Common use of Stipulated Penalties for Failure to Comply with Certain Obligations Clause in Contracts

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, and Appendix C. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Peer Review Consultant, as required in Section III.D. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission. 10. A Stipulated Penalty of $1,500 for each day KDMC fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC fails to grant access.) 11. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 12. A Stipulated Penalty of $1,000 for each day KDMC fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC stating the specific grounds for its determination that KDMC has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC RMC and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC RMC fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; ; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. h. Ineligible Persons screening and removal requirements; j. i. notification of Government investigations or legal proceedings; and k. j. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC RMC fails to engage and use an IRO, as required in Section III.EIII.D, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC RMC fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC RMC fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC RMC fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC RMC fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC RMC as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC RMC fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC RMC stating the specific grounds for its determination that KDMC RMC has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC RMC shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC RMC receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Ensign Group and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Ensign Group fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; of Directors; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. h. Ineligible Persons screening and removal requirements; j. i. notification of Government investigations or legal proceedings; and k. j. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Ensign Group fails to engage and use an IRO, as required in Section III.EIII.D, Appendix A, Appendix B, and Appendix C. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Ensign Group fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Ensign Group fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program MDS Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Therapy Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Assessment Report, or Unallowable Cost Review Report or any response to such report in accordance with the requirements of Section III.D, Section III.E Appendix B, and Appendices B and C by the deadlines for submission.Appendix C. 105. A Stipulated Penalty of $1,500 for each day KDMC Ensign Group fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Ensign Group fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Ensign Group as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Ensign Group fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Ensign Group stating the specific grounds for its determination that KDMC Ensign Group has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Ensign Group shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Ensign Group receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Good Shepherd and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Good Shepherd fails to establish and implement any of the following obligations as described in Section IIISections III and IV: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance management certification obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the development and/or implementation of a Training Plan for the training of Covered Persons, and Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 a risk assessment and III.F.2; internal review process as required by Section III.E; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and; k. policies and procedures regarding the repayment of Overpayments; l. the repayment of Overpayments as required by Section III.I; m. reporting of Reportable Events; and n. disclosure of changes to business units or locations. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Good Shepherd fails to engage and use an IRO, as required in Section III.EIII.D, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Good Shepherd fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Good Shepherd fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC Good Shepherd fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Good Shepherd fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Good Shepherd as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $10,000 (which shall begin to accrue on the day after the date the obligation became due) for each day Good Shepherd fails to cooperate and otherwise satisfy any of the obligations and requirements as described in Section III.K. 8. A Stipulated Penalty of $1,000 for each day KDMC Good Shepherd fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Good Shepherd stating the specific grounds for its determination that KDMC Good Shepherd has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Good Shepherd shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Good Shepherd receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Indivior and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day KDMC Indivior fails to establish and establish, implement or comply with any of the following obligations as described in Section III: a. (a) a Compliance Officer; b. (b) a Compliance Committee; c. (c) the Board NGC compliance obligations and the engagement of Directors compliance obligationsa Compliance Expert, the performance of a Compliance Program Review, and the preparation of a Compliance Program Review Report, as required by Section III.A.3; d. (d) the management certification obligations and the development and implementation of a written Code of Conductprocess for Certifying Employees, as required by Section III.A.4; e. (e) written Policies and Procedures; f. (f) the development of a written training plan and the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, Persons and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 NGC members; (g) a risk assessment and III.F.2; h. mitigation process; (h) a Disclosure Program; i. (i) Ineligible Persons screening and removal requirements; j. (j) the Incentive Compensation Restriction and Financial Recoupment Programs; (k) notification of Government investigations or legal proceedings; and; k. (l) reporting of Reportable Events; (m) notification of written communications with FDA; (n) the FFMP; (o) the NPMP; (p) notification to HCPs and HCIs; and (q) posting of any Payment-related information. