Common use of Training Plan Clause in Contracts

Training Plan. Within 90 days after the Effective Date, Good Shepherd shall develop a written plan (Training Plan) that outlines the steps Good Shepherd will take to ensure that: (a) all Covered Persons receive adequate training regarding Good Shepherd’s CIA requirements and Compliance Program, including the Code of Conduct and (b) all Relevant Covered Persons receive adequate training regarding: (i) the Federal health care program requirements regarding eligibility for hospice services upon initial admission, recertification for continued stay, and for Continuous Care, Respite Care, and General Inpatient Care; (ii) the role of physicians in making eligibility determinations; (iii) the accurate coding and submission of claims; (iv) policies, procedures, and other requirements applicable to the documentation of medical records; (v) the personal obligation of each individual involved in the claims submission process to ensure that such claims are accurate; (vi) applicable reimbursement statutes, regulations, and program requirements and directives; (vii) the legal sanctions for violations of the Federal health care program requirements; and (viii) examples of proper and improper eligibility determinations, documentation, and claims submission practices. The Training Plan shall include information regarding the training topics, the categories of Covered Persons and Relevant Covered Persons required to attend each training session, the length of the training, the schedule for training, and the format of the training. Within 30 days of the OIG’s receipt of Good Shepherd’s Training Plan, OIG will notify Good Shepherd of any comments or objections to the Training Plan. Absent notification by the OIG that the Training Plan is unacceptable, Good Shepherd may implement its Training Plan. Good Shepherd shall furnish training to its Covered Persons and Relevant Covered Persons pursuant to the Training Plan during each Reporting Period.

Training Plan. Within 90 days after the Effective Date, Good Shepherd shall develop a written plan (Training Plan) that outlines the steps Good Shepherd will take to ensure that: (a) all Covered Persons (other than Board members who shall receive the training described in Section III.C.2) receive adequate training regarding Good Shepherd’s CIA requirements and Compliance Program, including the Code of Conduct and (b) all Relevant Covered Persons receive adequate training regarding: (i) the Federal health care program requirements regarding eligibility for hospice services upon initial admission, admission and at recertification for continued stay, and for Continuous Care, Respite Care, and General Inpatient Care; (ii) the role of physicians in making eligibility determinations; (iii) the accurate coding and submission of claims; (iv) policies, procedures, and other requirements applicable to the documentation of medical records; (v) the personal obligation of each individual involved in the claims submission process to ensure that such claims are accurate; (vi) applicable reimbursement statutes, regulations, and program requirements and directives; (vii) the legal sanctions for violations of the Federal health care program requirements; and (viii) examples of proper and improper eligibility determinations, documentation, and claims submission practices. The Training Plan shall include information regarding the training topics, the categories of Covered Persons and Relevant Covered Persons required to attend each training session, the length of the training, the schedule for training, and the format of the training. Within 30 days of the OIG’s receipt of Good Shepherd’s Training Plan, OIG will notify Good Shepherd of any comments or objections to the Training Plan. Absent notification by the OIG that the Training Plan is unacceptable, Good Shepherd may implement its Training Plan. Good Shepherd shall furnish training to its Covered Persons and Relevant Covered Persons pursuant to the Training Plan during each Reporting Period.

Training Plan. Within 90 days after the Effective Date, Good Shepherd PharMerica shall develop a written plan (Training Plan) that outlines the steps Good Shepherd PharMerica will take to ensure that: (a) all Covered Persons receive adequate training regarding Good ShepherdPharMerica’s CIA requirements and Compliance Program, including the Code of Conduct and (b) all Relevant Covered Persons receive adequate training regarding: (i) the Federal health care program Controlled Substances Act requirements regarding eligibility for hospice services upon initial admission, recertification for continued stay, and for Continuous Care, Respite Care, and General Inpatient Caregoverning the dispensing of Controlled Substances; (ii) the role of physicians in making eligibility determinations; (iii) the accurate coding and submission of claims; (iv) policies, procedures, and other requirements applicable to the documentation of medical recordsprescriptions for Controlled Substances; (viii) the personal obligation of each individual involved in the claims submission process to ensure that such claims are accurate; (viiv) applicable reimbursement statutes, regulations, and program requirements and directivesdirectives relating to the Controlled Substances Act and Federal health care program reimbursement; (viiv) the legal sanctions for violations of the Federal health care program and Controlled Substances Act requirements; and (viiivi) examples of proper and improper eligibility determinations, documentation, Controlled Substances dispensing (including proper and improper prescriptions) and claims submission practices. The Training Plan shall include information regarding the training topics, the categories of Covered Persons and Relevant Covered Persons required to attend each training session, the length of the training, the schedule for training, and the format of the training. Within 30 days of the OIG’s receipt of Good ShepherdPharMerica’s Training Plan, OIG will notify Good Shepherd PharMerica of any comments or objections to the Training Plan. Absent notification by the OIG that the Training Plan is unacceptable, Good Shepherd PharMerica may implement its Training Plan. Good Shepherd PharMerica shall furnish training to its Covered Persons and Relevant Covered Persons pursuant to the Training Plan during each Reporting Period.

