Common use of Specific Training Clause in Contracts

Specific Training. Within 120 days after the Effective Date, each Arrangements Covered Person and Government Reimbursement Covered Person shall receive at least three hours of Specific Training, as identified below, in addition to the General Training required above, as follows: a. Arrangements Training for Arrangements Covered Persons shall include a discussion of: i. Arrangements that potentially implicate the Anti- Kickback Statute or the ▇▇▇▇▇ Law, as well as the regulations and other guidance documents related to these statutes; ii. Orthofix’s policies, procedures, and other requirements relating to Arrangements and Focus Arrangements, including but not limited to the Focus Arrangements Tracking System, the internal review and approval process, and the tracking of remuneration to and from sources of health care business or referrals required by Sections III.D.2 and III.D.3 of the CIA; iii. examples of violations of the Anti-Kickback Statute and the ▇▇▇▇▇ Law; iv. the personal obligation of each individual involved in the development, approval, management, or review of Orthofix’s Arrangements to know the applicable legal requirements and Orthofix’s Policies and Procedures; v. the legal sanctions under the Anti-Kickback Statute and the ▇▇▇▇▇ Law; and vi. the possible consequences to both Orthofix and Arrangements Covered Persons of failure to comply with all Federal health care program requirements and with Orthofix’s own Code of Conduct and Policies and Procedures and the failure to report such noncompliance. b. Government Reimbursement Training for Government Reimbursement Covered Persons shall include a discussion of: i. the Federal health care program requirements regarding the accurate submission of claims; ii. examples of proper and improper claims submission practices; iii. policies, procedures, and other requirements applicable to the documentation of medical records; iv. applicable reimbursement statutes, regulations, and program requirements and directives; v. the personal obligation of each individual involved in the claims submission process to ensure that such claims are accurate; vi. the legal sanctions for violations of the Federal health care program requirements; and vii. the possible consequences to both Orthofix and Government Reimbursement Covered Persons of failure to comply with all Federal health care program requirements and with Orthofix’s own Code of Conduct and Policies and Procedures and the failure to report such noncompliance. Each new Arrangements Covered Person and Government Reimbursement Covered Person shall receive the appropriate training, as identified above, within 30 days after the beginning of their employment or becoming an Arrangements Covered Person or Government Reimbursement Covered Person or within 120 days after the Effective Date, whichever is later. An Orthofix employee who has completed the Specific Training shall review a new Arrangements Covered Person’s or Government Reimbursement Covered Person’s work, to the extent that the work relates to an Arrangements Function or a Government Reimbursement Related Function, until such time as the Arrangements Covered Person or Government Reimbursement Covered Person completes his or her Specific Training. After receiving the initial Specific Training described in this Section, each Arrangements Covered Person or Government Reimbursement Covered Person shall receive at least two hours of Specific Training, in addition to the General Training, in each subsequent Reporting Period.

Specific Training. a. Within 120 days after the Effective Date, each Arrangements Relevant Covered Person and Government Reimbursement Covered Person who is involved in the preparation or submission of claims for reimbursement from any Federal health care program shall receive at least three hours of Specific Training, as identified below, Training in addition to the General Training required above, as follows: a. Arrangements . This Specific Training for Arrangements Covered Persons shall include a discussion of: i. Arrangements that potentially implicate the Anti- Kickback Statute or the ▇▇▇▇▇ Law, as well as the regulations and other guidance documents related to these statutes; ii. Orthofix’s policies, procedures, and other requirements relating to Arrangements and Focus Arrangements, including but not limited to the Focus Arrangements Tracking System, the internal review and approval process, and the tracking of remuneration to and from sources of health care business or referrals required by Sections III.D.2 and III.D.3 of the CIA; iii. examples of violations of the Anti-Kickback Statute and the ▇▇▇▇▇ Law; iv. the personal obligation of each individual involved in the development, approval, management, or review of Orthofix’s Arrangements to know the applicable legal requirements and Orthofix’s Policies and Procedures; v. the legal sanctions under the Anti-Kickback Statute and the ▇▇▇▇▇ Law; and vi. the possible consequences to both Orthofix and Arrangements Covered Persons of failure to comply with all Federal health care program requirements and with Orthofix’s own Code of Conduct and Policies and Procedures and the failure to report such noncompliance. b. Government Reimbursement Training for Government Reimbursement Covered Persons shall include a discussion of: i. the Federal health care program programs requirements regarding the accurate coding and submission of claims, including, but not limited to, ensuring the accuracy of the clinical data required under the MDS as specified by the Resident Assessment Instrument User’s Manual, and ensuring appropriate and accurate use of the current Resource Utilization Groups classification system; ii. examples of proper the policies and improper claims submission practicesprocedures implemented pursuant to Section III.B.2; iii. applicable reimbursement statutes, regulations, and program requirements and directives; iv. policies, procedures, and other requirements applicable to the documentation of medical records; iv. applicable reimbursement statutes, regulations, and program requirements and directives; v. the personal obligation of each individual involved in the claims submission process to ensure that such claims are accurate; vi. the legal sanctions for violations of the Federal health care program requirements; and vii. examples of proper and improper claims submission practices. b. Within 120 days after the possible consequences Effective Date, each Relevant Covered Person who is involved directly or indirectly in the delivery of rehabilitation therapy, or performs assessments of residents and/or patients that affect treatment decisions regarding rehabilitation therapy services or that affect reimbursement for rehabilitation therapy, shall receive at least three hours of Specific Training pertinent to both Orthofix their responsibilities in addition to the General Training required above. This Specific Training shall include a discussion of: i. policies, procedures, and Government Reimbursement Covered Persons other requirements applicable to the documentation of failure medical records; ii. the coordinated interdisciplinary approach to comply with all providing care and related communication between disciplines; iii. the policies and procedures implemented pursuant to Section III.B.2; iv. the personal obligation of each individual involved in resident and/or patient care to ensure that care is appropriate and meets professionally recognized standards of care; v. examples of proper and improper care; and vi. legal sanctions for violations of the Federal health care program requirements and with Orthofix’s own Code of Conduct and Policies and Procedures and the failure to report such noncompliancerequirements. Each new Arrangements New Relevant Covered Person and Government Reimbursement Covered Person Persons shall receive the appropriate training, as identified above, this training within 30 days after the beginning of their employment or becoming an Arrangements Relevant Covered Person or Government Reimbursement Covered Person Persons, or within 120 days after the Effective Date, whichever is later. An Orthofix employee who has For purposes of satisfying the initial Specific Training described in this Section, any Relevant Covered Persons, as defined in Section II.C.2 who, during the 120 days prior to the Effective Date of this CIA, received training that meets the requirements for Specific Training shall be considered to have completed the Specific Training shall review a new Arrangements Covered Person’s or Government Reimbursement Covered Person’s work, to the extent that the work relates to an Arrangements Function or a Government Reimbursement Related Function, until such time as the Arrangements Covered Person or Government Reimbursement Covered Person completes his or her Specific Trainingrequirements in Section III.C.2. After receiving the initial Specific Training described in this Sectionsection, each Arrangements Covered Person or Government Reimbursement Relevant Covered Person shall receive at least two three hours of Specific Training, in addition to the General Training, in each subsequent Reporting Period.