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Indivior fails to engage and use an IRO, IRO as required in by Section III.E, Appendix A, Appendix B, III.E and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Indivior fails to engage and use timely submit (a) a Peer Review Consultantcomplete Implementation Report or Annual Report, as required (b) a certification to OIG in accordance with the requirements of Section III.D.V, or (c) a complete response to any request for information from OIG. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Indivior fails to submit the Implementation Report or any Annual Reports to OIG IRO Review report in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC Indivior fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Indivior fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Indivior as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $2,500 for each day Indivior fails to grant the IRO access to all records and personnel necessary to complete the reviews required by Section III.E and for each day Indivior fails to furnish accurate and complete records to the IRO, as required by Section III.E and Appendix A; and 8. A Stipulated Penalty of $1,000 for each day KDMC Indivior fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Indivior stating the specific grounds for its determination that KDMC Indivior has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Indivior shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 business days after KDMC the date Indivior receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 7 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC LHC and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC LHC fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of ConductConduct and Ethics; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; ; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. h. Ineligible Persons screening and removal requirements; j. i. notification of Government investigations or legal proceedings; and k. j. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC LHC fails to engage and use an IRO, as required in Section III.EIII.D, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC LHC fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC LHC fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review ReportInternal Audit Review, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Claims Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC LHC fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC LHC fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC LHC as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC LHC fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC LHC stating the specific grounds for its determination that KDMC LHC has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC LHC shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC LHC receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC GSK and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC GSK fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations, including the resolution from the Board; d. the management accountability and certification obligations; d. e. a written Code of Conduct; e. f. written Policies and Procedures; f. g. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered PersonsManagement, and Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; ; h. a TRACER program; i. a Disclosure Program; i. j. Ineligible Persons screening and removal requirements; j. k. an employee and executive incentive compensation and recoupment program as required by Section III.H and Appendix E; l. notification of Government investigations or legal proceedingsproceedings as required by Section ▇▇▇.▇; and k. GlaxoSmithKline LLC Corporate Integrity Agreement m. reporting of Reportable Events.Events as required in Section III.J; n. notification of written communications with FDA as required by Section III.K; o. a program for FFMP as required by Section III.L; p. a program for Non-Promotional Monitoring Program as required by Section III.M; q. notifications to HCPs, HCIs, and Payers as required by Section III.N; and r. posting of any Payments as required by Section III.O. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC GSK fails to engage and use an IRO, IRO as required in Section III.E, Appendix III.E and Appendices A, Appendix B, and Appendix -C. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC GSK fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Report to OIG in accordance with the requirements of Section III.D.V of the CIA or of Appendix D by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC GSK fails to engage submit any IRO Review report (including the IRO Initial Report) in accordance with the requirements of Sections III.E and use the Physician Executive(s), as required in Section III.A.6.III.V and Appendices A-C. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC GSK fails to engage establish and use a Medical Director implement any of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission. 10. A Stipulated Penalty of $1,500 for each day KDMC fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC fails to grant access.) 11. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 12. A Stipulated Penalty of $1,000 for each day KDMC fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC stating the specific grounds for its determination that KDMC has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC receives this notice from OIG of the failure to comply.) A Stipulated Penalty following obligations as described in this Subsection shall not be demanded for any violation for which OIG has sought Section III of Appendix D: a. a Stipulated Penalty under Subsections 1-11 GMS Compliance Officer; b. a GMS Compliance Committee; c. the Board compliance obligations, including the resolution from GlaxoSmithKline LLC Corporate Integrity Agreement the Board; d. a written Code of this Section.Conduct;

