /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇/_ ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ Senior Counsel DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA. A. IRO Engagement‌ 1. Gonzaga shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.4 of the IA or any additional information submitted by Gonzaga in response to a request by OIG, whichever is later, OIG will notify Gonzaga if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Gonzaga may continue to engage the IRO.‌ 2. If Gonzaga engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Gonzaga shall submit the information identified in Section V.A.4 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Gonzaga at the request of OIG, whichever is later, OIG will notify Gonzaga if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Gonzaga may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management LFAC and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementLFAC’s obligations under this IA based on a certification by Center for Pain Management LFAC that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management LFAC is relieved of its IA obligations, Center for Pain Management LFAC shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management LFAC plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementLFAC’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents LFAC signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Foot Healers and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s Foot Healers’ obligations under this IA based on a certification by Center for Pain Management Foot Healers that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Foot Healers is relieved of its IA obligations, Center for Pain Management Foot Healers shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Foot Healers plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain Management’s Foot Healers’ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Foot Healers signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇▇/ 4/30/18 ‌‌ /_ 4/29/20 ▇▇▇▇ ▇. Re/ 5/11/2018 /▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services 5/11/18 APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IA. A. IRO Engagement‌ 1. Foot Healers shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.4 of the IA or any additional information submitted by Foot Healers in response to a request by OIG, whichever is later, OIG will notify Foot Healers if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Foot Healers may continue to engage the IRO.‌ 2. If Foot Healers engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Foot Healers shall submit the information identified in Section V.A.4 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Foot Healers at the request of OIG, whichever is later, OIG will notify Foot Healers if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Foot Healers may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Quarterly Claims Review who have expertise in the billing, coding, claims submission and other applicable Medicare and state Medicaid program requirements;‌ 2. assign individuals to design and select the Quarterly Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Quarterly Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professionals acting within their scope of practice and specialized expertise) to make the medical necessity determinations required by the Quarterly Claims Review; and‌‌ 5. have sufficient staff and resources to conduct the reviews required by the IA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Quarterly Claims Review in accordance with the specific requirements of the IA;‌ 2. follow all applicable Medicare and state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare or state Medicaid program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the IA. D. Foot Healers Responsibilities‌ Foot Healers shall ensure that the IRO has access to all records and personnel necessary to complete the reviews listed in Section III.E of this IA and that all records furnished to the IRO are accurate and complete.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management RehabCare, Kindred and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementKindred’s and/or RehabCare’s, obligations under this IA CIA based on a certification by Center for Pain Management Kindred and/or RehabCare, as applicable, that it is no longer providing health care items or services that will be billed by any entity to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Kindred and/or RehabCare, as applicable, is relieved of its IA CIA obligations, Center for Pain Management Kindred and/or RehabCare, as applicable, shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Kindred and/or RehabCare, as applicable, plans to resume providing health care items or services that are billed by any entity to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementKindred’s and RehabCare’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents RehabCare and warrants Kindred signatories represent and warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. G. This CIA is by and between the parties hereto. The CIA is not intended to establish any legal rights for or confer any legal rights upon any non-governmental entities or persons not a party to the CIA. The parties agree, however, that this CIA is a public document and it may be admissible in a judicial or administrative proceeding. /▇▇▇ ▇▇▇▇▇▇▇▇/ 1/7/16 ▇▇▇ ▇. ▇▇▇▇▇▇▇▇ President RehabCare Group, Inc. DATE /▇▇▇ ▇▇▇▇▇/ 1/8/16 ▇▇▇ ▇▇▇▇▇▇ President and Chief Executive Officer, Kindred Healthcare, Inc. /▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /1/8/16 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ DATE ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇ ▇▇▇▇▇▇▇ LLP /▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇/ 1/11/16 ▇▇▇▇▇▇ DATE ▇▇▇ . ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇1/11/16 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management OGCC and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementOGCC’s obligations requirements under this IA based on a certification by Center for Pain Management OGCC that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management OGCC is relieved of its IA obligationsrequirements, Center for Pain Management OGCC shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management OGCC plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementOGCC’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents OGCC signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE . Re/ 02/02/2022 /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Healthquest, Inc. and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementHealthquest, Inc.’s obligations under this IA based on a certification by Center for Pain Management Healthquest, Inc. that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Healthquest, Inc. is relieved of its IA obligations, Center for Pain Management Healthquest, Inc. shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Healthquest, Inc. plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementHealthquest, Inc.’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ Healthquest, Inc. signatory represents and warrants that hoe or she is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇ ▇▇▇▇▇▇▇▇▇/ 06/29/18 ‌‌ ▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. Owner DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /6/29/18 ‌‌ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.cEsq. /▇▇▇▇ ▇. Re/ 05/01/2020 DATE Counsel for Healthquest, Inc. ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. U.S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.F of the IA. A. IRO Engagement‌ 1. Healthquest, Inc. shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall not have a prohibited relationship to Healthquest, Inc., as set forth in Paragraph‌ E. Within 30 days after OIG receives the information identified in Section V.A.5 of the IA or any additional information submitted by Healthquest, Inc. in response to a request by OIG, whichever is later, OIG will notify Healthquest, Inc. if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Healthquest, Inc. may continue to engage the IRO. 2. If Healthquest, Inc. engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Healthquest, Inc. shall submit the information identified in Section V.A.5 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Healthquest, Inc. at the request of OIG, whichever is later, OIG will notify Healthquest, Inc. if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Healthquest, Inc. may continue to engage the IRO.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management APS and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementAPS’s obligations under this IA based on a certification by Center for Pain Management APS that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management APS is relieved of its IA obligations, Center for Pain Management APS shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management APS plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementAPS’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents APS signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇ ▇▇▇▇▇▇▇▇/ 6/16/2020 ▇▇▇▇▇ ▇▇▇▇▇▇▇▇, ▇.▇. ▇▇▇▇ Shareholder/_ 4/29/20 President/Treasurer Associated Pain Specialists, P.C. /▇▇▇▇▇▇ ▇▇▇▇▇, MD/ 6/16/2020 ▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE Shareholder/▇Vice President/Secretary Associated Pain Specialists, P.C. /▇▇▇▇▇▇ ▇▇▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /6/16/2020 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇Counsel for Associated Pain Specialists, s.c. P.C. /▇▇▇▇ ▇. Re/ 05/01/2020 Re/_ 06/26/2020_ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇ Berlin/ _ 6/19/2020 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ BERLIN DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Dakwa and HEAG and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementDakwa’s or HEAG’s obligations under this IA based on a certification by Center for Pain Management Dakwa or HEAG that he or it is no longer providing health care items or services that will be billed to any Federal health care program and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Dakwa or HEAG is relieved of his or its IA obligations, Center for Pain Management Dakwa and HEAG shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Dakwa or HEAG plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementDakwa’s and HEAG’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements.requirements.‌ E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Dakwa signatory and warrants HEAG signatory represent and warrant that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. ON BEHALF OF ▇▇. ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇- DAKWA‌ /▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇-▇▇▇▇▇/ May 14, 2021 _ _ ▇▇. ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇- Dakwa DATE /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇/__ ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇ Counsel _May 14, 2021 DATE /_ 4/29/20 ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇-▇▇▇▇▇/ May 14, 2021 ‌‌ ▇▇. ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇- Dakwa DATE /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇/ May 14, 2021 ‌‌ ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. Counsel ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌ /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. Re/_ 5/25/2021 LISA M. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ /Christina K. McGarvey/ 5.25.2021 CHRISTINA K. MCGARVEY DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. Dakwa and HEAG shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by Dakwa and HEAG in response to a request by OIG, whichever is later, OIG will notify Dakwa and HEAG if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Dakwa and HEAG may continue to engage the IRO.‌ 2. If Dakwa and HEAG engage a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Dakwa and HEAG shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by Dakwa and HEAG at the request of OIG, whichever is later, OIG will notify Dakwa and HEAG if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Dakwa and HEAG may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Hanflink and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementHanflink’s obligations under this IA based on a certification by Center for Pain Management Hanflink that it he is no longer providing health care items or services that will be billed to any Federal health care program and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Hanflink is relieved of its his IA obligations, Center for Pain Management Hanflink shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Hanflink plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementHanflink’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ Hanflink signatory represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇/ ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇, M.D. D.O. DATE /▇Counsel for ▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. , D.O. Pietragallo ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 , LLP DATE ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. Hanflink shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by Hanflink in response to a request by OIG, whichever is later, OIG will notify Hanflink if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Hanflink may continue to engage the IRO.‌ 2. If Hanflink engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Hanflink shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by Hanflink at the request of OIG, whichever is later, OIG will notify Hanflink if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Hanflink may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Progenity and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementProgenity’s obligations under this IA CIA based on a certification by Center for Pain Management Progenity that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Progenity is relieved of its IA CIA obligations, Center for Pain Management Progenity shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Progenity plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementProgenity’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Progenity signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies or facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇ ▇▇▇▇▇▇▇/_ July 21, 2020 ▇▇▇▇▇▇ ▇▇▇▇▇▇▇ DATE General Counsel, Progenity /▇▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇/_ 7/21/20 _ ▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ DATE ▇. ▇▇▇▇▇▇▇ Day ▇▇▇▇ DATE ▇▇▇ ▇▇▇, ▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 LLP Counsel for Progenity ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. U.S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇. ▇▇▇, Interventional Cardiology, and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management▇▇. ▇▇▇ and/or Interventional Cardiology’s obligations requirements under this IA based on a certification by Center for Pain Management ▇▇. ▇▇▇ and/or Interventional Cardiology that he/it is is/are no longer providing health care items or services that will be billed to any Federal health care program and he/it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇. ▇▇▇ and/or Interventional Cardiology is relieved of his/its IA obligationsrequirements, Center for Pain Management ▇▇. ▇▇▇ and Interventional Cardiology shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇. ▇▇▇ and/or Interventional Cardiology plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management▇▇. ▇▇▇ and Interventional Cardiology’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements.requirements.