Program Infrastructure. During the Term, EFS shall maintain, operate, or engage in, as the case may be, the following items in support of the Program:
Program Infrastructure. Vencor shall, within ninety (90) days of the effective date of this CIA, create an internal structure whereby individuals are given responsibility at the facility, district, regional, and corporate levels to address quality of care concerns. Much of this internal structure has been already created through the use of committees. These committees shall include individuals who are not charged with responsibilities concerning the financial aspects of Vencor's facilities. There shall be in place a mechanism and structure to provide the individuals who are charged with quality of care concerns with direct access to the Compliance Officer, the Compliance Department Staff, and the Quality Assurance Committees, including but not limited to, the Chief Medical Officers. As part of this internal structure, Vencor shall maintain or establish, as necessary, the following positions and committees. If Vencor changes its Compliance Program infrastructure in a way that affects these positions and committees, Vencor shall ensure that under the new structure Vencor devotes at least equal resources to its Compliance Program as are devoted under the structure described in this Section III.A and provide notice to the OIG within fifteen (15) days of any such change.
Program Infrastructure. Within 120 days of the Effective Date of this CIA, Sun shall review its current infrastructure and to the extent not already accomplished, create an internal structure whereby individuals are given responsibility at the facility, regional and corporate levels to address quality of care concerns. These individuals shall not be in the Chief Financial Officer's ("CFO's") chain of command. There shall be in place a mechanism and structure to provide the individuals who are charged with quality of care concerns with direct access to the Compliance Officer, appropriate clinical and/or medical staff and the Corporate Compliance Committee. As part of this internal structure, Sun shall maintain or establish, as necessary, the following positions and committees. If Sun changes its Compliance Program infrastructure in a way that affects these positions and committees, Sun shall ensure that under the new structure Sun devotes resources of equal effectiveness to its Compliance Program as are devoted under the structure described herein and provide notice to the OIG within 15 days after any such change.
Program Infrastructure