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Progenity and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day KDMC Progenity fails to establish and establish, implement or comply with any of the following obligations as described in Section Sections III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligationsobligations as required by Section III.A.3.; d. the management certification obligations and the development and implementation of a written Code of Conductprocess for Certifying Employees, as required by Section III.A.4; e. written Policies and Procedures; f. the development of a written training plan and the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; members; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 Requirements; h. a risk assessment and III.F.2; h. internal review process; i. a Disclosure Program; i. j. Ineligible Persons screening and removal requirements; j. k. notification of Government investigations or legal proceedings; l. policies and procedures regarding the repayment of Overpayments; and k. m. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Progenity fails to engage and use an IRO, as required in by Section III.E, Appendix A, Appendix B, and or Appendix C. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Progenity fails to engage and use timely submit (a) a Peer Review Consultantcomplete Implementation Report or Annual Report, as required (b) a certification to OIG in accordance with the requirements of Section III.D.V, or (c) a complete response to any request for information from OIG. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Progenity fails to engage submit any Arrangements Review Report in accordance with the requirements of Section III.E and use the Physician Executive(s), as required in Section III.A.6.Appendix B. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Progenity fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and Appendix C or fails to repay any Overpayment identified by the deadlines for submission.IRO as required by Appendix C. 106. A Stipulated Penalty of $1,500 for each day KDMC Progenity fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Progenity fails to grant access.) 117. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Progenity as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 128. A Stipulated Penalty of $2,500 for each day Progenity fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.E., and for each day Progenity fails to furnish accurate and complete records to the IRO, as required by Section III.E and Appendix A. 9. A Stipulated Penalty of $1,000 for each day KDMC Progenity fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Progenity stating the specific grounds for its determination that KDMC Progenity has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Progenity shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 business days after KDMC the date Progenity receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 8 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC CHSI and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CHSI fails to establish and implement any of the following obligations as described in Section III: a. a Corporate Compliance and Privacy Officer, Corporate Compliance Directors, and/or Facility Compliance Officers; b. a Corporate Compliance CommitteeWork Group; and/or Facility Compliance Committees; c. the Board of Directors compliance obligations;; Community Health Systems, Inc. Corporate Integrity Agreement d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; ; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. h. Ineligible Persons screening and removal requirements; j. i. notification of Government investigations or legal proceedings; and k. j. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CHSI fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CHSI fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CHSI fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Inpatient Medical Necessity and Appropriateness Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Unallowable Cost Review Report, or Unallowable Cost Arrangements Review Report in accordance with the requirements of Section III.DIII.E, Section III.E Appendix B, and Appendices B and C by the deadlines for submission.Appendix C. 105. A Stipulated Penalty of $1,500 for each day KDMC CHSI fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC CHSI fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC CHSI as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.. Community Health Systems, Inc. Corporate Integrity Agreement 127. A Stipulated Penalty of $1,000 for each day KDMC CHSI fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC CHSI stating the specific grounds for its determination that KDMC CHSI has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC CHSI shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC CHSI receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC the Friendship Entities and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails the Friendship Entities fail to establish and implement any of the following obligations as described in Section IIISections III and IV: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations and the engagement of a Compliance Expert, the performance of a Compliance Program Review and the preparation of a Compliance Program Review Report, as required by Section III.A.3.; d. the management certification obligations; d. e. a written Code of Conduct; e. f. written Policies and Procedures; f. g. the development and/or implementation of a Training Plan for the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, ; h. a risk assessment and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. internal review process as required by Section III.E; i. a Disclosure Program; i. j. Ineligible Persons screening and removal requirements; j. k. notification of Government investigations or legal proceedings; l. policies and procedures regarding the repayment of Overpayments; m. the repayment of Overpayments as required by Section III.I and Appendix B; and k. n. reporting of Reportable Events; and o. disclosure of changes to business units or locations. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails the Friendship Entities fail to engage and use an IRO, as required in by Section III.EIII.D, Appendix A, or Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails the Friendship Entities fail to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails Friendship Entities fail to submit the Implementation Report any Claims Review or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Additional Items Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC fails the Friendship Entities fail to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC fails the Friendship Entities fail to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC the Friendship Entities as part of its their Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC fails the Friendship Entities fail to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC the Friendship Entities stating the specific grounds for its determination that KDMC has the Friendship Entities have failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC the Friendship Entities shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC receives the date the Friendship Entities receive this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC LCPCC and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC LCPCC fails to establish and establish, implement or comply with any of the following obligations as described in Section III: a. post a Compliance Officer;notice