Common use of Implementation Report Clause in Contracts

Implementation Report. Within 150 days after the Effective Date, Walgreens shall submit a written report to OIG summarizing the status of its implementation of the requirements of this CIA (Implementation Report). The Implementation Report shall, at a minimum, include: 1. the name, address, phone number, and position description of the Compliance and Ethics Officer required by Section III.A, and a summary of other noncompliance job responsibilities the Compliance and Ethics Officer may have; 2. the names and positions of the members of the Compliance Committee required by Section III.A; 3. the names of the Audit Committee of the Board members who are responsible for satisfying the Board of Directors compliance obligations described in Section III.A.3; 4. the names and positions of the Certifying Employees required by Section III.A.4, and a copy of the written process for completing the certification required by Section III.A.4; 5. a list of the Policies and Procedures required by Section III.B; Walgreen Co. - Corporate Integrity Agreement 6. the Training Plan required by Section III.C.1 and a description of the Board Member Training required by Section III.C.2 (including a summary of the topics covered, the length of the training, and when the training was provided); 7. the following information regarding the IRO(s): (a) identity, address, and phone number; (b) a copy of the engagement letter; (c) information to demonstrate that the IRO has the qualifications outlined in Appendix A to this CIA; and (d) a certification from the IRO regarding its professional independence and objectivity with respect to Walgreens; 8. a description of the risk assessment and internal review process required by Section III.E; 9. a description of the Disclosure Program required by Section III.F; 10. a description of the Ineligible Persons screening and removal process required by Section III.G; 11. a copy of Walgreens’ policies and procedures regarding the identification, quantification and repayment of Overpayments required by Section III.I; 12. a description of Walgreens’ corporate structure, including identification of any parent and sister companies, subsidiaries, and their respective lines of business; 13. a list of all of Walgreens’ locations that perform Covered Functions (including locations and mailing addresses), the corresponding name under which each location is doing business, and the location’s Medicare and state Medicaid program provider number and/or supplier number(s); and

Implementation Report. Within 150 120 days after the Effective Date, Walgreens HealthSouth shall submit a written report to OIG summarizing the status of its implementation of the requirements of this CIA (Implementation Report). The Implementation Report shall, at a minimum, include: 1. the name, address, phone number, and position description of the Compliance and Ethics Officer required by Section III.A, and a summary of other noncompliance job responsibilities the Compliance and Ethics Officer may have; 2. the names and positions of the members of the Executive Compliance Committee and the Board Compliance Committee required by Section III.A; 3. the names a copy of the Audit Committee HealthSouth’s Code of the Board members who are responsible for satisfying the Board of Directors compliance obligations described in Conduct required by Section III.A.3;III.B.1; Corporate Integrity Agreement HealthSouth Corporation 4. the names a copy of all policies and positions procedures required by Sections III.B.3.a through III.B.3.e, and a summary of the Certifying Employees all other policies and procedures required by Section III.A.4, and a copy III.B; 5. the number of individuals required to complete the written process for completing the Code of Conduct certification required by Section III.A.4III.B.1, the percentage of individuals who have completed such certification, and an explanation of any exceptions (the documentation supporting this information shall be available to OIG, upon request); 5. a list of the Policies and Procedures required by Section III.B; Walgreen Co. - Corporate Integrity Agreement 6. the Training Plan following information regarding each type of training required by Section III.C.1 and III.C: a. a description of the Board Member Training required by Section III.C.2 (such training, including a summary of the topics covered, the length of the trainingsessions and a training schedule; b. number of individuals required to be trained, percentage of individuals actually trained, and when an explanation of any exceptions. A copy of all training materials and the training was provided)documentation supporting this information shall be available to OIG, upon request. 