Training Plan. Within 90 120 days after the Effective Date, Good Shepherd CareMed shall develop a written plan (Training Plan) that outlines the steps Good Shepherd CareMed will take to ensure that: (a) all Covered Persons receive adequate training regarding Good ShepherdCareMed’s CIA requirements and Compliance Program, including the Code of Conduct Ethics and (b) all Relevant Covered Persons receive adequate training regarding: (i) applicable state pharmacy requirements; (ii) the Federal health care program requirements regarding eligibility for hospice services upon initial admission, recertification for continued stay, and for Continuous Care, Respite Care, and General Inpatient Care; (ii) the role of physicians in making eligibility determinations; (iii) the accurate coding and submission of claims, including pharmacy billing and crediting requirements; (iii) the Federal health care program requirements regarding physician orders for pharmacy items and supplies and for dispensing of pharmacy items and supplies; (iv) policies, procedures, and other requirements applicable to the documentation of medical recordsrecords and the processing of physician orders for prescription drugs that require prior authorization from health plans; (v) the personal obligation of each individual involved in the claims submission process to ensure that such claims are accurate; (vi) applicable reimbursement statutes, regulations, and program requirements and directives; (vii) the legal sanctions for violations of the Federal health care program requirements; and (viii) examples of proper and improper eligibility determinations, documentation, and claims submission practices. The Training Plan shall include information regarding the training topics, the categories of Covered Persons and Relevant Covered Persons required to attend each training session, the length of the training, the schedule for training, and the format of the training. Within 30 days of the OIG’s receipt of Good ShepherdCareMed’s Training Plan, OIG will notify Good Shepherd CareMed of any comments or objections to the Training Plan. Absent notification by the OIG that the Training Plan is unacceptable, Good Shepherd CareMed may implement its Training Plan. Good Shepherd CareMed shall furnish training to its Covered Persons and Relevant Covered Persons pursuant to the Training Plan during each Reporting Period.

Training Plan. Within 90 days after the Effective Date, Good Shepherd Envision shall develop a written plan (Training Plan) that outlines the steps Good Shepherd Envision will take to ensure that: (a) all Covered Persons receive adequate training regarding Good ShepherdEnvision’s CIA requirements and Compliance Program, including the Code of Conduct and an overview of the Anti-Kickback Statute and how this statute could apply to Envision’s business (General Training) and (b) all Relevant Arrangements Covered Persons receive adequate training regarding: (i) Arrangements that potentially implicate the Federal health care program requirements regarding eligibility for hospice services upon initial admissionAnti-Kickback Statute, recertification for continued stay, as well as the regulations and for Continuous Care, Respite Care, and General Inpatient Careother guidance documents related to this statute; (ii) the role of physicians in making eligibility determinations; (iii) the accurate coding and submission of claims; (iv) Envision’s policies, procedures, and other requirements applicable relating to Arrangements and Focus Arrangements, including but not limited to the documentation Focus Arrangements Tracking System, the internal review and approval process, and the tracking of medical recordsremuneration to and from sources of health care business or referrals required by Section III.D of the CIA; (viii) the personal obligation of each individual involved in the claims submission process development, approval, Envision Corporate Integrity Agreement management, or review of Envision’s Arrangements to ensure that such claims are accurateknow the applicable legal requirements and the Envision’s policies and procedures; (vi) applicable reimbursement statutes, regulations, and program requirements and directives; (viiiv) the legal sanctions for under the Anti-Kickback Statute; and (v) examples of violations of the Federal health care program requirements; and (viii) examples of proper and improper eligibility determinations, documentation, and claims submission practicesAnti-Kickback Statute. The Training Plan shall include information regarding the training topics, the categories identification of Covered Persons and Relevant Arrangements Covered Persons required to attend each training session, the length of the training, the schedule for training, and the format of the training. Within 30 days of the OIG’s receipt of Good ShepherdEnvision’s Training Plan, OIG will notify Good Shepherd Envision of any comments or objections to the Training Plan. Absent notification by the OIG that the Training Plan is unacceptable, Good Shepherd Envision may implement its Training Plan. Good Shepherd Envision shall furnish training to its Covered Persons and Relevant Arrangements Covered Persons pursuant to the Training Plan during each Reporting Period.