in accordance with the requirements of Section III.A;‌ b. a Compliance Committee;complete the training required for LCPCC and Covered Persons and maintain training records, in accordance with the requirements of Section III.B;‌ c. screen Covered Persons in accordance with the Board requirements of Directors compliance obligationsSection III.D; require Covered Persons to disclose if they‌ are excluded in accordance with the requirements of Section III.D; or maintain copies of print screens from search results to demonstrate the required screening has been performed in accordance with the requirements of Section III.D; d. notify OIG of a written Code government investigation or legal proceeding, in accordance with the requirements of Conduct;Section III.E;‌ e. written Policies repay any Overpayments as required by Section III.F and Procedures;Appendix B; or‌ f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described report a Reportable Event in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events.accordance with Section III.G.‌ 2. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC LCPCC fails to engage and use an IRO, as required in by Section III.EIII.C, Appendix A, or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC LCPCC fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC LCPCC fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quarterly Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.C and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B.‌ 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC LCPCC fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC LCPCC fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC LCPCC as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIA.IA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC fails LCPCCfails to comply fully grant the IRO access to all records and adequately with any obligation of this CIA. OIG shall provide notice personnel necessary to KDMC stating complete the specific grounds for its determination that KDMC has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 of this Section.reviews listed in‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC the DIG Entities and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC the DIG Entities fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors Directors’ compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive ManagementRelevant Covered Persons; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 III.D.1 and III.F.2III.D.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC the DIG Entities fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, and Appendix C. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC the DIG Entities fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC DIG Entities fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program annual Arrangements Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Claims Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.DIII.E, Section III.E Appendix B, and Appendices B and C by the deadlines for submission.Appendix C. 105. A Stipulated Penalty of $1,500 for each day KDMC the DIG Entities fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC the DIG Entities fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC the DIG Entities as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC fails the DIG Entities fail to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC the DIG Entities stating the specific grounds for its determination that KDMC the DIG Entities has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC the DIG Entities shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the DIG Entities receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC the GIS Parties and OIG hereby agree that failure to to‌‌ comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails the GIS Parties fail to establish and establish, implement or comply with any of the following obligations as described in Section Sections III: a. a Compliance Officer;Officers;‌ b. a Compliance Committee;Committees;‌ c. the Board Boards of Directors Directors’ compliance obligations;obligations;‌ d. a written Code of Conduct;the management certification obligations;‌ e. written Policies and Procedures;Procedures;‌ f. the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; Members;‌ g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; Requirements;‌ h. a Disclosure Program;risk assessment and internal review process;‌ i. a Disclosure Program;‌ j. Ineligible Persons screening and removal requirements;requirements;‌ j. k. notification of Government investigations or legal proceedingsproceedings;‌‌‌ l. policies and procedures regarding the repayment of Overpayments; andand‌ k. m. reporting of Reportable Events.Events.‌ 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails the GIS Parties fail to engage and use an IRO, as required in by Section III.E, Appendix A, or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails the GIS Parties fail to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails GIS Parties fail to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B.‌ 105. A Stipulated Penalty of $1,500 for each day KDMC fails the GIS Parties fail to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC fails the GIS Parties fail to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC the GIS Parties as part of its their Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC fails the GIS Parties fail to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC the GIS Parties stating the specific grounds for its determination that KDMC has the GIS Parties have failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC the GIS Parties shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC receives the date the GIS Parties receive this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC PHC and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC PHC fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 III.D.1 and III.F.2III.D.