‌‌ E. The undersigned ▇▇▇▇. ▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ and Interventional Cardiology signatory represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /ON BEHALF OF ▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇‌‌ /▇/ _4/29/20▇▇▇▇▇ ▇▇▇/_ 8/29/21 ▇▇▇▇▇▇ ▇▇▇, M.D. DATE ▇▇▇▇ ▇. ▇▇▇▇▇▇ Avenue Orlando, FL 32836 /▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & / 8/29/21 _‌ ▇▇▇▇▇▇ ▇▇▇, s.cM.D. DATE o/b/o Interventional Cardiology & Vascular Consultants, PLC ▇▇▇▇ ▇. ▇▇▇▇▇ Avenue Orlando, FL 32836 ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌‌ /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇/_ 9/07/2021 _ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇ Berlin/ _ 9/1/2021_ ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ BERLIN DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ ▇▇▇▇▇ Pharmacy and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management▇▇▇▇▇ Pharmacy’s obligations under this IA based on a certification by Center for Pain Management ▇▇▇▇▇ Pharmacy that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇▇ Pharmacy is relieved of its IA obligations, Center for Pain Management ▇▇▇▇▇ Pharmacy shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇▇▇ Pharmacy plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain Management▇▇▇▇▇ Pharmacy’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements.requirements.‌‌ E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Pharmacy signatories represent and warrants warrant that she is they are authorized to execute this IAthis. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. ON BEHALF OF ▇▇▇▇▇ Pharmacy‌‌ /▇▇▇▇ ▇▇▇▇/ ▇▇▇▇▇▇ ▇▇▇▇▇ PROFESSIONAL‌ PHARMACY, INC. 9-20-18 ‌ DATE /▇▇▇▇ ▇▇▇▇/ ▇▇▇▇ ▇▇▇▇‌ Co-Owner, ▇▇▇▇▇▇ ▇▇▇▇▇ Professional Pharmacy, Inc. 9-20-18 ‌ DATE /▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ‌ Co-Owner, ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇Professional Pharmacy, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 Inc. 9-20-18 ‌ DATE ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. U.S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E 111.D of the IA. A. IRO Engagement‌ 1. ▇▇▇▇▇ Pharmacy shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.4 of the IA or any additional information submitted by ▇▇▇▇▇ Pharmacy in response to a request by OIG, whichever is later, OIG will notify ▇▇▇▇▇ Pharmacy if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇▇▇▇ Pharmacy may continue to engage the IRO.‌ 2. If ▇▇▇▇▇ Pharmacy engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, ▇▇▇▇▇ Pharmacy shall submit the information identified in Section V.A.4 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by ▇▇▇▇▇ Pharmacy at the request of OIG, whichever is later, OIG will notify ▇▇▇▇▇ Pharmacy if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇▇▇▇ Pharmacy may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ TAF and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementTAF’s obligations under this IA based on a certification by Center for Pain Management TAF that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined engaging in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care programPatient Assistance Related Functions. If Center for Pain Management TAF is relieved of its IA obligations, Center for Pain Management TAF shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management TAF plans to resume providing health care items or services that are billed to any Federal health care program Patient Assistance Related Functions or to obtain an ownership or control interest in any entity that bills any Federal health care programengages in Patient Assistance Related Functions. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementTAF’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. This IA does not supersede OIG’s rights as set forth in 42 C.F.R. 1008.45 in connection with conduct other than the Covered Conduct or conduct that occurs on or after the Effective Date of the Settlement Agreement described in the Preamble. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents TAF signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇ ▇▇▇▇▇▇▇▇/ ▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇, President The Assistance Fund, Inc. Date ▇▇▇▇▇ ▇▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center ▇ Counsel for Pain ManagementThe Assistance Fund, S.C. DATE /▇Inc. Date ▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE Re DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. U.S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌‌‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.G of the IA. A. IRO Engagement‌ 1. TAF shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.6 of the IA or any additional information submitted by TAF in response to a request by OIG, whichever is later, OIG will notify TAF if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, TAF may continue to engage the IRO.‌ 2. If TAF engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, TAF shall submit the information identified in Section V.A.6 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by TAF at the request of OIG, whichever is later, OIG will notify TAF if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, TAF may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Diversicare and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementDiversicare’s obligations under this IA CIA based on a certification by Center for Pain Management Diversicare that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Diversicare is relieved of its IA CIA obligations, Center for Pain Management Diversicare shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Diversicare plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementDiversicare’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Diversicare signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /ON BEHALF OF DIVERSICARE /s/ James R. McKnigh▇, ▇▇ 1/31/2020 JAMES R. McKNIGH▇, ▇▇. DATE Chief Executive Officer Diversicare Healthcare Services, Inc. /s/ Jeff H. Gibson 1/31/2020 JEFF H. GIBSON DATE Bass, Berry & Sims PLC ▇▇▇▇▇▇nse▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. r Diversicare ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES /s/ Lisa M. Re 2/5/2020 LISA M. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. U.S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ /s/ Lisa G.Veigel 2/14/2020 LISA G. VEIGEL DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services APPENDIX A This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement 1. Diversicare shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s ▇▇▇▇▇▇▇▇’▇ obligations under this IA based on a certification by Center for Pain Management Klurfeld that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Klurfeld is relieved of its IA obligations, Center for Pain Management Klurfeld shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Klurfeld plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementKlurfeld’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Klurfeld signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇ ▇▇▇▇▇▇▇▇/ 07/27/2020 ▇▇▇▇ ▇▇▇▇▇▇▇▇, on behalf of DATE Williamsburg Physical Therapy, P.C. and Euro Physical Therapy, P.C. /▇▇▇▇▇ ▇▇▇▇▇▇▇▇/_ 4/29/20 07/27/2020_ ▇▇▇▇▇ ▇▇▇▇▇▇▇▇, on behalf of DATE First Plus Service, Inc. /▇▇▇▇ ▇▇▇▇▇▇▇▇/ 07/27/2020 ▇▇▇▇ ▇▇▇▇▇▇▇▇ DATE /▇▇▇▇▇ ▇▇▇▇▇▇▇▇/_ 07/27/2020 ▇▇▇▇▇ ▇▇▇▇▇▇▇▇ DATE /▇▇▇▇▇ ▇▇▇▇▇▇▇/_ 07/28/2020 ▇▇▇▇▇ ▇▇▇▇▇▇▇ DATE ▇▇▇▇▇ ▇▇▇▇▇▇▇▇ FLEXNER LLP Counsel for Klurfeld /▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇/ 07/28/2020 ▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. ▇ DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. FLEXNER LLP Counsel for Klurfeld /▇▇▇▇ ▇. Re/ 05/01/2020 _ 08/13/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇_ 8/13/2020 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ PSI and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementPSI’s obligations under this IA based on a certification by Center for Pain Management PSI that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined engaging in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care programPatient Assistance Related Functions. If Center for Pain Management PSI is relieved of its IA obligations, Center for Pain Management PSI shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management PSI plans to resume providing health care items or services that are billed to any Federal health care program Patient Assistance Related Functions or to obtain an ownership or control interest in any entity that bills any Federal health care programengages in Patient Assistance Related Functions. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementPSI’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirementsrequirements during the IA or thereafter. This IA does not supersede OIG’s rights as set forth in 42 C.F.R. 1008.45 in connection with conduct other than the Covered Conduct or conduct that occurs on or after the Effective Date of the Settlement Agreement described above in the Preamble. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents PSI signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇. ▇▇▇▇▇▇ ▇▇▇▇/ 1/17/2020 ▇/_ 4/29/20 ▇. ▇▇▇▇▇▇ ▇▇▇▇▇▇ Date Chief Executive Officer Patient Services, M.D. DATE Inc. /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇1/17/2020 ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ Date ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ ▇▇▇▇▇▇ ▇▇▇▇▇▇ LLP Counsel for Patient Services, Inc. /▇▇▇▇ ▇. ▇▇/ 01/17/2020 ▇▇▇▇ ▇. Re DATE Associate Counsel Assistant Inspector General for Legal Affairs Office of Inspector General U.S. Department of Health and Human Services /▇▇▇▇ ▇. ▇▇▇▇▇▇▇/ 01/17/2020 ▇▇▇▇ ▇. ▇▇▇▇▇▇▇ DATE Senior Counsel Office of Inspector General APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.G of the IA. A. IRO Engagement‌ 1. PSI shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.6 of the IA or any additional information submitted by PSI in response to a request by OIG, whichever is later, OIG will notify PSI if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, PSI may continue to engage the IRO.‌ 2. If PSI engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, PSI shall submit the information identified in Section V.A.6 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by PSI at the request of OIG, whichever is later, OIG will notify PSI if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, PSI may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇▇▇▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by prior written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s ▇▇▇▇▇▇▇▇▇▇’▇ obligations under this IA based on a certification by Center for Pain Management ▇▇▇▇▇▇▇▇▇▇ that it he is no longer providing health care items or services that will be billed to any Federal health care program programs and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, interest in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇▇▇▇▇▇▇ is relieved of its his IA obligations, Center for Pain Management ▇▇▇▇▇▇▇▇▇▇ shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇▇▇▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, the OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to to, and do not affect: affect (1) Center for Pain Management’s ▇▇▇▇▇▇▇▇▇▇’▇ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇/ 10/20/2014 ▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇, ▇.▇. ▇▇▇▇ /▇▇▇▇▇ ▇▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /10/21/14 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ DATE Counsel for ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Counsel to the Inspector General Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Counsel to the Inspector General Office of Inspector General U.S. U. S. Department of Health and Human Services DATE This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Northwest ENT and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA.IA.‌ B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA.IA.‌ C. OIG may agree to a suspension of Center for Pain Management’s Northwest ENT's obligations under this IA based on a certification by Center for Pain Management Northwest ENT that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health hea,lth care program. If Center for Pain Management Northwest ENT is relieved of its IA obligations, Center for Pain Management Northwest ENT shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Northwest ENT plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified.modified.‌ D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain Management’s Northwest ENT's responsibility to follow all applicable Federal health care program requirements or (2) the government’s 's right to impose appropriate remedies for failure to follow applicable Federal health care program requirements.requirements.‌‌ E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Northwest ENT signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. IA.‌‌‌ Northwest ENTIntegrity Agreement /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇/ ▇▇▇▇▇▇ ▇▇▇▇▇▇, M.D. DATE M.D.‌ /▇▇▇▇▇ ▇▇▇▇▇ ▇▇▇▇▇▇/ 4/29/20 Center for Pain Management▇▇▇▇▇ ▇▇▇▇▇ ▇▇▇▇▇▇, S.C. DATE M.D.‌ /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇, MD/ ▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE , ▇.▇.‌‌ /▇▇▇▇ ▇▇▇▇▇▇▇▇, MD/ ▇▇▇▇ & ▇▇▇▇▇▇▇▇, s.c. M.D.‌‌ 7/18/18 DATE‌ 7/18/18 DATE‌ 7/18/18 DATE 7/18/18 DATE‌ /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇/ ▇▇▇▇ ▇. RE DATE ▇▇.eRE‌‌ Assistant Inspector General for Legal Affairs Office of Inspector General U. S. ▇.▇▇. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. ▇.▇▇. Department of Health and Human Services 6/28/2018 DATE 7/17/2018 DATE This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E 111.E of the IA. A. IRO Engagement 1. Northwest ENT shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.4 of the IA or any additional information submitted by Northwest ENT in response to a request by OIG, whichever is later, OIG will notify Northwest ENT if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Northwest ENT may continue to engage the IRO. 2. If Northwest ENT engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Northwest ENT shall submit the information identified in Section V.A.4 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Northwest ENT at the request of OIG, whichever is later, OIG will notify Northwest ENT if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Northwest ENT may continu� to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌ 1. assign individuals to conduct the Quarterly Claims Review who have expertise in the billing, coding, claims submission and other applicable Medicare and Medicaid program requirements, including those applicable to Medicare Advantage and Medicaid managed care;‌ 2. assign individuals to design and select the Quarterly Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques; 3. assign individuals to conduct the coding review portions of the Quarterly Claims Review who have a nationally recognized coding certification and who have maintained this certification U, completed applicable continuing education requirements);‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management AmeriCare and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementAmeriCare’s obligations under this IA CIA based on a certification by Center for Pain Management AmeriCare that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management AmeriCare is relieved of its IA CIA obligations, Center for Pain Management AmeriCare shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management AmeriCare plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementAmeriCare’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents AmeriCare signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇ ▇▇▇▇/ ▇▇▇▇▇▇ ▇▇▇▇▇▇ /_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center AmeriCare Ambulance Service, Inc. and AmeriCare ALS, Inc. /▇▇▇▇▇▇▇ ▇. ▇▇▇▇/ on ▇▇▇▇, LLC, AmeriCare Ambulance Service, Inc., and AmeriCare ALS, Inc. DATE‌ /▇▇▇▇ ▇. ▇▇/ Assistant Inspector General for Pain Management, S.C. DATE Legal Affairs Office of Inspector General U.S. Department of Health and Human Services /▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Berlin/ Senior Counsel Office of Inspector General U.S. Department of Health and Human Services 1 /23/2018 DATE This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. AmeriCare shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.7 of the CIA or any additional information submitted by AmeriCare in response to a request by OIG, whichever is later, OIG will notify AmeriCare if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, AmeriCare may continue to engage the IRO.