7. a description of the Disclosure Program required by Section III.E; 78. the following information regarding the IRO(s): (a) identity, address, and phone number; (b) a copy of the engagement letter; (c) information to demonstrate that a summary and description of any and all current and prior engagements and agreements between HealthSouth and the IRO has the qualifications outlined in Appendix A to this CIAIRO; and (d) the proposed start and completion dates of the Cost Reporting Engagement, Unallowable Cost Review, and Billing Engagement during the first CIA year; 9. a certification from the IRO regarding its professional independence and and/or objectivity with respect to WalgreensHealthSouth; 8. a description of the risk assessment and internal review process required by Section III.E; 9. a description of the Disclosure Program required by Section III.F; 10. a description of the process by which HealthSouth fulfills the requirements of Section III.F regarding Ineligible Persons screening and removal process required by Section III.GPersons; 11. a copy the name, title, and responsibilities of Walgreens’ policies any person who is determined to be an Ineligible Person under Section III.F; the actions taken in response to the screening and procedures regarding removal obligations set forth in Section III.F; and the identificationactions taken to identify, quantification quantify, and repayment of Overpayments required repay any overpayments to Federal health care programs relating to items or services furnished, ordered or prescribed by Section III.Ian Ineligible Person; 12. to the extent not already provided to OIG, a list of all of HealthSouth’s facilities furnishing items or services that may be reimbursed by Federal health care programs including the address of each facility, phone number, Corporate Integrity Agreement HealthSouth Corporation fax number, Medicare Provider number, provider identification number and/or supplier number, and the corresponding contractor’s name and address that issued each Medicare number; 13. to the extent not already provided to OIG, a description of Walgreens’ HealthSouth’s corporate structure, including identification of any parent and sister companies, subsidiaries, and their respective lines of business; 13. a list of all of Walgreens’ locations that perform Covered Functions (including locations and mailing addresses), the corresponding name under which each location is doing business, and the location’s Medicare and state Medicaid program provider number and/or supplier number(s); and 14. the certifications required by Section V.C.

Implementation Report. Within 150 120 days after the Effective Date, Walgreens United Therapeutics shall submit a written report to OIG summarizing the status of its implementation of the requirements of this CIA (Implementation Report). The Implementation Report shall, at a minimum, include: 1. the name, address, phone number, and position description of the Compliance and Ethics Officer required by Section III.AIII.A.1, and a summary of other noncompliance job responsibilities the Compliance and Ethics Officer may have; 2. the names and positions of the members of the Compliance Committee required by Section III.AIII.A.2; 3. the names of the Audit Committee members of the Board members of Directors who are responsible for satisfying the Board of Directors compliance obligations described in Section III.A.3; 4. the identity and credentials of the Compliance Expert required by Section III.A.3; 5. the names and positions of the Certifying Employees required by Section III.A.4, and a copy of the written process for completing the certification required by Section III.A.4; 56. a list of the Policies and Procedures required by Section III.B; Walgreen Co. - Corporate Integrity AgreementIII.B.3; 67. the Training Plan required by Section III.C.1 and a description of the Board Member Training of Directors training required by Section III.C.2 (including a summary of the topics covered, the length of the training, training and when the training was provided); 78. a description of the risk assessment and internal review process required by Section III.D; 9. the following information regarding the IRO(s): (a) identity, address, and phone number; (b) a copy of the engagement letter; (c) information to demonstrate that the IRO has the qualifications outlined in Appendix A to this CIAA; and (d) a certification from the IRO regarding its professional independence and objectivity with respect to WalgreensUnited Therapeutics; 8. a description of the risk assessment and internal review process required by Section III.E; 910. a description of the Disclosure Program required by Section III.F; 10; 11. a description of the Ineligible Persons screening and removal process required by Section III.G; 11. a copy of Walgreens’ policies and procedures regarding the identification, quantification and repayment of Overpayments required by Section III.IIII.G.; 12. a list of all of United Therapeutics’ locations (including locations and mailing addresses); the corresponding name under which each location is doing business; the corresponding phone numbers and fax numbers; 13. a description of WalgreensUnited Therapeutics’ corporate structure, including identification of any parent and sister companies, subsidiaries, and their respective lines of business; 13. a list of all of Walgreens’ locations that perform Covered Functions (including locations and mailing addresses), the corresponding name under which each location is doing business, and the location’s Medicare and state Medicaid program provider number and/or supplier number(s); and 14. the certifications required by Section V.C.