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC PHC fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC PHC fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC PHC fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems annual Arrangements Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC PHC fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC PHC fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC PHC as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC PHC fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC PHC stating the specific grounds for its determination that KDMC PHC has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC PHC shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC PHC receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC T▇▇▇▇ and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC T▇▇▇▇ fails to establish and implement any of the following obligations as described in Section III: a. a Chief Compliance Officer; b. a Regional Compliance Officers; c. Hospital Compliance Officers; d. Ethics and Compliance Department; e. Clinical Quality Department; f. Corporate Compliance Committee; c. g. Regional and Hospital Compliance Committees; h. Quality, Compliance, and Ethics Committee of the Board of Directors compliance obligationsDirectors; d. a written Code of Conduct; e. i. written Policies and Procedures; f. the ; j. training of Covered Persons, Relevant Billing and Reimbursement Covered Persons, Arrangements Covered Persons, Board Members, and Executive ManagementClinical Quality Covered Persons; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. k. a Disclosure Program; i. l. Ineligible Persons screening and removal requirements;; and j. notification m. Notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC T▇▇▇▇ fails to engage and use an IRO, as required in Section III.E, Appendix III.D and Appendices A, Appendix B, and Appendix C.-E. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC T▇▇▇▇ fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or the Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC T▇▇▇▇ fails to submit the Implementation Report or any Annual IRO Review Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.A-E. 105. A Stipulated Penalty of $1,500 for each day KDMC T▇▇▇▇ fails to grant access to the information or documentation as required in Section VIIVII or any other provision under the CIA. (This Stipulated Penalty shall begin to accrue on the date KDMC T▇▇▇▇ fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC T▇▇▇▇ as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC T▇▇▇▇ fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC T▇▇▇▇, stating the specific grounds for its determination that KDMC T▇▇▇▇ has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC T▇▇▇▇ shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC T▇▇▇▇ receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC DaVita and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC DaVita fails to establish and implement any of the following obligations as described in Section IIISections III and IV: a. a Chief Compliance Officer; b. a Management Compliance Committee; c. the Board of Directors compliance obligations;; DaVita HealthCare Partners Inc. Corporate Integrity Agreement d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; ; g. the Selection Process and Selection Criteria, Valuation Methodologies, Focus Arrangements Procedures Procedures, and/or Focus Arrangements Requirements described in Sections III.F.1 Section III.D; h. the Notice to Joint Venture Partners and III.F.2; h. Medical Directors; i. the unwinding of the Subject Joint Venture Clinics, except to the extent covered by a Monitor’s certification as described in Section III.F.3; j. the Executive Financial Recoupment Program; k. the Compliance Input on Executive Compensation; l. a Disclosure Program; i. m. Ineligible Persons screening and removal requirements; j. n. notification of Government government investigations or legal proceedings; andproceedings in the United States; k. o. repayment by DaVita Dialysis of Overpayments; p. reporting of Reportable Events; and q. disclosure of changes to business units or locations. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC DaVita fails to engage and use an IROa Compliance Advisor, as required in Section III.E, Appendix A, Appendix B, III.A.3 and Appendix C.A. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC DaVita fails to engage and use a Peer Review Consultantan Independent Monitor, as required in Section III.D.III.G and Appendix C. DaVita HealthCare Partners Inc. Corporate Integrity Agreement 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC DaVita fails to engage and use submit the Physician Executive(s), as required Implementation Report or any Quarterly Response Reports or Annual Reports to OIG in accordance with the requirements of Section III.A.6V by the deadlines for submission. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC DaVita fails to engage submit a Compliance Program Review Report in accordance with the requirements of Section III.A.3 and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7.Appendix A. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Independent Monitor fails to submit the Implementation Report a Quarterly or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E III.G and Appendices B and C by the deadlines for submission.Appendix C. 107. A Stipulated Penalty of $1,500 for each day KDMC DaVita fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC DaVita fails to grant access.) 118. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC DaVita as part of its Implementation Report, Quarterly Response Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 129. A Stipulated Penalty of $1,000 for each day KDMC DaVita fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC DaVita stating the specific grounds for its determination that KDMC DaVita has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC DaVita shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC DaVita receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1–8 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Amedisys and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Amedisys fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors and Covered Administrators compliance obligations; d. a written Code of Conduct;; Amedisys, Inc. and Amedisys Holding, LLC Corporate Integrity Agreement e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; ; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; REM Program; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Amedisys fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Amedisys fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Amedisys fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Claims Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements REM Program Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC Amedisys fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Amedisys fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Amedisys as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.. Amedisys, Inc. and Amedisys Holding, LLC Corporate Integrity Agreement 127. A Stipulated Penalty of $1,000 for each day KDMC Amedisys fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Amedisys stating the specific grounds for its determination that KDMC Amedisys has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Amedisys shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Amedisys receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC CSI and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CSI fails to establish and establish, implement or comply with any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conductthe management certification obligations; e. written Policies and Procedures; f. the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, Persons and Executive Management; members of the Board; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 annual budget plan and III.F.2; needs assessment processes for Consulting Activities; h. a risk assessment and internal review process; i. a Disclosure Program; i. j. Ineligible Persons screening and removal requirements; j. k. notification of Government investigations or legal proceedings; and; k. l. the Field Force Monitoring Program; m. reporting of Reportable Events; n. Co-Marketing Activities Requirements; and o. Reporting of Physician Payments requirements. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CSI fails to engage and use an IRO, as required in by Section III.E, Appendix A, or Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CSI fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CSI fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Transactions Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC CSI fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC CSI fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC CSI as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC CSI fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC CSI stating the specific grounds for its determination that KDMC CSI has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC CSI shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date CSI receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC FHG and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC FHG fails to establish and establish, implement or comply with any of the following obligations as described in Section III: a. appoint a Compliance Officer;Officer as required by Section III.A;‌ b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures;Procedures required by Section III.B;‌ c. post a notice in accordance with the requirements of Section III.C;‌ d. complete the training required for Covered Persons and maintain training records, in accordance with the requirements of Section III.D;‌ e. screen Covered Persons in accordance with the requirements of Section III.F or require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.F; and maintain documentation of screening and disclosure requirements in accordance with the requirements of Section III.F;‌ f. notify OIG of a government investigation or legal proceeding, in accordance with the training requirements of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, Section III.G;‌‌ g. establish policies and Executive Management; g. procedures regarding the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 repayment of Overpayments;‌ h. repay any Overpayments as required by Section III.H and III.F.2; h. a Disclosure Program;Appendix B;‌ i. Ineligible Persons screening and removal requirements;report a Reportable Event in accordance with Section III.I; or‌ j. notification provide to OIG the certifications required by Section III.J relating to any third party ▇▇▇▇▇▇ engaged by FHG during the term of Government investigations or legal proceedings; and k. reporting of Reportable Events.the IA.‌ 2. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC FHG fails to engage and use an IRO, as required in by Section III.E, Appendix A, A or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC FHG fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC FHG fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quarterly Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B.‌ 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC FHG fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC FHG fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC FHG as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIA.IA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC FHG fails to comply fully and adequately with any obligation of this CIAIA. OIG shall provide notice to KDMC FHG stating the specific grounds for its determination that KDMC FHG has failed to comply fully and adequately with the CIA IA obligation(s) at issue and steps KDMC the FHG shall take to comply with the CIAIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date FHG receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.Section.‌‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC CVS and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CVS fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. d. written Policies and Procedures; f. e. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. ; f. a Disclosure Program; i. g. Ineligible Persons screening and removal requirements;; and CVS Caremark Corporate Integrity Agreement j. notification h. Notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CVS fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, III.D and Appendix C.A. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CVS fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or the Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CVS fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Government Reimbursement Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC CVS fails to grant access to the information or documentation as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC CVS fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC CVS as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC CVS fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC CVS, stating the specific grounds for its determination that KDMC CVS has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC CVS shall take to comply with the this CIA. (This Stipulated Penalty shall begin to accrue 10 ten (10) days after KDMC CVS receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Forest and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Forest fails to establish and implement establish, implement, or accomplish any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. a resolution from the Board of Directors compliance obligationsDirectors; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; ; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. h. Ineligible Persons screening and removal requirements; j. i. notification of Government investigations or legal proceedings; and; k. j. reporting of Reportable Events.; k. notification of written communications with FDA; l. a Field Force Monitoring Program as required by III.J; m. a Non-Promotional Monitoring Program as required by III.K; n. notification of HCPs and HCIs as required by Section III.L; and o. posting of any Payments as required by Section 111.M. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Forest fails to engage and use an IRO, a Compliance Expert as required in Section III.E, Appendix III.A.3 or an IRO as required in Section III.D and Appendices A, Appendix B, and Appendix C.