‌ 2. If AmeriCare engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, AmeriCare shall submit the information identified in Section V.A.7 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by AmeriCare at the request of OIG, whichever is later, OIG will notify AmeriCare if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, AmeriCare may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Guardian and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementGuardian’s obligations under this IA CIA based on a certification by Center for Pain Management Guardian that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Guardian is relieved of its IA CIA obligations, Center for Pain Management Guardian shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Guardian plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementGuardian’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Guardian signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇. Herald/ 12/9/2019 /_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇12/9/2019 /▇▇▇▇ ▇. ▇▇▇▇▇▇▇/ 12/9/2019 /▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services ▇. Re/ 01/22/2020 /▇▇▇▇▇▇ ▇▇▇▇ ▇▇▇▇▇/ January 13, 2020 This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. Guardian shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.7 of the CIA or any additional information submitted by Guardian in response to a request by OIG, whichever is later, OIG will notify Guardian if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Guardian may continue to engage the IRO.‌ 2. If Guardian engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Guardian shall submit the information identified in Section V.A.7 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Guardian at the request of OIG, whichever is later, OIG will notify Guardian if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Guardian may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review who have expertise in the Medicare and state Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professionals acting within their scope‌ of practice and specialized expertise) to make the medical necessity determinations required by the Claims Review; and 5. have sufficient staff and resources to conduct the reviews required by the CIA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌ 1. perform each Claims Review in accordance with the specific requirements of the CIA;‌ 2. follow all applicable Medicare and state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare or state Medicaid program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the CIA. D. Guardian Responsibilities‌ Guardian shall ensure that the IRO has access to all records and personnel necessary to complete the reviews listed in III.D of this CIA and that all records furnished to the IRO are accurate and complete.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ ▇▇. ▇▇▇▇▇▇▇▇▇▇-AFAS and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management▇▇. ▇▇▇▇▇▇▇▇▇▇-AFAS’s obligations under this IA based on a certification by Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇▇▇-AFAS that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇▇▇-AFAS is relieved of its IA obligations, Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇▇▇-AFAS shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇▇▇-AFAS plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management▇▇. ▇▇▇▇▇▇▇▇▇▇-AFAS’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ ▇▇-AFAS signatory represents and warrants that she is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇/ ▇-▇-▇▇ ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇, M.D. D.P.M. DATE /▇▇▇▇▇ ▇▇▇▇▇/ 3/5/18 ▇▇▇▇▇ ▇. BUENOCounsel for ▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.D.P.M. DATE

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ ▇▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s ▇▇▇▇▇▇’▇ obligations under this IA based on a certification by Center for Pain Management ▇▇▇▇▇▇ that it she is no longer providing health care items or services that will be billed to any Federal health care program and it she does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇▇▇ is relieved of its her IA obligations, Center for Pain Management ▇▇▇▇▇▇ shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s ▇▇▇▇▇▇’▇ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇/ ▇▇▇▇▇▇ ▇▇▇▇▇▇, M.D. RPH DATE /▇▇▇▇▇ ▇▇▇▇▇▇ – Attorneys at Law Counsel for ▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. RPH DATE /▇▇▇▇ ▇. Re/ 05/01/2020 7/31/2019 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇7/31/2019 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. ▇▇▇▇▇▇ shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by ▇▇▇▇▇▇ in response to a request by OIG, whichever is later, OIG will notify ▇▇▇▇▇▇ if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇▇▇▇▇ may continue to engage the IRO.‌ 2. If ▇▇▇▇▇▇ engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, ▇▇▇▇▇▇ shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by ▇▇▇▇▇▇ at the request of OIG, whichever is later, OIG will notify ▇▇▇▇▇▇ if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇▇▇▇▇ may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management The Providers and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by prior written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s the Providers’ obligations under this IA based on a certification by Center for Pain Management any of the Providers that it is they are no longer providing health care items or services that will be billed to any Federal health care program programs and it does they do not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, interest in any entity that bills any Federal health care program. If Center for Pain Management is any of the Providers are relieved of its their IA obligations, Center for Pain Management the Provider shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management the Provider plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, the OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to to, and do not affect: affect (1) Center for Pain Management’s the Providers’ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ Provider signatories represents and warrants that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇ ▇▇ . ▇▇▇▇, M.D./ 4/9/14 ▇▇▇▇▇/_ 4/29/20 ▇ ▇. ▇▇▇▇, M.D. Date [Address] /▇▇▇▇▇▇▇▇ Yarra, M.D./ 4/9/14 ▇▇▇▇▇▇▇▇ Yarra, M.D. Date [Address] ▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇, Esq. Date /▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ 4/22/14 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Counsel to the Inspector General Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 4/11/2014 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Counsel to the Inspector General Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ ▇▇. ▇▇▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementDr. Muttath’s obligations under this IA based on a certification by Center for Pain Management ▇▇. ▇▇▇▇▇▇▇ that it he is no longer providing health care items or services that will be billed to any Federal health care program and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇. ▇▇▇▇▇▇▇ is relieved of its his IA obligations, Center for Pain Management ▇▇. ▇▇▇▇▇▇▇ shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇. ▇▇▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementDr. Muttath’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇/ ▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇, M.D. DATE Counsel for ▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services DATE APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ ▇▇. ▇▇▇▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s ▇▇. ▇▇▇▇▇▇▇▇’▇ obligations under this IA based on a certification by Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇ that it he is no longer providing health care items or services that will be billed to any Federal health care program and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇ is relieved of its his IA obligations, Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇ shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s ▇▇. ▇▇▇▇▇▇▇▇’▇ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements.requirements.‌‌ E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ signatory represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ FHG and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementFHG’s obligations under this IA based on a certification by Center for Pain Management FHG that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management FHG is relieved of its IA obligations, Center for Pain Management FHG shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management FHG plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementFHG’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents FHG signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. ON BEHALF OF FHG‌ /▇▇▇▇▇ ▇▇▇▇/ 5/4/17 ▇▇. ▇▇▇▇▇ ▇▇▇▇ DATE Medical Director Fredericksburg Hospitalist Group, P.C. /▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇/ 5/4/17 ▇▇▇▇▇▇ ▇. ▇. ▇▇▇▇▇▇, Esq. DATE ▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇ PLLC ▇▇▇▇ ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇ Suite 430 Arlington, VA 22209 Counsel for FHG ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌ /▇▇▇▇ ▇. ▇▇/ 4/29/20 Center ▇▇▇▇ ▇. ▇▇ Assistant Inspector General for Pain Management, S.C. Legal Affairs Office of Inspector General U.S. Department of Health and Human Services 5/11/17 DATE /▇▇▇▇ ▇. ▇▇▇▇▇▇/ ▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Senior Counsel Office of Inspector General U. S. U.S. Department of Health and Human Services 6/1/17 DATE /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services DATE This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Good Days and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s Good Days’ obligations under this IA based on a certification by Center for Pain Management Good Days that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined engaging in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care programPatient Assistance Related Functions. If Center for Pain Management Good Days is relieved of its IA obligations, Center for Pain Management Good Days shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Good Days plans to resume providing health care items or services that are billed to any Federal health care program Patient Assistance Related Functions or to obtain an ownership or control interest in any entity that bills any Federal health care programengages in Patient Assistance Related Functions. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain Management’s Good Days’ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. This IA does not supersede OIG’s rights as set forth in 42 C.F.R. 1008.45 in connection with conduct other than the Covered Conduct or conduct that occurs on or after the Effective Date of the Settlement Agreement described in the Preamble. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Good Days signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇▇ ▇▇▇▇▇/▇/ _ 4/29/20 10/24/19 ‌‌ ▇▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE ▇ Date President and Chief Executive Officer Good Days /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇/ 10/24/19 ▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. Date ▇▇▇▇▇▇ DATE Associate ▇▇▇▇▇▇▇, Esq. Miles & Stockbridge Counsel for Good Days /▇▇▇▇▇▇ ▇▇▇▇▇▇/ 10/24/19 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. Date ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇, LLP Counsel for Good Days /▇▇▇▇ ▇. ▇▇/ ▇▇▇▇ ▇. ▇▇ Assistant Inspector General for Legal Affairs Office of Inspector General U.S. Department of Health and Human Services DATE Senior Counsel DATE APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.G of the IA. A. IRO Engagement‌ 1. Good Days shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.6 of the IA or any additional information submitted by Good Days in response to a request by OIG, whichever is later, OIG will notify Good Days if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Good Days may continue to engage the IRO.‌ 2. If Good Days engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Good Days shall submit the information identified in Section V.A.6 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Good Days at the request of OIG, whichever is later, OIG will notify Good Days if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Good Days may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the IRO Reviews who have expertise in all applicable Federal health care program requirements relating to Patient Assistance Related Functions, including but not limited to the Federal Anti-Kickback Statute and False Claims Act.‌ 2. assign or retain individuals to conduct the IRO Reviews who are knowledgeable in the requirements of the Federal Anti-Kickback Statute and the regulations and other guidance documents relating to the statute, Advisory Opinion 06- 10, and guidance documents from the OIG relating to patient assistance programs (including those referenced in Section III.C of the IA), including individuals with the expertise and qualifications necessary to perform the legal analysis required by Section‌‌‌ IV.B.2.d of Appendix B and to serve as Legal Reviewer(s) (as defined in Section III.G.3 of the IA); and 3. have sufficient staff and resources to conduct the reviews required by the IA on a timely basis.‌‌‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each component of the IRO Reviews in accordance with the specific requirements of the IA;‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management HOTC and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementHOTC’s obligations under this IA CIA based on a certification by Center for Pain Management HOTC that it is no longer providing health care items or services that will be billed to any Federal health care program and that it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management HOTC is relieved of its IA CIA obligations, Center for Pain Management shall HOTC will be required to notify OIG in writing at least 30 days in advance if Center for Pain Management HOTC plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents and warrants that she is authorized to execute this IA. The undersigned OIG HOTC signatories represent that they are signing this IA in their official capacity and warrant that they are authorized to execute this IACIA. The undersigned OIG signatory represents that he is signing this CIA in his official capacity and that he is authorized to execute this CIA. F. E. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 . ▇▇▇▇▇▇▇ / 9-3-2013 ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ DATE PRESIDENT /▇▇ ▇▇▇▇▇▇▇▇/ _4/29/20_ 9-3-2013 ▇▇ ▇▇▇▇▇▇▇▇ DATE CHAIRMAN OF THE BOARD /▇▇▇▇▇▇ “LT” ▇▇▇▇▇▇▇▇, Esq./ 9-3-13 ▇▇▇▇▇▇ “LT” ▇▇▇▇▇▇▇▇, ESQ. DATE COUNSEL FOR HOTC /▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇/ 10/24/13 ▇▇▇▇▇▇ DATE ▇▇▇ . ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General I.G. for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇9/10/13 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management SERA and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementSERA’s obligations under this IA CIA based on a certification by Center for Pain Management SERA that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management SERA is relieved of its IA CIA obligations, Center for Pain Management SERA shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management SERA plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementSERA’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents SERA signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by prior written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementKrentel’s obligations under this IA based on a certification by Center for Pain Management ▇▇▇▇▇▇▇ that it he is no longer providing health care items or services that will be billed to any Federal health care program programs and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, interest in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇▇▇▇ is relieved of its his IA obligations, Center for Pain Management ▇▇▇▇▇▇▇ shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, the OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to to, and do not affect: affect (1) Center for Pain ManagementKrentel’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ signatory represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 . ▇▇▇▇▇▇▇, M.D./ 9/12/13 ▇▇▇ ▇. ▇▇▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE Date /▇▇▇▇▇ ▇. ▇▇▇▇▇ & ▇▇▇▇ ▇▇▇▇▇▇▇▇/ _4/29/20_ 9/12/13 Counsel for ▇▇▇▇▇▇▇ Date GrayRobinson, P.A. ▇▇▇▇▇ ▇. ▇▇▇▇▇ & ▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇9/12/13 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Assistant Inspector General for Legal Affairs Office of Counsel to the Inspector General Office of Inspector General U.S. U. S. Department of Health and Human Services DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇▇▇/ 9-11-13 ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇▇▇ Associate Counsel Office of Counsel to the Inspector General Office of Inspector General U. S. Department of Health and Human Services DATE This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement 1. ▇▇▇▇▇▇▇ shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.3 of the IA or any additional information submitted by ▇▇▇▇▇▇▇ in response to a request by OIG, whichever is later, OIG will notify ▇▇▇▇▇▇▇ if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇▇▇▇▇▇ may continue to engage the IRO. 2. If ▇▇▇▇▇▇▇ engages a new IRO during the term of the IA, this IRO shall also meet the requirements of this Appendix. If a new IRO is engaged, ▇▇▇▇▇▇▇ shall submit the information identified in Section V.A.3 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by ▇▇▇▇▇▇▇ at the request of OIG, whichever is later, OIG will notify ▇▇▇▇▇▇▇ if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇▇▇▇▇▇ may continue to engage the IRO.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇▇▇▇ and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementBanner’s obligations under this IA CIA based on a certification by Center for Pain Management Banner that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Banner is relieved of its IA CIA obligations, Center for Pain Management Banner shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Banner plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementBanner’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Banner signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. 3/29/18 ‌ 3/29/18 ‌ 4/3/18 ‌ /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services 4/09/18 /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services 3-30-18 APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. Banner shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.8 of the CIA or any additional information submitted by Banner in response to a request by OIG, whichever is later, OIG will notify Banner if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Banner may continue to engage the IRO.‌ 2. If Banner engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, ▇▇▇▇▇▇ shall submit the information identified in Section V.A.8 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Banner at the request of OIG, whichever is later, OIG will notify Banner if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Banner may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review and Inpatient Medical Necessity and Appropriateness Review who have expertise in the Medicare program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Claims Review and Inpatient Medical Necessity and Appropriateness Review samples who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review and Inpatient Medical Necessity and Appropriateness Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professionals acting within their scope of practice and specialized expertise) to make the medical necessity determinations required by the Claims Review and the Inpatient Medical Necessity and Appropriateness Review; and‌ 5. have sufficient staff and resources to conduct the reviews required by the CIA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Claims Review and Inpatient Medical Necessity and Appropriateness Review in accordance with the specific requirements of the CIA;‌ 2. follow all applicable Medicare program rules and reimbursement guidelines in making assessments in the Claims Review and Inpatient Medical Necessity and Appropriateness Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B and Appendix C to the CIA. D. IRO Independence and Objectivity‌ The IRO must perform the Claims Review and Inpatient Medical Necessity and Appropriateness Review in a professionally independent and objective fashion, as defined in the most recent Government Auditing Standards issued by the U.S. Government Accountability Office.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ THM and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementTHM’s obligations under this IA CIA based on a certification by Center for Pain Management THM that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management THM is relieved of its IA CIA obligations, Center for Pain Management THM shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management THM plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementTHM’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents THM signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. 1/21/19 /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services 1/22/2019 APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. THM shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.9 of the CIA or any additional information submitted by THM in response to a request by OIG, whichever is later, OIG will notify THM if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, THM may continue to engage the IRO.‌ 2. If THM engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, THM shall submit the information identified in Section V.A.9 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by THM at the request of OIG, whichever is later, OIG will notify THM if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, THM may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review who have expertise in the state Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professionals acting within their scope‌ of practice and specialized expertise) to make the medical necessity determinations required by the Claims Review; and‌ 5. have sufficient staff and resources to conduct the reviews required by the CIA on a timely basis. C. IRO Responsibilities The IRO shall:‌ 1. perform each Claims Review in accordance with the specific requirements of the CIA;‌ 2. follow all applicable state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., state payor), if in doubt of the application of a particular state Medicaid program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the CIA. D. THM Responsibilities‌ THM shall ensure that the IRO has access to all records and personnel necessary to complete the reviews listed in III.D of this CIA and that all records furnished to the IRO are accurate and complete.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ VirtuOx and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementVirtuOx’s obligations requirements under this IA CIA based on a certification by Center for Pain Management VirtuOx that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management VirtuOx is relieved of its IA obligationsCIA requirements, Center for Pain Management VirtuOx shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management VirtuOx plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementVirtuOx’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents VirtuOx signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇May 6, M.D. 2022 DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ /_ May 6, 2022 DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. VirtuOx, Inc. (VirtuOx) shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.7 of the CIA or any additional information submitted by VirtuOx in response to a request by OIG, whichever is later, OIG will notify VirtuOx if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, VirtuOx may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Dia-Foot and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementDia-Foot’s obligations requirements under this IA based on a certification by Center for Pain Management Dia-Foot that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Dia-Foot is relieved of its IA obligationsrequirements, Center for Pain Management Dia-Foot shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Dia-Foot plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementDia-Foot’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Dia-Foot signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇ON BEHALF OF ▇▇▇▇▇▇ ▇▇▇▇▇▇, DPM AND FOOT CARE STORE, INC.‌ /_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇/ ▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center ▇, DPM DATE President, Foot Care Store, Inc. d/b/a Dia-Foot DATE Counsel for Pain Management, S.C. DATE /Dia-Foot Brown & ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. DATE /▇▇▇▇ ▇. Re/ 05/01/2020 12/29/21 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇/_ 12-30-21 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Administrative and Civil Remedies Branch Office of Counsel to the Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Trans-Star and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by prior written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementTrans-Star’s obligations under this IA CIA based on a certification by Center for Pain Management Trans-Star that it is no longer providing health care items or services that will be billed to any Federal health care program programs and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Trans-Star is relieved of its IA CIA obligations, Center for Pain Management Trans- Star shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Trans-Star plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, the OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to to, and do not affect: affect (1) Center for Pain ManagementTrans-Star’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Trans-Star signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇ ▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇/ 11-20-2014 ▇▇▇▇ ▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇ DATE President /▇▇▇▇▇ ▇▇▇▇▇▇▇/ 4/29/20 Center 11/20/2014 ▇▇▇▇▇ ▇▇▇▇▇▇▇ DATE HURT, ▇▇▇▇▇▇▇ & MAY, PLLC Counsel for Pain Management, S.C. DATE Trans-Star /▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ 1/8/15 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Counsel to the Inspector General Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇ ▇. ▇▇▇▇▇▇/ 1/14/15 ▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Counsel to the Inspector General Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Oglethorpe and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementOglethorpe’s obligations under this IA CIA based on a certification by Center for Pain Management Oglethorpe that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Oglethorpe is relieved of its IA CIA obligations, Center for Pain Management Oglethorpe shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Oglethorpe plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementOglethorpe’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Oglethorpe signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE 1/26/21 /A. ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇III/ ▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services 1/26/2021 This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. Oglethorpe shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.7 of the CIA or any additional information submitted by Oglethorpe in response to a request by OIG, whichever is later, OIG will notify Oglethorpe if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Oglethorpe may continue to engage the IRO.‌ 2. If Oglethorpe engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Oglethorpe shall submit the information identified in Section V.A.7 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Oglethorpe at the request of OIG, whichever is later, OIG will notify Oglethorpe if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Oglethorpe may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review who have expertise in the Medicare and state Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review who have a nationally recognized coding certification and who have maintained‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professionals acting within their scope of practice and specialized expertise) to make the medical necessity determinations required by the Claims Review; and‌ 5. have sufficient staff and resources to conduct the reviews required by the CIA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌ 1. perform each Claims Review in accordance with the specific requirements of the CIA;‌ 2. follow all applicable Medicare and state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare or state Medicaid program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the CIA. ▇. ▇▇▇▇▇▇▇▇▇▇ Responsibilities‌ Oglethorpe shall ensure that the IRO has access to all records and personnel necessary to complete the reviews listed in III.D of this CIA and that all records furnished to the IRO are accurate and complete.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ ▇▇▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s obligations under this IA based on a certification by Center for Pain Management that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management is relieved of its IA obligations, Center for Pain Management shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. B. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementBalotin’s and any Owned or Controlled Entity’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. C. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ signatory represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. D. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇ON BEHALF OF ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ ‌ 6/9/23 June 14, 2023 DATE Associate Counsel Office U. S. Department of Inspector General U.S. Health and Human Services U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. ▇▇▇▇▇▇▇ shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by ▇▇▇▇▇▇▇ in response to a request by OIG, whichever is later, OIG will notify Balotin if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Balotin may continue to engage the IRO.