Implementation Report. Within 150 days after the Effective Date, Walgreens Sandoz shall submit a written report to OIG summarizing the status of its implementation of the requirements of this CIA (Implementation Report). The Implementation Report shall, at a minimum, include: 1. the name, address, phone number, and position description of the Compliance and Ethics Officer required by Section III.AIII.A.1, and a summary of other noncompliance job responsibilities the Compliance and Ethics Officer may have; 2. the names and positions of the members of the Compliance Committee required by Section III.AIII.A.2; 3. the names of the Audit Committee of the Board members who are responsible for satisfying the Board of Directors compliance obligations described in Section III.A.3; 4. the names and positions of the Certifying Employees required by Section III.A.4, III.A.4 and a written copy of the written process for to be followed by Certifying Employees in connection with completing the certification required by Section III.A.4certifications; 5. a list of the Policies and Procedures required by Section III.B; Walgreen Co. - Corporate Integrity Agreement; 6. the Training Plan required by Section III.C.1 and a description of the Board Member Training of Directors training required by Section III.C.2 (including a summary of the topics covered, the length of the training, training and when the training was provided); 7. a description of the risk assessment and internal review process required by Section III.D; 8. the following information regarding the IRO(s): (a) identity, address, and phone number; (b) a copy of the engagement letter; (c) information to demonstrate that the IRO has the qualifications outlined in Appendix A to this CIAA; and (d) a certification from the IRO regarding its professional independence and objectivity with respect to Walgreens; 8. a description of the risk assessment and internal review process required by Section III.ESandoz; 9. a description of the Disclosure Program required by Section III.F; 10. a description of the Ineligible Persons screening and removal process required by Section III.GIII.G.; 11. a copy list of Walgreens’ policies all of Sandoz’s locations (including locations and procedures regarding mailing addresses); the identificationcorresponding name under which each location is doing business; the corresponding phone numbers and fax numbers, quantification and repayment of Overpayments required by Section III.Ithe location’s Medicare and state Medicaid program provider and/or supplier numbers (if any); 12. a description of Walgreens’ ▇▇▇▇▇▇’▇ corporate structure, including identification of any parent and sister companies, subsidiaries, and their respective lines of business; 13. a list of all of Walgreens’ locations that perform Covered Functions (including locations and mailing addresses), the corresponding name under which each location is doing business, and the location’s Medicare and state Medicaid program provider number and/or supplier number(s); and

Implementation Report. Within 150 days after the Effective Date, Walgreens CHSI shall submit a written report to OIG summarizing the status of its implementation of the requirements of this CIA (Implementation Report). The Implementation Report shall, at a minimum, include: 1. The name, address, phone number, and position description of the Corporate Compliance and Privacy Officer required by Section III.A.1, and a summary of other noncompliance job responsibilities the Corporate Compliance and Privacy Officer may have; Community Health Systems, Inc. Corporate Integrity Agreement, Amended 2. the name, address, phone number, and position description of the each Senior Compliance Director, Corporate Compliance Director, and Ethics Officer Facility Compliance Officers required by Section III.AIII.A.2, and a summary of other noncompliance job responsibilities the each Senior Compliance Director, Corporate Compliance Director, and Ethics Officer Facility Compliance officers may have; 23. the names and positions of the members of the Corporate Compliance Work Group required by Section III.A.3; 4. the names and positions of the members of each Facility Compliance Committee required by Section III.AIII.A.4; 35. the names of the Audit Committee of the Board members who are responsible for satisfying the Board of Directors compliance obligations described in Section III.A.3III.A.5; 46. the names and positions a copy of the Certifying Employees CHSI’s Code of Conduct required by Section III.A.4, and a copy III.B.1; 7. the number of individuals required to complete the written process for completing the Code of Conduct certification required by Section III.A.4III.B.1, the percentage of individuals who have completed such certification, and an explanation of any exceptions (the documentation supporting this information shall be available to OIG upon request); 58. a list summary of the all Policies and Procedures required by Section III.B; Walgreen Co. - Corporate Integrity AgreementIII.B.2 (copies of the Policies and Procedures shall be made available to OIG upon request); 69. the Training Plan following information regarding each type of training required by Section III.C.1 and III.C: a. a description of the Board Member Training required by Section III.C.2 (such training, including a summary of the topics covered, the length of sessions, and a schedule of training sessions; b. the number of individuals required to be trained, percentage of individuals actually trained, and an explanation of any exceptions; and c. with respect to active medical staff members, the number and percentage who completed the training, the type of training Community Health Systems, Inc. Corporate Integrity Agreement, Amended and when the training was provided); 7. the following information regarding the IRO(s): (a) identity, addressdate received, and phone number; (b) a description of CHSI’s efforts to encourage medical staff members to complete the training. A copy of all training materials and the engagement letter; (c) documentation supporting this information shall be made available to demonstrate that the IRO has the qualifications outlined in Appendix A to this CIA; and (d) a certification from the IRO regarding its professional independence and objectivity with respect to Walgreens;OIG upon request. 