-B. 3. A Stipulated Penalty of $2,500 ({which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Forest fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or the Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Forest fails to submit the Implementation Report or any Annual Reports to OIG annual IRO Review Report(s) in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E MD and Appendices B and C by the deadlines for submission.A-B. 105. A Stipulated Penalty of $1,500 for each day KDMC Forest fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Forest fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC Forest as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Forest fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Forest, stating the specific grounds for its determination that KDMC Forest has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Forest shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Forest receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Lundbeck and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions.provisions.‌ 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Lundbeck fails to establish and establish,‌ implement or comply with any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conductthe management certification obligations; e. written Policies and Procedures; f. the development of a written training plan and the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Persons and Board Members, ; g. a risk assessment and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; internal review process; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and; k. reporting of Reportable Events; and l. the Independent Charity PAP policies, procedures, and practices required by Section ▇▇▇.▇. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Lundbeck fails to engage and use an IRO, IRO as required in by Section III.E, Appendix A, or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Lundbeck fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Lundbeck fails to submit the Implementation Report or any Annual Reports to OIG IRO Review report in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B.‌ 105. A Stipulated Penalty of $1,500 for each day KDMC Lundbeck fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Lundbeck fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Lundbeck as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 127. A Stipulated Penalty of $2,500 for each day Lundbeck fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.E, and for each day Lundbeck fails to furnish accurate and complete records to the IRO, as required by Section III.E and Appendix A.‌ 8. A Stipulated Penalty of $1,000 for each day KDMC Lundbeck fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Lundbeck stating the specific grounds for its determination that KDMC Lundbeck has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Lundbeck shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date Lundbeck receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 7 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC PGS and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC PGS fails to establish and establish, implement or comply with any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. the engagement of a written Code Compliance Expert, the performance of Conducta Compliance Program Review and the preparation of a Compliance Program Review Report, as required by Section III.A.3; e. the management certification obligations; f. written Policies and Procedures; f. the g. training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Persons and Board Members, ; h. a risk assessment and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. internal review process; i. a Disclosure Program; i. j. Ineligible Persons screening and removal requirements; j. k. notification of Government investigations or legal proceedings; l. policies and procedures regarding the repayment of Overpayments; and k. m. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC PGS fails to engage and use an IRO, as required in by Section III.EIII.D, Appendix A, or Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC PGS fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC PGS fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC PGS fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC PGS fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC PGS as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC PGS fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC PGS stating the specific grounds for its determination that KDMC PGS has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC PGS shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date PGS receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Rotech and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Rotech fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. d. written Policies and Procedures; f. e. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. ; f. a Disclosure Program; i. g. Ineligible Persons screening and removal requirements;; and j. h. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Rotech fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, III.D and Appendix C.A. Rotech Healthcare Inc. Corporate Integrity Agreement 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Rotech fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Rotech fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC Rotech fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Rotech fails to grant access.) 116. A Stipulated Penalty of $50,000 20,000 for each false certification submitted by or on behalf of KDMC Rotech as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $2,500 for each day Rotech fails to comply with the Board of Directors resolution obligations as required by Section III.A.3; 8. A Stipulated Penalty of $1,000 for each day KDMC Rotech fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Rotech stating the specific grounds for its determination that KDMC Rotech has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Rotech shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Rotech receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC Toccoa and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions.provisions.