‌ 2. If ▇▇▇▇▇▇▇ engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, ▇▇▇▇▇▇▇ shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by ▇▇▇▇▇▇▇ at the request of OIG, whichever is later, OIG will notify Balotin if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Balotin may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review who have expertise in the Federal health care program requirements and State Board of Pharmacy requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professional acting within their scope of practice and specialized expertise) to review and ensure that all ingredients in each prescription for a compounded medication or cream were authorized by the prescriber and for each‌ 5. have sufficient staff and resources to conduct the reviews required by the IA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Claims Review in accordance with the specific requirements of the‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ ▇▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s ▇▇▇▇▇▇’▇ obligations under this IA based on a certification by Center for Pain Management ▇▇▇▇▇▇ that it is they are no longer providing health care items or services that will be billed to any Federal health care program and it does they do not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇▇▇ is relieved of its their IA obligations, Center for Pain Management ▇▇▇▇▇▇ shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s ▇▇▇▇▇▇’▇ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements.requirements.‌‌ E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. ON BEHALF OF SERBIN‌‌ /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇/ 10/10/18 ‌‌ ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /10/10/18 ‌‌ ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌‌ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. ▇▇▇▇▇▇ shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by ▇▇▇▇▇▇ in response to a request by OIG, whichever is later, OIG will notify ▇▇▇▇▇▇ if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇▇▇▇▇ may continue to engage the IRO.‌ 2. If ▇▇▇▇▇▇ engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, ▇▇▇▇▇▇ shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by at the request of OIG, whichever is later, OIG will notify ▇▇▇▇▇▇ if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇▇▇▇▇ may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Arora and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s obligations under this IA based on a certification by Center for Pain Management that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management is relieved of its IA obligations, Center for Pain Management shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. B. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementArora’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. C. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ signatory represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. D. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇ON BEHALF OF ▇▇▇▇ ▇▇▇▇▇, M.D. DATE MD‌‌‌ /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇9/11/23 ‌‌ ▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. , MD DATE /▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇/ 9/11/23 ‌‌ ▇▇▇▇▇▇ & ▇. DEL GIORNO DATE Garfunkel Wild, P.C. Counsel for ▇▇▇▇ ▇▇▇▇▇, s.c. MD /▇▇▇▇ ▇. Re/ 05/01/2020 2023.09.20 ‌ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. General‌ U.S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇2023.09.20 ‌ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General General‌ U.S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. Arora shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by Arora in response to a request by OIG, whichever is later, OIG will notify Arora if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Arora may continue to engage the IRO.‌ 2. If ▇▇▇▇▇ engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, ▇▇▇▇▇ shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by ▇▇▇▇▇ at the request of OIG, whichever is later, OIG will notify Arora if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Arora may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ EPIPG and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementEPIPG’s obligations under this IA based on a certification by Center for Pain Management EPIPG that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management EPIPG is relieved of its IA obligations, Center for Pain Management EPIPG shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management EPIPG plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementEPIPG’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements.requirements.‌‌ E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents EPIPG signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. ON BEHALF OF EL PASO INTEGRATED PHYSICIANS GROUP, P.A.‌‌ /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇/ Dr. ▇▇▇▇▇▇ ▇▇▇▇▇▇ (on behalf of himself) DATE President, M.D. El Paso Integrated Physicians Group, P.A. DATE /and Accutrack Medical Claims Service, LLC Manager, Accutrack Medical Claims Service, LLC DATE and Accutrack Medical Claims Service, LLC Manager, Accutrack Medical Claims Service, LLC DATE ▇▇▇▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. ▇▇▇ & ▇▇▇ LLP DATE /▇ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌‌ ▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE Re DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA. A. IRO Engagement‌ 1. EPIPG shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.4 of the IA or any additional information submitted by EPIPG in response to a request by OIG, whichever is later, OIG will notify EPIPG if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, EPIPG may continue to engage the IRO.‌ 2. If EPIPG engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, EPIPG shall submit the information identified in Section V.A.4 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by EPIPG at the request of OIG, whichever is later, OIG will notify EPIPG if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, EPIPG may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Golden and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementGolden’s obligations under this IA based on a certification by Center for Pain Management Golden that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Golden is relieved of its IA obligations, Center for Pain Management Golden shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Golden plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementGolden’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Golden signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇ ▇▇▇▇▇/ 12/21/2020_ ▇▇▇▇▇ ▇▇▇▇▇ DATE Individually /▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇/_ 12/21/2020 _ ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ DATE Counsel for ▇▇▇▇▇ ▇▇▇▇▇ /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 , MD/ 12/24/20 ‌‌ ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇/_ 12/24/20_ ‌‌ ▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇▇ DATE Counsel for Integrated Labs, LLC /▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. 12/21/2020 ‌‌ ▇▇▇▇▇ ▇▇▇▇▇ DATE /▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇/_ 12/21/2020 ‌‌ ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇Counsel for Golden Management Team, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 LLC ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇/_ 12/28/20 _ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Deputy Branch Chief Administrative and Civil Remedies Branch Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA. A. IRO Engagement‌ 1. Golden shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.5 of the IA or any additional information submitted by Golden in response to a request by OIG, whichever is later, OIG will notify Golden if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Golden may continue to engage the IRO.‌ 2. If Golden engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Golden shall submit the information identified in Section V.A.5 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Golden at the request of OIG, whichever is later, OIG will notify Golden if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Golden may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management OC, ▇▇▇▇▇▇, and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s OC or ▇▇▇▇▇▇’▇ obligations under this IA based on a certification by Center for Pain Management OC and ▇▇▇▇▇▇ that it it/he is no longer providing health care items or services that will be billed to any Federal health care program and it it/he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management is OC or ▇▇▇▇▇▇ are relieved of its their IA obligations, Center for Pain Management OC or ▇▇▇▇▇▇ (as applicable) shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management OC or ▇▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s OC and ▇▇▇▇▇▇’▇ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇OC and ▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. _/▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, MD/ _ 4/29/2020 DR. ▇▇▇▇▇▇ ▇▇▇▇▇▇ DATE Individually, and on behalf of Ophthalmic Consultants, P.A. /▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇/ May 5, 2020 ▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇ DATE Counsel for Ophthalmic Consultants, P.A. and Dr. ▇▇▇▇▇▇ ▇▇▇▇▇▇ ▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇, P.A. ▇▇▇▇ ▇. ▇▇▇ ▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇ ▇▇▇▇▇, ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇-▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20/_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 04/30/2020_ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇ Berlin/ 6/29/2020_ ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ BERLIN DATE Associate Senior Counsel Administrative and Civil Remedies Branch Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management AAMC and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementAAMC’s obligations under this IA CIA based on a certification by Center for Pain Management AAMC that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management AAMC is relieved of its IA CIA obligations, Center for Pain Management AAMC shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management AAMC plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementAAMC’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents AAMC signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. 6-17-2019 6/18/2019 6/18/2019 /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services 06/24/2019 /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services 26 June 19 APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. AAMC shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.7 of the CIA or any additional information submitted by AAMC in response to a request by OIG, whichever is later, OIG will notify AAMC if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, AAMC may continue to engage the IRO.‌ 2. If AAMC engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, AAMC shall submit the information identified in Section V.A.7 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by AAMC at the request of OIG, whichever is later, OIG will notify AAMC if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, AAMC may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review who have expertise in the Medicare, state Medicaid, and TRICARE program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professionals acting within their scope‌ of practice and specialized expertise) to make the medical necessity determinations required by the Claims Review; and‌ 5. have sufficient staff and resources to conduct the reviews required by the CIA on a timely basis. C. IRO Responsibilities The IRO shall:‌ 1. perform each Claims Review in accordance with the specific requirements of the CIA;‌ 2. follow all applicable Medicare, state Medicaid, and TRICARE program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare, state Medicaid, or TRICARE program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the CIA. D. AAMC Responsibilities‌ AAMC shall ensure that the IRO has access to all records and personnel necessary to complete the reviews listed in III.D of this CIA and that all records furnished to the IRO are accurate and complete.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management PFH and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementPFH’s obligations under this IA CIA based on a certification by Center for Pain Management PFH that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management PFH is relieved of its IA CIA obligations, Center for Pain Management PFH shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management PFH plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementPFH’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents PFH signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ DATE President and CEO Preferred Family Healthcare, Inc. /▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /_ 10/6/20 ▇▇▇▇▇ ▇. ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. ▇ PC Counsel for PFH /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇/ _ 10/13/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. U.S. Department of Health and Human Services /▇▇▇▇▇ ▇▇▇▇▇▇▇▇/ 10/19/2020_ _ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ PC, ▇▇▇▇▇, and Bandar and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementPC, ▇▇▇▇▇, and Bandar’s obligations requirements under this IA based on a certification by Center for Pain Management PC, ▇▇▇▇▇, and Bandar that it is it/he are no longer providing health care items or services that will be billed to any Federal health care program and it it/he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management is PC, ▇▇▇▇▇, and/or Bandar is/are relieved of its its/his IA obligationsrequirements, Center for Pain Management PC, ▇▇▇▇▇, and/or Bandar shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management plans PC, ▇▇▇▇▇, and Bandar plan to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified.modified.‌ D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementPC, ▇▇▇▇▇, and Bandar’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements.requirements.‌ E. The undersigned PC, ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ , and Bandar signatory represents and warrants that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA.IA.‌ F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. IA.‌ ON BEHALF OF ▇▇▇▇▇ ▇▇▇▇▇, PC‌‌ /▇▇▇▇▇ ▇▇▇▇▇/ DR. HEALTH ▇▇▇▇▇ O/B/O ▇▇▇▇▇ ▇▇▇▇▇, PC __12/22/2021 _ DATE Counsel for ▇▇▇▇▇ ▇▇▇▇▇, PC DATE ON BEHALF OF ▇▇. ▇▇▇▇▇ ▇▇▇▇▇‌‌ /▇▇▇▇▇ ▇▇▇▇▇/__ 4/29/20 ▇▇12/22/2021 ‌‌ DR. HEALTH ▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20/_ ▇12/22/21 ‌‌ ▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇ DATE Counsel for ▇▇. ▇▇▇▇▇ ▇▇▇▇▇ DATE ON BEHALF OF BANDAR ENTERPRISES, LLC‌‌ /▇▇▇▇▇ ▇▇▇▇▇▇▇ & /__ DR. HEALTH ▇▇▇▇▇▇ O/B/O Bandar Enterprises, s.c. LLC (including Assurity Labs and Cuur Diagnostics) _12/22/2021 DATE Counsel for Bandar Enterprises, LLC (including Assurity Labs and Cuur Diagnostics) DATE ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌‌ /▇▇▇▇ ▇. Re/ 05/01/2020 12/28/2021 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇ Berlin/ 12/26/2021 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ BERLIN DATE Associate Senior Counsel Administrative and Civil Remedies Branch Office of Counsel to the Inspector General Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management CareMed and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementCareMed’s obligations under this IA CIA based on a certification by Center for Pain Management CareMed that it is no longer providing health care items or services that will be billed to any Federal health care program and that it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management CareMed is relieved of its IA CIA obligations, Center for Pain Management shall CareMed will be required to notify OIG in writing at least 30 days in advance if Center for Pain Management CareMed plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents CareMed signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. E. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. Corporate Integrity Agreement between the Office of Inspector General and Sorkin’s Rx Ltd. d/b/a CareMed Pharmaceutical Services /Nuaman Tyyeb/ 11/24/2014 NUAMAN TYYEB DATE President, Sorkin’s RX Ltd. As the Executor of the Estate of Muhammad Tyyeb /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ 11/24/14 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇ DATE Counsel for CareMed Corporate Integrity Agreement between the Office of Inspector General and Sorkin’s Rx Ltd. d/b/a CareMed Pharmaceutical Services /▇▇▇▇▇▇ DATE ▇. ▇▇▇▇▇▇▇/ 11/21/14 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇12/1/2014 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services Corporate Integrity Agreement between the Office of Inspector General and Sorkin’s Rx Ltd. d/b/a CareMed Pharmaceutical Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇▇▇ and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain Management’s VITAS' obligations under this IA CIA based on a certification by Center for Pain Management VITAS that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management VITAS is relieved of its IA CIA obligations, Center for Pain Management VITAS shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management VITAS plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain Management’s VITAS' responsibility to follow all applicable Federal health care program requirements or (2) the government’s 's right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents VITAS signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.Vitas Corporate Integrity Agreement