Training Plan. Within 90 days after the Effective Date, Good Shepherd UMHS shall develop a written plan (Training Plan) that outlines the steps Good Shepherd UMHS will take to ensure that: (a) all Covered Persons receive adequate training regarding Good ShepherdUMHS’s CIA requirements and Compliance Program, including the Code of Conduct Conduct; and (b) all Relevant appropriate Covered Persons receive adequate training regarding: (i) the Federal health care program requirements regarding eligibility for hospice services upon initial admission, recertification for continued stay, and for Continuous Care, Respite Care, and General Inpatient Care; (ii) the role of physicians in making eligibility determinations; (iii) the accurate coding and submission of claims; (ivii) policies, procedures, and other requirements applicable to the documentation of medical records; (viii) the personal obligation of each individual involved in the claims submission process to ensure that such claims are accurate; (viiv) the personal obligation of each individual involved in the medical records documentation process to ensure that such records are accurate; (v) applicable reimbursement statutes, regulations, and program requirements and directives; (viivi) the legal sanctions for violations of the Federal health care program requirements; (vii) examples of proper and improper claims submission practices; (viii) examples of proper and improper eligibility determinations, documentation, medical record documentation practices; and claims submission practices(ix) the Federal health care program requirements for teaching physician supervision of services rendered by residents. The Training Plan shall include information regarding the training topics, the categories of Covered Persons and Relevant Covered Persons required to attend each training session, the length of the training, the schedule for training, and the format of the training. Within 30 days of the OIG’s receipt of Good ShepherdUMHS’s Training Plan, OIG will notify Good Shepherd UMHS of any comments or objections to the Training Plan. Absent notification by the OIG that the Training Plan is unacceptable, Good Shepherd UMHS may implement its Training Plan. Good Shepherd UMHS shall furnish training to its Covered Persons and Relevant Covered Persons pursuant to the Training Plan during each Reporting Period.

Training Plan. Within 90 days after the Effective Date, Good Shepherd Kindred shall develop a written plan (Training Plan) that outlines the steps Good Shepherd Kindred will take to ensure that: (a) all Covered Persons receive adequate training regarding Good ShepherdKindred’s CIA requirements and Compliance Program, including the Code of Conduct and (b) all Relevant Covered Persons receive adequate training regarding: (i) the Federal health care program requirements regarding eligibility for hospice services upon initial admission, recertification for continued staythe accuracy of the data required under the Minimum Data Set (MDS) as specified by the Resident Assessment Instrument User’s Manual, and for Continuous Care, Respite Care, ensuring appropriate and General Inpatient Careaccurate use of the current Resource Utilization Groups (RUG) classification system; (ii) the role of physicians in making eligibility determinations; (iii) the accurate coding and submission of claims; (iv) policies, procedures, and other requirements applicable to the documentation of medical recordstherapy services; (viii) the coordinated interdisciplinary approach to providing care and the related communications between rehabilitation therapy disciplines and between skilled nursing and skilled rehabilitation therapy; (iv) the personal obligation of each individual involved in the claims submission process provision of therapy services to ensure that a service provided is medically necessary and reasonable given the patient’s condition and treatment plan and meets professionally recognized standards of care; (v) examples of proper and improper rehabilitation RehabCare and Kindred - Corporate Integrity Agreement therapy services, including evaluations and treatment plans; (vi) the personal obligation of each individual involved in the generation and provision of therapy-related information to RehabCare’s external customers to ensure that such claims information is accurate and that such skilled therapy services are accuratecovered when an individualized assessment of the patient’s clinical condition demonstrates that the specialized judgment, knowledge, and skills of a qualified therapist are necessary for the performance of the rehabilitation services; (vivii) applicable reimbursement statutes, regulations, and program requirements and directives; and (viiviii) the reporting obligations and legal sanctions for violations of the Federal health care program requirements; and (viii) examples of proper and improper eligibility determinations, documentation, and claims submission practices. The Training Plan shall include information regarding the training topics, the categories of Covered Persons and Relevant Covered Persons required to attend each training session, the length of the training, the schedule for training, and the format of the training. Within 30 days of the OIG’s receipt of Good ShepherdKindred’s Training Plan, OIG will notify Good Shepherd Kindred of any comments or objections to the Training Plan. Absent notification by the OIG that the Training Plan is unacceptable, Good Shepherd Kindred may implement its Training Plan. Good Shepherd Kindred shall furnish training to its Covered Persons and Relevant Covered Persons pursuant to the Training Plan during each Reporting Period. If Kindred provided training within 90 days prior to the Effective Date that fully satisfies the all the requirements set forth in Section III.C.1 above, except for the requirement of prior approval by OIG, then OIG will credit that training for purposes of satisfying the applicable part of either Kindred’s training and education obligations for the first Reporting Period of the CIA.

