Common use of Program Compliance Clause in Contracts

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master Agreement. a. The Compliance Plan must include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980). ii. Clearly defined practices that provide for prevention, detection, investigation, and remediation of any compliance related matters. iii. The designation of a compliance officer and a compliance committee that are accountable to senior management; iv. Effective training and education for the compliance officer and the organization’s employees; v. Effective lines of communication between the compliance officer and the organization’s employees; vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting; viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations c. Upon request, PROVIDER will furnish a copy of the compliance plan to MSHN d. PROVIDER agree to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possible, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHP, and to fully cooperate with any investigation by MSHN, its payers and/or the MDHHS or Office of the Attorney General and with any subsequent legal action that may arise from such investigation. e. PROVIDER who is contracting with MSHN as licensed independent practitioner or individual ancillary service PROVIDER agree to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. PROVIDER agrees to immediately notify MSHN’s Compliance Officer with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG).

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan ("Compliance Plan") that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master AgreementMDHHS Contract. a. The Compliance Plan must meet the requirements within the MSHN Compliance Plan and include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s PROVIDER's commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980). ii. Clearly defined practices that provide for prevention, detection, investigation, investigation and remediation of any compliance related matters. iii. The designation of a compliance officer and a compliance committee that are accountable to senior management;. iv. Effective training and education for the compliance officer and the organization’s employees;. v. Effective lines of communication between the compliance officer and the organization’s employees;. vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting;. viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations c. Upon request, PROVIDER will promptly furnish a copy of the compliance plan Compliance Plan to MSHN. d. c. PROVIDER agree agrees to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possible, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHPMSHN, and agrees to fully cooperate with any investigation by MSHN, its payers payors and/or the MDHHS or Office of the Attorney General and with any subsequent legal action that may arise from such investigation. e. d. PROVIDER who is contracting with MSHN as a licensed independent practitioner or an individual ancillary service PROVIDER agree agrees to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. e. PROVIDER agrees to immediately notify MSHN’s Compliance Officer with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG) or the Attorney General. f. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the OIG (Program Integrity Section of the MDHHS Contract). This may include, but is not limited to: i. Identification and investigation of fraud, waste, and abuse, ii. Audits performed, iii. Overpayments collected, iv. Corrective Action Plans implemented, v. Provider dis-enrollments, vi. Contract terminations. g. Annually, PROVIDER must submit a list of subcontracted entities using the template created by MDHHS-OIG. h. PROVIDER must maintain a list that contains all facility locations where services are provided, or business is conducted. This list must contain Billing Provider NPI numbers assigned to the entity, what services the entity is subcontracted to provide, and provider email address(es).

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master Agreement. a. The Compliance Plan must include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980). ii. Clearly defined practices that provide for prevention, detection, investigation, investigation and remediation of any compliance related matters. iii. The designation of a compliance officer and a compliance committee that are accountable to senior management; iv. Effective training and education for the compliance officer and the organization’s employees; v. Effective lines of communication between the compliance officer and the organization’s employees; vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting; viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations c. Upon request, PROVIDER will furnish a copy of the compliance plan to MSHN. d. c. PROVIDER agree agrees to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possible, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHP, and agrees to fully cooperate with any investigation by MSHN, its payers and/or the MDHHS or Office of the Attorney General and with any subsequent legal action that may arise from such investigation. e. d. PROVIDER who is contracting with MSHN as licensed independent practitioner or individual ancillary service PROVIDER agree agrees to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. e. PROVIDER agrees to immediately notify MSHN’s Compliance Officer with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG). f. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Program Integrity Section of the MDHHS/PIHP Master Contract). This may include, but is not limited to: i. Identification and investigation of fraud, waste, and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations g. Annually, the Provider must submit a list of subcontracted entities using the template created by MDHHS-OIG. i. The Provider must maintain a list that contains all facility locations where services are provided, or business is conducted. This list must contain Billing Provider NPI numbers assigned to the entity, what services the entity is subcontracted to provide, and Provider email address(es).