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Practitioner and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA.IA.‌‌ C. OIG may agree to a suspension of Center for Pain ManagementPractitioner’s obligations requirements under this IA based on a certification by Center for Pain Management Practitioner that it Practitioner is no longer providing health care items or services that will be billed to any Federal health care program and it Practitioner does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Practitioner is relieved of its Practitioner’s IA obligationsrequirements, Center for Pain Management Practitioner shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Practitioner plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementPractitioner’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ Practitioner signatory represents and warrants that she is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. _/▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇/ 7-23-21 ‌‌ ▇▇▇▇ ▇▇▇▇▇, M.D. ▇▇▇▇ DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇/ _ _ 7/23/21 _ ▇▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & DATE‌‌ ▇▇▇▇▇▇ ▇▇▇▇▇▇▇, s.c. LLP Counsel for ▇▇▇▇ ▇▇▇▇▇▇▇▇▇ _/▇▇▇▇ ▇▇▇▇▇▇▇▇▇/ ▇▇▇▇ ▇▇▇▇▇▇▇▇▇ Owner _/▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇/ ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇ ▇▇▇▇▇▇ ▇▇▇▇▇▇▇, LLP Counsel for L.A. Vision LLC DATE ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌‌ _/▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇/ 8/06/2021 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services _/▇▇▇▇▇▇▇▇ ▇. ▇’▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇/_ _ 08/03/2021 _ ▇▇▇▇ ▇. ▇▇▇▇’▇▇▇▇▇ DATE Associate ▇▇▇▇ Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. Practitioner shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by Practitioner in response to a request by OIG, whichever is later, OIG will notify Practitioner if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Practitioner may continue to engage the IRO.‌ 2. If Practitioner engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Practitioner shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by Practitioner at the request of OIG, whichever is later, OIG will notify Practitioner if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Practitioner may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Agendia and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementAgendia’s obligations under this IA CIA based on a certification by Center for Pain Management Agendia that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Agendia is relieved of its IA CIA obligations, Center for Pain Management Agendia shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Agendia plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementAgendia’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Agendia signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services 01/11/2021 APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. Agendia shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.7 of the CIA or any additional information submitted by Agendia in response to a request by OIG, whichever is later, OIG will notify Agendia if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Agendia may continue to engage the IRO.‌ 2. If Agendia engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Agendia shall submit the information identified in Section V.A.7 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Agendia at the request of OIG, whichever is later, OIG will notify Agendia if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Agendia may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review who have expertise in the Medicare and state Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professionals acting within their scope‌ of practice and specialized expertise) to make the medical necessity determinations required by the Claims Review; and 5. have sufficient staff and resources to conduct the reviews required by the CIA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌ 1. perform each Claims Review in accordance with the specific requirements of the CIA;‌ 2. follow all applicable Medicare and state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare or state Medicaid program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the CIA. D. Agendia Responsibilities‌ Agendia shall ensure that the IRO has access to all records and personnel necessary to complete the reviews listed in III.D of this CIA and that all records furnished to the IRO are accurate and complete.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ The Covered Entities and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s obligations any of the Covered Entities’ requirements under this IA based on a certification by Center for Pain Management the Covered Entities that it is they are no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management is any of the Covered Entities are relieved of its their IA obligationsrequirements, Center for Pain Management such Covered Entities shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management plans such Covered Entities plan to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified.modified.‌ D. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain Management’s the Covered Entities’ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements.requirements.‌ E. The Covered Entities’ undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA.IA.‌ F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. IA.‌ /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇/ ▇▇▇▇ ▇▇▇▇▇▇, M.D. DATE /▇▇▇Counsel for ▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. M.D. and the Covered Entities DATE /▇▇▇▇ ▇. Re/ 05/01/2020 Re/_ 12/3/2021 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇/ _ 12/3/2021 ▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management DOCS and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management’s obligations under this IA based on a certification by Center for Pain Management that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management is relieved of its IA obligations, Center for Pain Management shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. B. All requirements and remedies set forth in this IA are in addition to and do not affect: affect (1) Center for Pain ManagementDOCS’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. C. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents DOCS signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. D. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General ON BEHALF OF DOCS‌ U.S. Department of Health and Human Services Services‌ U.S. Department of Health and Human Services‌ APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA. A. IRO Engagement‌ 1. DOCS shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.4 of the IA or any additional information submitted by DOCS in response to a request by OIG, whichever is later, OIG will notify DOCS if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, DOCS may continue to engage the IRO.‌ 2. If DOCS engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, DOCS shall submit the information identified in Section V.A.4 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by DOCS at the request of OIG, whichever is later, OIG will notify DOCS if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, DOCS may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review who have expertise in the billing, coding, claims submission and other applicable Federal health care program requirements;‌ 2. assign individuals to design and select the Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professionals acting within their scope of practice and specialized expertise) to make the medical necessity determinations required by the Claims Review; and‌ 5. have sufficient staff and resources to conduct the reviews required by the IA on a timely basis.‌‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Claims Review in accordance with the specific requirements of the‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇ and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementArc’s obligations under this IA CIA based on a certification by Center for Pain Management Arc that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Arc is relieved of its IA CIA obligations, Center for Pain Management Arc shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Arc plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementArc’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Arc signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. 4/17/18 /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services 4-18-18 This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. ▇▇▇ shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.7 of the CIA or any additional information submitted by Arc in response to a request by OIG, whichever is later, OIG will notify Arc if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Arc may continue to engage the IRO.‌ 2. If ▇▇▇ engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Arc shall submit the information identified in Section V.A.7 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by ▇▇▇ at the request of OIG, whichever is later, OIG will notify Arc if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Arc may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review who have expertise in the Alaska Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review who have expertise in the Alaska Medicaid coding requirements applicable to the claims being reviewed;‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professionals acting within their scope of practice and specialized expertise) to make the medical necessity determinations‌ required by the Claims Review; and 5. have sufficient staff and resources to conduct the reviews required by the CIA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Claims Review in accordance with the specific requirements of the CIA;‌ 2. follow all applicable Alaska Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority if in doubt of the application of a particular Alaska Medicaid program policy or regulation;‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and‌ 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the CIA.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by prior written consent of the parties to this IA. C. OIG ▇. ▇▇▇ may agree to a suspension of Center for Pain ManagementQin’s obligations under this IA based on a certification by Center for Pain Management ▇▇▇ that it he is no longer providing health care items or services that will be billed to any Federal health care program programs and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, interest in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇ is relieved of its his IA obligations, Center for Pain Management Qin shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, the OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to to, and do not affect: affect (1) Center for Pain Management▇▇▇’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ signatory represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇ ▇▇▇, M.D./ April 29, 2015 ▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇ ▇. ▇▇▇ ▇▇▇▇▇/ 4/29/20 Center 4/29/15 Counsel for Pain Management, S.C. Qin DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. ▇ PLLC /▇▇▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇▇▇▇/ 4/27/15 ▇▇▇▇▇▇ ▇. RE ▇▇▇▇▇▇▇ DATE Assistant Inspector General for Legal Affairs Office of Counsel to the Inspector General Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇4/29/2015 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Counsel to the Inspector General Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementQamar’s obligations under this IA based on a certification by Center for Pain Management Qamar that it he is no longer providing health care items or services that will be billed to any Federal health care program and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇▇ is relieved of its his IA obligations, Center for Pain Management Qamar shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Qamar plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementQamar’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ Qamar signatory represents and warrants that she [he/she] is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ . ▇▇▇▇▇, M.D. DATE /Counsel DATE ▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ MPG and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA.IA.‌‌ C. OIG may agree to a suspension of Center for Pain ManagementMPG’s obligations under this IA based on a certification by Center for Pain Management MPG that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management MPG is relieved of its IA obligations, Center for Pain Management MPG shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management MPG plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementMPG’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents MPG signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇ON BEHALF OF MICHIGAN PHYSICIANS GROUP, P.C., AND ▇▇▇▇▇▇ ▇▇▇▇▇, M.D.‌‌ /_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇/_ Michigan Physicians Group, M.D. P.C. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇, s.c. P.C. ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌‌ /▇▇▇▇ ▇. Re/ 05/01/2020 2/11/2021 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. U.S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇/__ 2/11/2021_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. MPG shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph E. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by MPG in response to a request by OIG, whichever is later, OIG will notify MPG if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, MPG may continue to engage the IRO.