810. a description of (a) the risk assessment and Focus Arrangements Tracking System required by Section III.D.1.a, (b) the internal review and approval process required by Section III.EIII.D.1.e; 9and (c) the tracking and monitoring procedures and other Focus Arrangements Procedures required by Section III.D.1; 11. a description of the Disclosure Program required by Section III.F; 10. a description of the Ineligible Persons screening and removal process required by Section III.G; 11. a copy of Walgreens’ policies and procedures regarding the identification, quantification and repayment of Overpayments required by Section III.I; 12. a description of Walgreens’ corporate structure, including identification of any parent and sister companies, subsidiaries, and their respective lines of business; 13. a list of all of Walgreens’ locations that perform Covered Functions (including locations and mailing addresses), the corresponding name under which each location is doing business, and the location’s Medicare and state Medicaid program provider number and/or supplier number(s); and

Implementation Report. Within 150 120 days after the Effective Date, Walgreens Rotech shall submit a written report to OIG summarizing the status of its implementation of the requirements of this CIA (Implementation Report). The Implementation Report shall, at a minimum, include: 1. the name, address, phone number, and position description of the Compliance and Ethics Officer required by Section III.A, and a summary of other noncompliance job responsibilities the Compliance and Ethics Officer may have; 2. the names and positions of the members of the Compliance Committee required by Section III.A; 3. the names of the Audit Committee of the Board members who are responsible for satisfying the individuals serving on Rotech’s Board of Directors compliance obligations described in Section III.A.3;Directors; Rotech Healthcare Inc. Corporate Integrity Agreement 4. the names and positions a copy of the Certifying Employees Rotech’s Code of Conduct required by Section III.A.4, and a copy of the written process for completing the certification required by Section III.A.4III.B.1; 5. a list copy of the all Policies and Procedures required by Section III.B; Walgreen Co. - Corporate Integrity AgreementIII.B.2; 6. the Training Plan number of individuals required to complete the Code of Conduct certification required by Section III.C.1 III.B.1, the percentage of individuals who have completed such certification, and an explanation of any exceptions (the documentation supporting this information shall be available to OIG, upon request); 7. the following information regarding each type of training required by Section III.C: a. a description of the Board Member Training required by Section III.C.2 (such training, including a summary of the topics covered, the length of the trainingsessions, and when the a schedule of training was provided)sessions; 7b. the number of individuals required to be trained, percentage of individuals actually trained, and an explanation of any exceptions. A copy of all training materials and the documentation supporting this information shall be available to OIG, upon request. 8. a description of the Disclosure Program required by Section III.E; 9. the following information regarding the IRO(s): (a) identity, address, and phone number; (b) a copy of the engagement letter; and (c) information to demonstrate that a summary and description of any and all current and prior engagements and agreements between Rotech and the IRO has the qualifications outlined in Appendix A to this CIA; and (d) IRO; 10. a certification from the IRO regarding its professional independence and objectivity with respect to WalgreensRotech; 811. a description of the risk assessment process by which Rotech fulfills the requirements of Section III.F regarding Ineligible Persons; 12. the name, title, and internal review process required responsibilities of any person who is determined to be an Ineligible Person under Section III.F; the actions taken in response to the screening and removal obligations set forth in Section III.F; and the actions taken to identify, quantify, and repay any overpayments to Federal health care programs relating to items or services furnished, ordered or prescribed by Section III.Ean Ineligible Person; 9Rotech Healthcare Inc. Corporate Integrity Agreement 13. a list of all of Rotech’s locations (including locations and mailing addresses); the corresponding name under which each location is doing business; the corresponding phone numbers and fax numbers; each location’s National Provider Identifier, Medicare Provider number(s), provider identification number(s), and/or supplier number(s); and the name and address of each Medicare contractor to which Rotech currently submits claims; 14. a description of the Disclosure Program required by Section III.F; 10. a description of the Ineligible Persons screening and removal process required by Section III.G; 11. a copy of Walgreens’ policies and procedures regarding the identification, quantification and repayment of Overpayments required by Section III.I; 12. a description of Walgreens’ Rotech’s corporate structure, including identification of any parent and sister companies, subsidiaries, and their respective lines of business; 13. a list of all of Walgreens’ locations that perform Covered Functions (including locations and mailing addresses), the corresponding name under which each location is doing business, and the location’s Medicare and state Medicaid program provider number and/or supplier number(s); and