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master Agreement. a. The Compliance Plan must include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980). ii. Clearly defined practices that provide for prevention, detection, investigation, and remediation of any compliance related matters. iii. The designation of a compliance officer and a compliance committee that are accountable to senior management; iv. Effective training and education for the compliance officer and the organization’s employees; v. Effective lines of communication between the compliance officer and the organization’s employees; vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting; viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity Section of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations c. Upon request, PROVIDER will furnish a copy of the compliance plan to MSHN d. PROVIDER agree to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possible, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHP, and to fully cooperate with any investigation by MSHN, its payers and/or the MDHHS or Office of the Attorney General and with any subsequent legal action that may arise from such investigation. e. PROVIDER who is contracting with MSHN as licensed independent practitioner or individual ancillary service PROVIDER agree to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. PROVIDER agrees to immediately notify MSHN’s Compliance Officer with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG).

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master Agreement. a. The Compliance Plan must include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980). ii. Clearly defined practices that provide for prevention, detection, investigation, investigation and remediation of any compliance related matters. iii. The designation of a compliance officer and a compliance committee that are accountable to senior management; iv. Effective training and education for the compliance officer and the organization’s employees; v. Effective lines of communication between the compliance officer and the organization’s employees; vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting; viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations c. Upon request, PROVIDER will furnish a copy of the compliance plan to MSHN. d. c. PROVIDER agree agrees to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possible, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHP, and agrees to fully cooperate with any investigation by MSHN, its payers and/or the MDHHS or Office of the Attorney General and with any subsequent legal action that may arise from such investigation. e. d. PROVIDER who is contracting with MSHN as licensed independent practitioner or individual ancillary service PROVIDER agree agrees to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. e. PROVIDER agrees to immediately notify MSHN’s Compliance Officer with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG). f. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master Agreement. a. The Compliance Plan must include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980). ii. Clearly defined practices that provide for prevention, detection, investigation, investigation and remediation of any compliance related matters. iii. The designation of a compliance officer and a compliance committee that are accountable to senior management; iv. Effective training and education for the compliance officer and the organization’s employees; v. Effective lines of communication between the compliance officer and the organization’s employees; vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting; viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations c. Upon request, PROVIDER will furnish a copy of the compliance plan to MSHN. d. c. PROVIDER agree agrees to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possible, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHP, and agrees to fully cooperate with any investigation by MSHN, its payers and/or the MDHHS or Office of the Attorney General and with any subsequent legal action that may arise from such investigation. e. d. PROVIDER who is contracting with MSHN as licensed independent practitioner or individual ancillary service PROVIDER agree agrees to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. e. PROVIDER agrees to immediately notify MSHN’s Compliance Officer with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG). f. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Program Integrity Section of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master Agreement. a. The Compliance Plan must include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980). ii. Clearly defined practices that provide for prevention, detection, investigation, investigation and remediation of any compliance related matters. iii. The designation of a compliance officer and a compliance committee that are accountable to senior management; iv. Effective training and education for the compliance officer and the organization’s employees; v. Effective lines of communication between the compliance officer and the organization’s employees; vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting; viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on ix. Submission to MSHN of quarterly reports detailing program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: . Program Integrity of the MDHHS/PIHP Master Contract). This may include, activities include but are not limited to: i. 1) Tips/grievances received 2) Data mining and analysis of paid claims, including audits performed based on the results 3) Audits performed 4) Overpayments collected 5) Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected(as these terms are defined in Section 33.0 Program Integrity of the MDHHS/PIHP Master Agreement) iv. 6) Corrective Action Plans Implementedaction plans implemented v. 7) Provider Disdis-Enrollmentsenrollments vi. 8) Contract Terminationsterminations c. b. Upon request, PROVIDER will furnish a copy of the compliance plan to MSHN. d. c. PROVIDER agree agrees to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possible, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHP, abuse and agrees to fully cooperate with any investigation by MSHN, its payers and/or the MDHHS or Office of the Attorney General and with any subsequent legal action that may arise from such investigation. e. d. PROVIDER who is contracting with MSHN as licensed independent practitioner or individual ancillary service PROVIDER agree agrees to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. e. PROVIDER agrees to immediately notify MSHN’s Compliance Officer MSHN with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG).