‌ 2. If MPG engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, MPG shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by MPG at the request of OIG, whichever is later, OIG will notify MPG if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, MPG may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Lan Apothecary and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementLan Apothecary’s obligations requirements under this IA based on a certification by Center for Pain Management Lan Apothecary that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Lan Apothecary is relieved of its IA obligationsrequirements, Center for Pain Management Lan Apothecary shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Lan Apothecary plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementLan Apothecary’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ Lan Apothecary signatory represents and warrants that she is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 / ▇▇▇▇▇▇▇ (▇▇▇▇▇▇▇) ▇. ▇▇▇▇, M.D. RPH Individually and on behalf of Lan Apothecary, Inc. DATE /Counsel for ▇▇▇▇▇▇▇ (▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ) ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ , RPH and Lan Apothecary, Inc. DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 12/10/2021_ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇12/10/2021_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Affirmative Litigation Branch Office of Inspector General U.S. U. S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Lincare and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementLincare’s obligations under this IA CIA based on a certification by Center for Pain Management Lincare that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Lincare is relieved of its IA CIA obligations, Center for Pain Management Lincare shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Lincare plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementLincare’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Lincare signatories represent and warrants warrant that she is they are authorized to execute this IACIA . The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇▇ Clinic and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain Management▇▇▇▇ Clinic’s obligations under this IA based on a certification by Center for Pain Management ▇▇▇▇ Clinic that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇ Clinic is relieved of its IA obligations, Center for Pain Management ▇▇▇▇ Clinic shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇▇ Clinic plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management▇▇▇▇ Clinic’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ Clinic signatory represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇, O.D., DATE President and Owner ▇▇▇▇▇ ▇▇▇▇ ▇▇▇▇/ _4/29/20, O.D., PH.D., P.C., D/B/A ▇▇▇▇ EYE CLINIC /▇▇▇▇▇ ▇. Day/ 9/15/2020_ ▇▇▇▇▇ ▇. DAY DATE ▇▇▇▇▇ & ▇▇▇▇▇▇▇, counsel for ▇▇▇▇▇ ▇▇▇▇ ▇▇▇▇, O.D., PH.D., P.C., D/B/A ▇▇▇▇ EYE CLINIC /▇▇▇▇▇ ▇▇▇▇ ▇▇▇▇/_ 9/4/2020 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ , O.D., DATE President and Owner ▇▇▇▇ DATE EYE CLINIC /▇▇▇▇▇ ▇. Day/ 9/15/2020_ ▇▇▇▇▇ ▇. DAY DATE ▇▇▇▇▇ & ▇▇▇▇▇▇▇, s.c. /counsel for ▇▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇, O.D. ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by prior written consent of the parties to this IA. C. OIG ▇. ▇▇▇ may agree to a suspension of Center for Pain Management▇▇▇▇▇’s obligations under this IA based on a certification by Center for Pain Management ▇▇▇▇▇ that it he is no longer providing health care items or services that will be billed to any Federal health care program programs and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, interest in any entity that bills any Federal health care program. If Center for Pain Management ▇▇▇▇▇ is relieved of its his IA obligations, Center for Pain Management ▇▇▇▇▇ shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, the OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to to, and do not affect: affect (1) Center for Pain Management▇▇▇▇▇’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IA. /Counsel for ▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Counsel to the Inspector General Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Counsel to the Inspector General Office of Inspector General U.S. U. S. Department of Health and Human Services DATE DATE This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Maxim and OIG agree as follows: A. This IA CIA shall be binding on the successors, assigns, and transferees of Maxim. B. This CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. C. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. D. OIG may agree to a suspension of Center for Pain ManagementMaxim’s obligations under this IA CIA based on a certification by Center for Pain Management Maxim that it is no longer providing health care items or services that will be billed to any Federal health care program and that it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Maxim is relieved of its IA CIA obligations, Center for Pain Management shall Maxim will be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Maxim plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Maxim signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /ON BEHALF OF MAXIM HEALTHCARE SERVICES, INC. /W. ▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇/ W. ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. ▇▇ Chief Executive Officer DATE 9/9/2011 /▇▇▇▇▇ ▇▇▇▇▇▇▇-▇▇▇▇▇▇▇▇▇▇/ ▇▇▇▇▇ ▇▇▇▇▇▇▇-▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇ ▇▇▇▇▇ LLP Counsel for Maxim Healthcare Services, Inc. DATE 9/7/2011 ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES /▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services DATE 9/9/2011 /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services DATE 9/7/2011 APPENDIX A INDEPENDENT REVIEW ORGANIZATION This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Flower Mound and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementFlower Mound’s obligations requirements under this IA CIA based on a certification by Center for Pain Management Flower Mound that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Flower Mound is relieved of its IA obligationsCIA requirements, Center for Pain Management Flower Mound shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Flower Mound plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementFlower Mound’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Flower Mound signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇▇/_ 4/29/20 _ 11-22-21 _‌‌ ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 President ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇ and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementArc’s obligations under this IA CIA based on a certification by Center for Pain Management Arc that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Arc is relieved of its IA CIA obligations, Center for Pain Management Arc shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Arc plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementArc’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Arc signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. 4/17/18 /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ 4-18-18 /▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services ▇. Re/ 4/23/18 /▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4-18-18 This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA. A. IRO Engagement‌ 1. ▇▇▇ shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.7 of the CIA or any additional information submitted by Arc in response to a request by OIG, whichever is later, OIG will notify Arc if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Arc may continue to engage the IRO.‌ 2. If ▇▇▇ engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, Arc shall submit the information identified in Section V.A.7 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by ▇▇▇ at the request of OIG, whichever is later, OIG will notify Arc if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Arc may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Claims Review who have expertise in the Alaska Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Claims Review who have expertise in the Alaska Medicaid coding requirements applicable to the claims being reviewed;‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professionals acting within their scope of practice and specialized expertise) to make the medical necessity determinations‌ required by the Claims Review; and 5. have sufficient staff and resources to conduct the reviews required by the CIA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Claims Review in accordance with the specific requirements of the CIA;‌ 2. follow all applicable Alaska Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority if in doubt of the application of a particular Alaska Medicaid program policy or regulation;‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and‌ 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the CIA.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Diversicare and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementDiversicare’s obligations under this IA CIA based on a certification by Center for Pain Management Diversicare that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Diversicare is relieved of its IA CIA obligations, Center for Pain Management Diversicare shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Diversicare plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementDiversicare’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Diversicare signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management Primex and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementPrimex’s obligations under this IA CIA based on a certification by Center for Pain Management Primex that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Primex is relieved of its IA CIA obligations, Center for Pain Management Primex shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Primex plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementPrimex’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Primex signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇-▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇/▇▇▇▇ ▇. ▇▇/ /▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management PGS and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain Management’s PGS’ obligations under this IA CIA based on a certification by Center for Pain Management PGS that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management PGS is relieved of its IA CIA obligations, Center for Pain Management PGS shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management PGS plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain Management’s PGS’ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ PGS signatory represents and warrants that she is authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ ▇▇. ▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG ▇. ▇▇▇ may agree to a suspension of Center for Pain Management’s ▇▇. ▇▇▇▇▇’▇ obligations under this IA based on a certification by Center for Pain Management ▇▇. ▇▇▇▇▇ that it he is no longer providing health care items or services that will be billed to any Federal health care program and it he does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇. ▇▇▇▇▇ is relieved of its his IA obligations, Center for Pain Management ▇▇. ▇▇▇▇▇ shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇. ▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s Dr, ▇▇▇▇▇’▇ or the Cancer Centers’ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned signatory on behalf of ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ and the Cancer Centers represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 / DR. ▇▇▇▇▇▇▇ ▇▇▇▇▇ DATE Counsel for ▇, M.D. DATE /▇. ▇▇▇▇▇ and the Cancer Centers Ice ▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA. A. IRO Engagement‌ 1. ▇▇. ▇▇▇▇▇ shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.2 of the IA or any additional information submitted by ▇▇. ▇▇▇▇▇ in response to a request by OIG, whichever is later, OIG will notify ▇▇. ▇▇▇▇▇ if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇. ▇▇▇▇▇ may continue to engage the IRO.‌ 2. If ▇▇. ▇▇▇▇▇ engages a new IRO during the term of the IA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, ▇▇. ▇▇▇▇▇ shall submit the information identified in Section V.A.2 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by ▇▇. ▇▇▇▇▇ at the request of OIG, whichever is later, OIG will notify ▇▇. ▇▇▇▇▇ if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇. ▇▇▇▇▇ may continue to engage the IRO.‌ B. IRO Qualifications The IRO shall:‌‌ 1. assign individuals to conduct the Quarterly Claims Review who have expertise in the Medicare and state Medicaid program requirements applicable to the claims being reviewed;‌ 2. assign individuals to design and select the Quarterly Claims Review sample who are knowledgeable about the appropriate statistical sampling techniques;‌ 3. assign individuals to conduct the coding review portions of the Quarterly Claims Review who have a nationally recognized coding certification and who have maintained this certification (e.g., completed applicable continuing education requirements);‌‌ 4. assign licensed nurses or physicians with relevant education, training and specialized expertise (or other licensed health care professional acting within their scope of practice and specialized expertise) to make the medical necessity determinations required by the Quarterly Claims Review; and‌ 5. have sufficient staff and resources to conduct the reviews required by the IA on a timely basis.‌ C. IRO Responsibilities The IRO shall:‌‌ 1. perform each Quarterly Claims Review in accordance with the specific requirements of the IA;‌ 2. follow all applicable Medicare and state Medicaid program rules and reimbursement guidelines in making assessments in the Claims Review;‌ 3. request clarification from the appropriate authority (e.g., Medicare contractor), if in doubt of the application of a particular Medicare or state Medicaid program policy or regulation;‌‌ 4. respond to all OIG inquires in a prompt, objective, and factual manner; and 5. prepare timely, clear, well-written reports that include all the information required by Appendix B to the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇▇ and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementION’s obligations under this IA CIA based on a certification by Center for Pain Management ION that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ION is relieved of its IA CIA obligations, Center for Pain Management ION shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ION plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain Management▇▇▇’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents ION signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. / /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix A contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.F of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇ and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by prior written consent of the parties to this IA. C. This IA shall be binding on the successors, assigns, and transferees of ▇▇. ▇▇▇▇▇▇▇▇. D. OIG may agree to a suspension of Center for Pain Management’s ▇▇. ▇▇▇▇▇▇▇▇’▇ obligations under this IA based on a certification by Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇ that it he is no longer providing health care items or services that will be billed to any Federal health care program programs and it he does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇ is relieved of its his IA obligations, Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇ shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management ▇▇. ▇▇▇▇▇▇▇▇ plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, the OIG shall evaluate whether the IA will be reactivated or modified. D. E. All requirements and remedies set forth in this IA are in addition to to, and do not affect: affect (1) Center for Pain Management’s ▇▇. ▇▇▇▇▇▇▇▇’▇ responsibility to follow all applicable Federal health care program requirements or (2) the governmentGovernment’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. F. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents signatories represent and warrants warrant that she is they are authorized to execute this IA. The undersigned OIG signatories represent represents that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. G. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 . ▇▇▇▇▇▇▇▇, M.D./ 1/11/13 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain ManagementIndividually and on behalf of Primary Care Associates, S.C. DATE P.C. Date /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ 1/9/2013 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇ LLP Counsel for ▇▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇, M.D., and Primary Care Associates, P.C. Date ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES /▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇1/18/13 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Assistant Inspector General for Legal Affairs Office of Counsel to the Inspector General Office of Inspector General U.S. U. S. Department of Health and Human Services DATE /▇▇▇▇ ▇. ▇’▇▇▇▇▇/ 1/24/13 ▇▇▇▇ ▇. ▇’▇▇▇▇▇ Senior Counsel Office of Counsel to the Inspector General Office of Inspector General U. S. Department of Health and Human Services DATE This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA. A. IRO Engagement 1. ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇, M.D., and Primary Care Associates, P.C. (collectively referred to herein as “▇▇. ▇▇▇▇▇▇▇▇”) shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.5 of the IA or any additional information submitted by ▇▇. ▇▇▇▇▇▇▇▇ in response to a request by OIG, whichever is later, OIG will notify ▇▇. ▇▇▇▇▇▇▇▇ if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇. ▇▇▇▇▇▇▇▇ may continue to engage the IRO. 2. If ▇▇. ▇▇▇▇▇▇▇▇ engages a new IRO during the term of the IA, this IRO shall also meet the requirements of this Appendix. If a new IRO is engaged, ▇▇. ▇▇▇▇▇▇▇▇ shall submit the information identified in Section V.A.5 of the IA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information, or any additional information submitted by ▇▇. ▇▇▇▇▇▇▇▇ at the request of OIG, whichever is later, OIG will notify ▇▇. ▇▇▇▇▇▇▇▇ if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, ▇▇. ▇▇▇▇▇▇▇▇ may continue to engage the IRO.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management LHMC and OIG agree as follows: A. This IA shall become final and binding on the date the final signature is obtained on the IA. B. This IA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IA. C. OIG may agree to a suspension of Center for Pain ManagementLHMC’s obligations under this IA based on a certification by Center for Pain Management LHMC that it he or she is no longer providing health care items or services that will be billed to any Federal health care program and it he or she does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management LHMC is relieved of its his or her IA obligations, Center for Pain Management LHMC shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management LHMC plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain ManagementLHMC’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ LHMC signatory represents and warrants that she he is authorized to execute this IA. The undersigned OIG signatories represent that they are signing this IA in their official capacity and that they are authorized to execute this IA. F. This IA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IA. Electronically transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. __/▇▇▇▇▇▇▇ ▇▇▇▇▇/_________ 4/29/20 ___11/6/2020__________ ▇▇▇▇▇▇▇ ▇. ▇▇▇▇, M.D. D.C. DATE Individually ___/▇▇▇▇▇▇▇ ▇▇▇▇/____________ _____11/6/2020_________ ▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇▇ ▇. ▇▇▇▇, D.C. DATE Owner Life Health Medical Center, Inc. ____/▇▇▇▇▇ ▇▇▇▇/ /_4/29/20________________ _____11/9/2020_________ ▇▇▇▇▇ ▇. ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇, s.cP.C. Counsel for ▇▇▇▇▇▇▇ ▇. ▇▇▇▇, D.C. and Life Health Medical Center, Inc. ____/▇▇▇▇ ▇. Re/ 05/01/2020 Re/_____________________ _____11/16/2020_______ ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services ____/▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇/____________________ _____11/12/2020__ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Affirmative Litigation Branch Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.C of the IA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management RehabCare, Kindred and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementKindred’s and/or RehabCare’s, obligations under this IA CIA based on a certification by Center for Pain Management Kindred and/or RehabCare, as applicable, that it is no longer providing health care items or services that will be billed by any entity to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Kindred and/or RehabCare, as applicable, is relieved of its IA CIA obligations, Center for Pain Management Kindred and/or RehabCare, as applicable, shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Kindred and/or RehabCare, as applicable, plans to resume providing health care items or services that are billed by any entity to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementKindred’s and RehabCare’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents RehabCare and warrants Kindred signatories represent and warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. G. This CIA is by and between the parties hereto. /The CIA is not intended to establish any legal rights for or confer any legal rights upon any non-governmental entities or persons not a party to the CIA. The parties agree, however, that this CIA is a public document and it may be admissible in a judicial or administrative proceeding. /s/ ▇▇▇ ▇. ▇▇▇▇▇▇▇▇ January 7, 2016 ▇▇▇ ▇. ▇▇▇▇▇▇▇▇ DATE President RehabCare Group, Inc. /s/ ▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇ January 8, 2016 ▇▇▇ ▇▇▇▇▇▇ DATE President and Chief Executive Officer, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain ManagementKindred Healthcare, S.C. DATE /Inc. /s/ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ January 8, 2016 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ DATE ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & LLP /s/ ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇▇▇▇ January 11, 2016 ▇▇▇▇▇▇ ▇. RE ▇▇▇▇▇▇▇ DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services //s/ ▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇January 11, 2016 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IA.Services

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ Mercy, MHM and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementMercy’s or MHM’s respective obligations under this IA CIA based on a certification by Center for Pain Management Mercy or MHM that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §§ 1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management Mercy or MHM is relieved of its IA respective CIA obligations, Center for Pain Management Mercy or MHM shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management Mercy or MHM plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified.modified.‌‌‌ D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementMercy’s and MHM’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents Mercy and warrants MHM signatories represent and warrant that she is they are authorized to execute this IACIA . The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. ON BEHALF OF‌‌ /▇▇▇▇ ▇▇▇▇▇▇▇/ ▇▇▇▇ ▇▇▇▇▇▇▇, MD, JD President April 20, 2017 DATE /▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇/ ▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. LLP Counsel for Mercy Hospital Springfield and Mercy Clinic Springfield Communities 4/20/2017 DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇/ 4/18/17 ‌‌ ▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇▇▇▇ DATE President /▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇/ _4/29/20_ 4/20/2017 ‌‌ ▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇ DATE ▇. ▇▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. LLP Counsel for MHM Support Services ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌‌ /▇▇▇▇ ▇. Re/ 05/01/2020 4/28/17 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇5/2/17 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General to the Inspector General Office of Inspector General U.S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IACIA. A. IRO Engagement‌ 1. ▇▇▇▇▇ shall engage an IRO that possesses the qualifications set forth in Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO shall conduct the review in a professionally independent and objective fashion, as set forth in Paragraph D. Within 30 days after OIG receives the information identified in Section V.A.9 of the CIA or any additional information submitted by Mercy in response to a request by OIG, whichever is later, OIG will notify Mercy if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Mercy may continue to engage the IRO.‌ 2. If Mercy engages a new IRO during the term of the CIA, that IRO must also meet the requirements of this Appendix. If a new IRO is engaged, ▇▇▇▇▇ shall submit the information identified in Section V.A.9 of the CIA to OIG within 30 days of engagement of the IRO. Within 30 days after OIG receives this information or any additional information submitted by Mercy at the request of OIG, whichever is later, OIG will notify Mercy if the IRO is unacceptable. Absent notification from OIG that the IRO is unacceptable, Mercy may continue to engage the IRO.‌

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌ CRC and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementCRC’s obligations under this IA CIA based on a certification by Center for Pain Management CRC that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management CRC is relieved of its IA CIA obligations, Center for Pain Management ,CRC shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management CRC plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain ManagementCRC’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents CRC signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of signatures shall constitute acceptable, binding signatures for purposes of this IA. /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Counsel Office of Inspector General U.S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management CareMed and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain ManagementCareMed’s obligations under this IA CIA based on a certification by Center for Pain Management CareMed that it is no longer providing health care items or services that will be billed to any Federal health care program and that it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management CareMed is relieved of its IA CIA obligations, Center for Pain Management shall CareMed will be required to notify OIG in writing at least 30 days in advance if Center for Pain Management CareMed plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA are in addition to and do not affect: (1) Center for Pain Management’s responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents CareMed signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. E. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically transmitted copies Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. /Nuaman Tyyeb/ 11/24/2014 NUAMAN TYYEB DATE President, Sorkin’s RX Ltd. As the Executor of the Estate of Muhammad Tyyeb /▇▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇▇▇▇▇▇▇ ▇▇▇▇▇, M.D. DATE /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ 11/24/14 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇ DATE Counsel for CareMed DATE /▇▇▇▇▇▇ DATE ▇. ▇▇▇▇▇▇▇/ 11/21/14 ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 ▇▇▇▇ ▇. RE DATE Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇12/1/2014 ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. U. S. Department of Health and Human Services This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E III.D of the IACIA.

EFFECTIVE AND BINDING AGREEMENT. Center for Pain Management ‌‌‌ The GIS Parties and OIG agree as follows: A. This IA CIA shall become final and binding on the date the final signature is obtained on the IACIA. B. This IA CIA constitutes the complete agreement between the parties and may not be amended except by written consent of the parties to this IACIA. C. OIG may agree to a suspension of Center for Pain Management’s any of the GIS Parties’ obligations under this IA CIA based on a certification by Center for Pain Management the relevant GIS Party that it is no longer providing health care items or services that will be billed to any Federal health care program and it does not have any ownership or control interest, as defined in 42 U.S.C. §1320a-3, in any entity that bills any Federal health care program. If Center for Pain Management a GIS Party is relieved of its IA CIA obligations, Center for Pain Management the GIS Party shall be required to notify OIG in writing at least 30 days in advance if Center for Pain Management the GIS Party plans to resume providing health care items or services that are billed to any Federal health care program or to obtain an ownership or control interest in any entity that bills any Federal health care program. At such time, OIG shall evaluate whether the IA CIA will be reactivated or modified. D. All requirements and remedies set forth in this IA CIA are in addition to and do not affect: affect (1) Center for Pain Management’s the GIS Parties’ responsibility to follow all applicable Federal health care program requirements or (2) the government’s right to impose appropriate remedies for failure to follow applicable Federal health care program requirements. E. The undersigned ▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇.▇. ▇▇▇▇▇▇▇▇▇ represents GIS Parties’ signatories represent and warrants warrant that she is they are authorized to execute this IACIA. The undersigned OIG signatories represent that they are signing this IA CIA in their official capacity capacities and that they are authorized to execute this IACIA. F. This IA CIA may be executed in counterparts, each of which constitutes an original and all of which constitute one and the same IACIA. Electronically Electronically-transmitted copies of Facsimiles of signatures shall constitute acceptable, binding signatures for purposes of this IACIA. ON BEHALF OF THE GIS PARTIES‌‌ /▇▇▇▇ ▇▇▇▇▇▇▇/ 5/8/18 ▇▇▇▇ ▇▇▇▇▇▇▇, M.D. Managing Partner Gastrointestinal Specialists of Georgia, P.C. DATE Managing Partner G.I. Diagnostics Endoscopy Center, L.L.C. DATE Managing Partner DCA Diagnostics, L.L.C DATE ▇▇▇▇▇▇ ▇▇▇▇▇/_ 4/29/20 ▇ ▇▇▇▇▇▇▇▇ ▇▇▇▇▇LLP Counsel for Gastrointestinal Specialists of Georgia, M.D. P.C.; G.I. Diagnostics Endoscopy Center, L.L.C.; and DCA Diagnostics, LLC DATE ON BEHALF OF THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES‌‌ /▇▇▇▇▇▇▇ ▇▇▇▇▇/ 4/29/20 Center for Pain Management, S.C. DATE /▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇/ _4/29/20_ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇ DATE ▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇, s.c. /▇▇▇▇ ▇. Re/ 05/01/2020 5/10/2018 ▇▇▇▇ ▇. RE DATE DATE‌ Assistant Inspector General for Legal Affairs Office of Inspector General U. S. Department of Health and Human Services /▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇/ 05/01/2020 ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ DATE Associate Senior Counsel Office of Inspector General U.S. Department of Health and Human Services APPENDIX A INDEPENDENT REVIEW ORGANIZATION‌‌‌ This Appendix contains the requirements relating to the Independent Review Organization (IRO) required by Section III.E of the IACIA.