Training Plan. Within 90 days after the Effective Date, Good Shepherd Kindred shall develop a written plan (Training Plan) that outlines the steps Good Shepherd Kindred will take to ensure that: (a) all Covered Persons receive adequate training regarding Good ShepherdKindred’s CIA requirements and Compliance Program, including the Code of Conduct and (b) all Relevant Covered Persons receive adequate training regarding: (i) the Federal health care program requirements regarding eligibility for hospice services upon initial admission, recertification for continued staythe accuracy of the data required under the Minimum Data Set (MDS) as specified by the Resident Assessment Instrument User’s Manual, and for Continuous Care, Respite Care, ensuring appropriate and General Inpatient Careaccurate use of the current Resource Utilization Groups (RUG) classification system; (ii) the role of physicians in making eligibility determinations; (iii) the accurate coding and submission of claims; (iv) policies, procedures, and other requirements applicable to the documentation of medical recordstherapy services; (viii) the coordinated interdisciplinary approach to providing care and the related communications between rehabilitation therapy disciplines and between skilled nursing and skilled rehabilitation therapy; (iv) the personal obligation of each individual involved in the claims submission process provision of therapy services to ensure that a service provided is medically necessary and reasonable given the patient’s condition and treatment plan and meets professionally recognized standards of care; (v) examples of proper and improper rehabilitation RehabCare and Kindred - Corporate Integrity Agreement therapy services, including evaluations and treatment plans; (vi) the personal obligation of each individual involved in the generation and provision of therapy- related information to RehabCare’s external customers to ensure that such claims information is accurate and that such skilled therapy services are accuratecovered when an individualized assessment of the patient’s clinical condition demonstrates that the specialized judgment, knowledge, and skills of a qualified therapist are necessary for the performance of the rehabilitation services; (vivii) applicable reimbursement statutes, regulations, and program requirements and directives; and (viiviii) the reporting obligations and legal sanctions for violations of the Federal health care program requirements; and (viii) examples of proper and improper eligibility determinations, documentation, and claims submission practices. The Training Plan shall include information regarding the training topics, the categories of Covered Persons and Relevant Covered Persons required to attend each training session, the length of the training, the schedule for training, and the format of the training. Within 30 days of the OIG’s receipt of Good ShepherdKindred’s Training Plan, OIG will notify Good Shepherd Kindred of any comments or objections to the Training Plan. Absent notification by the OIG that the Training Plan is unacceptable, Good Shepherd Kindred may implement its Training Plan. Good Shepherd Kindred shall furnish training to its Covered Persons and Relevant Covered Persons pursuant to the Training Plan during each Reporting Period. If Kindred provided training within 90 days prior to the Effective Date that fully satisfies the all the requirements set forth in Section III.C.1 above, except for the requirement of prior approval by OIG, then OIG will credit that training for purposes of satisfying the applicable part of either Kindred’s training and education obligations for the first Reporting Period of the CIA.