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master Agreement. a. The Compliance Plan must include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980). ii. Clearly defined practices that provide for prevention, detection, investigation, investigation and remediation of any compliance related matters. iii. The designation of a compliance officer and a compliance committee that are accountable to senior management; iv. Effective training and education for the compliance officer and the organization’s employees; v. Effective lines of communication between the compliance officer and the organization’s employees; vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting; viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations c. Upon request, PROVIDER will furnish a copy of the compliance plan to MSHN. d. c. PROVIDER agree agrees to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possible, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHP, and agrees to fully cooperate with any investigation by MSHN, its payers and/or the MDHHS or Office of the Attorney General and with any subsequent legal action that may arise from such investigation. e. d. PROVIDER who is contracting with MSHN as licensed independent practitioner or individual ancillary service PROVIDER agree agrees to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. e. PROVIDER agrees to immediately notify MSHN’s Compliance Officer with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG). f. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity Section of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master Agreement. a. The Compliance Plan must include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980). ii. Clearly defined practices that provide for prevention, detection, investigation, investigation and remediation of any compliance related matters. iii. The designation of a compliance officer and a compliance committee that are accountable to senior management; iv. Effective training and education for the compliance officer and the organization’s employees; v. Effective lines of communication between the compliance officer and the organization’s employees; vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting; viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations c. Upon request, PROVIDER will furnish a copy of the compliance plan to MSHN. d. c. PROVIDER agree agrees to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possible, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHP, and agrees to fully cooperate with any investigation by MSHN, its payers and/or the MDHHS or Office of the Attorney General and with any subsequent legal action that may arise from such investigation. e. d. PROVIDER who is contracting with MSHN as licensed independent practitioner or individual ancillary service PROVIDER agree agrees to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. PROVIDER agrees to immediately notify MSHN’s Compliance Officer with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG).

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master Agreement. a. The Compliance Plan must meet the requirements within the MSHN Compliance Plan and include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980). ii. Clearly defined practices that provide for prevention, detection, investigation, and remediation of any compliance related matters. iii. The designation of a compliance officer and a compliance committee that are accountable to senior management; iv. Effective training and education for the compliance officer and the organization’s employees; v. Effective lines of communication between the compliance officer and the organization’s employees; vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting; viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity Section of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations c. Upon request, PROVIDER will promptly furnish a copy of the compliance plan to MSHN d. PROVIDER agree to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possible, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHP, and to fully cooperate with any investigation by MSHN, its payers and/or the MDHHS or Office of the Attorney General and with any subsequent legal action that may arise from such investigation. e. PROVIDER who is contracting with MSHN as licensed independent practitioner or individual ancillary service PROVIDER agree to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. PROVIDER agrees to immediately notify MSHN’s Compliance Officer with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG)) or the Attorney General.

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master Agreement. a. The Compliance Plan must include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980). ii. Clearly defined practices that provide for prevention, detection, investigation, investigation and remediation of any compliance related matters. iii. The designation of a compliance officer and a compliance committee that are accountable to senior management; iv. Effective training and education for the compliance officer and the organization’s employees; v. Effective lines of communication between the compliance officer and the organization’s employees; vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting; viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations c. Upon request, PROVIDER will furnish a copy of the compliance plan to MSHN. d. c. PROVIDER agree agrees to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possible, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHP, and agrees to fully cooperate with any investigation by MSHN, its payers and/or the MDHHS or Office of the Attorney General and with any subsequent legal action that may arise from such investigation. e. d. PROVIDER who is contracting with MSHN as licensed independent practitioner or individual ancillary service PROVIDER agree agrees to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. e. PROVIDER agrees to immediately notify MSHN’s Compliance Officer with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG). f. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Program Integrity Section of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan ("Compliance Plan") that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master AgreementMDHHS Contract. a. The Compliance Plan must meet the requirements within the MSHN Compliance Plan and include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s PROVIDER'S commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980).; ii. Clearly defined practices that provide for prevention, detection, investigation, investigation and remediation of any compliance related matters.; iii. The designation of a compliance officer and a compliance committee that are accountable to senior management; iv. Effective training and education for the compliance officer and the organization’s employees; v. Effective lines of communication between the compliance officer and the organization’s employees; vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting;; and viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: Program Integrity of the MDHHS/PIHP Master Contract). This may include, but not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations c. Upon request, PROVIDER will promptly furnish a copy of the compliance plan to MSHN. d. c. PROVIDER agree agrees to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possibleincluding, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHPMSHN, and agrees to fully cooperate with any investigation by MSHN, its payers payors and/or the MDHHS or Office of the Attorney General and with any subsequent legal action that may arise from such investigation. e. d. PROVIDER who is contracting with MSHN as a licensed independent practitioner or an individual ancillary service PROVIDER agree provider agrees to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729-3733), the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. e. PROVIDER agrees to immediately notify MSHN’s Compliance Officer with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG). f. PROVIDER will submit information on program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Program Integrity Section of the MDHHS Contract). This may include, but is not limited to: i. Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans implemented v. Provider dis-enrollments vi. Contract terminations

Program Compliance. PROVIDER shall implement and maintain a compliance and program integrity plan that is designed to guard against fraud and abuse in accordance with federal and state law, including but not limited to 42 CFR 438.608 and as included in the MDHHS/PIHP Master Agreement. a. The Compliance Plan must include, at a minimum, all of the following elements: i. Written policies, procedures and standards of conduct that articulate the organization’s commitment to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 3729- 3729-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005) and the Michigan Whistleblowers Protection Act (PA 469 of 1980). ii. Clearly defined practices that provide for prevention, detection, investigation, investigation and remediation of any compliance related matters. iii. The designation of a compliance officer and a compliance committee that are accountable to senior management; iv. Effective training and education for the compliance officer and the organization’s employees; v. Effective lines of communication between the compliance officer and the organization’s employees; vi. Enforcement of standards through well publicized disciplinary guidelines; vii. Provision for internal monitoring and reporting; viii. Provision for prompt response to detected offenses, and for development of corrective action initiatives. b. PROVIDER will submit information on ix. Submission to MSHN of quarterly reports detailing program integrity activities, when requested, to comply with requirements of the Office of Inspector General (Section 33.0: . Program Integrity of the MDHHS/PIHP Master Contract). This may include, activities include but are not limited to: i. 1) Tips/grievances received 2) Data mining and analysis of paid claims, including audits performed based on the results 3) Audits performed 4) Overpayments collected 5) Identification and investigation of fraud, waste and abuse ii. Audits performed iii. Overpayments collected iv. Corrective Action Plans Implemented v. Provider Dis-Enrollments vi. Contract Terminations c. Upon request, PROVIDER will furnish a copy (as these terms are defined in Section 33.0 Program Integrity of the compliance plan to MSHNMDHHS/PIHP Master Agreement) d. PROVIDER agree to report immediately to the MSHN Compliance Officer any suspicion or knowledge of fraud or abuse, including if possible, the nature of the complaint, the name of the individuals or entity involved in the suspected fraud and abuse, including name, address, phone number, Medicaid identification number and/or any other identifying information. The PROVIDER agrees not to investigate or resolve the alleged fraud and/or abuse, until guidance has been given by the PIHP, and to fully cooperate with any investigation by MSHN, its payers and/or the MDHHS or Office of the Attorney General and with any subsequent legal 6) Corrective action that may arise from such investigation.plans implemented e. PROVIDER who is contracting with MSHN as licensed independent practitioner or individual ancillary service PROVIDER agree to comply with all applicable federal and state standards, including but not limited to the False Claims Act (31 USC 37297) Provider dis-3733, the elimination of fraud and abuse in Medicaid provisions of the Deficit Reduction Act of 2005; and the Michigan Medicaid False Claims Act (PA 72 of 1977, as amended by PA 337 of 2005). The PROVIDER agrees to utilize internal monitoring mechanisms to ensure only valid service claims, free of fraud and abuse, are submitted to MSHN for payment. PROVIDER agrees to immediately report to MSHN any invalid claims for correction and to cooperate with MSHN regarding reclamation of any payments made based upon invalid claims. PROVIDER agrees to implement internal process changes to mitigate the risk of future claims payment issues. f. PROVIDER agrees to immediately notify MSHN’s Compliance Officer with respect to any inquiry, investigation, sanction or otherwise from the Office of Inspector General (OIG).enrollments 8) Contract terminations