‌‌ 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Toccoa fails to establish and implement any of the following obligations as described in Section IIISections III and IV: a. a Compliance Officer;Officer;‌ b. a Compliance Committee;Committee;‌ c. the Board of Directors Executive Committee compliance obligations;obligations;‌ d. the management certification obligations;‌ e. a written Code of Conduct;Conduct;‌ e. f. written Policies and Procedures;Procedures;‌ f. g. the development and/or implementation of a Training Plan for the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; Members;‌‌ h. a Disclosure Program;risk assessment and internal review process as required by Section III.E;‌ i. a Disclosure Program;‌ j. Ineligible Persons screening and removal requirements;requirements;‌ j. k. notification of Government investigations or legal proceedings; andproceedings;‌ k. l. policies and procedures regarding the repayment of Overpayments;‌ m. the repayment of Overpayments as required by Section III.I and Appendix B;‌ n. reporting of Reportable Events.; and‌ o. disclosure of changes to business units or locations or of new employment or contractual arrangements.‌ 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Toccoa fails to engage and use an IRO, as required in by Section III.EIII.D, Appendix A, or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Toccoa fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Toccoa fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B.‌ 105. A Stipulated Penalty of $1,500 for each day KDMC Toccoa fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Toccoa fails to grant access.)access.)‌‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Toccoa as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC Toccoa fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Toccoa stating the specific grounds for its determination that KDMC Toccoa has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Toccoa shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date Toccoa receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC CBHA and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CBHA fails to establish and establish, implement or comply with any of the following obligations as described in Section III: a. appoint a Compliance Officer;Officer as required by Section III.A;‌ b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures;Procedures required by Section III.B;‌ c. post a notice in accordance with the requirements of Section III.C;‌ d. complete the training required for Covered Persons and maintain training records, in accordance with the requirements of Section III.D;‌ e. screen Covered Persons in accordance with the requirements of Section III.F; require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.F; or maintain copies of print screens from search results‌ to demonstrate the required screening has been performed in accordance with the requirements of Section III.F;‌‌ f. notify OIG of a government investigation or legal proceeding, in accordance with the training requirements of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, Section III.G;‌ g. establish policies and Executive Managementprocedures regarding the repayment of Overpayments;‌ h. repay any Overpayments as required by Section III.H and Appendix B; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program;or‌ i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of report a Reportable Events.Event in accordance with Section III.I.‌ 2. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CBHA fails to engage and use an IRO, as required in by Section III.E, Appendix A, A or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CBHA fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CBHA fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quarterly Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B.‌ 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC CBHA fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC CBHA fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC CBHA and/or ▇▇. ▇▇▇▇▇▇ ▇▇▇▇ as part of its the Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIA.IA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC CBHA fails to comply fully grant the IRO access to all records and adequately with any obligation of this CIA. OIG shall provide notice personnel necessary to KDMC stating complete the specific grounds for its determination that KDMC has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 of this Section.reviews listed in‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC eTEL-Rx and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC eTEL-Rx fails to establish and implement any of the following obligations as described in Section III:: eTEL-Rx Corporate Integrity Agreement a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. c. written Policies and Procedures; f. d. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. ; e. a Disclosure Program; i. f. Ineligible Persons screening and removal requirements; j. g. notification of Government investigations or legal proceedings; and k. h. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC eTEL-Rx fails to engage and use an IRO, as required in Section III.EIII.D, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC eTEL-Rx fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC eTEL-Rx fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC eTEL-Rx fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC eTEL-Rx fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC eTEL-Rx as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.. eTEL-Rx Corporate Integrity Agreement 127. A Stipulated Penalty of $1,000 for each day KDMC eTEL-Rx fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC eTEL-Rx stating the specific grounds for its determination that KDMC eTEL-Rx has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC eTEL-Rx shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC eTEL-Rx receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC ▇▇▇▇▇ ▇▇▇▇▇▇▇▇ and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day ▇▇▇▇▇ Pharmacy fails to establish, implement or comply with any of the following obligations as described in Section III: a. post a notice in accordance with the requirements of Section III.A; b. complete the training required for ▇▇▇▇▇ Pharmacy and Covered Persons and maintain training records, in accordance with the requirements of Section III.B; c. screen Covered Persons in accordance with the requirements of Section III.D; require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.D; or maintain copies of print screens from search results to demonstrate the required screening has been performed in accordance with the requirements of Section III.D; d. notify OIG of a government investigation or legal proceeding, in accordance with the requirements of Section III.E; e. repay any Overpayments as required by Section III.F and Appendix B; f. report a Reportable Event in accordance with Section III.G; or g. provide to OIG the certifications required by Section III.H relating to any third-party ▇▇▇▇▇▇ engaged by ▇▇▇▇▇ ▇▇▇▇▇▇▇▇ during the term of the IA. 2. A Stipulated Penalty of $1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ▇▇▇▇▇ Pharmacy fails to establish engage and implement any of the following obligations use an IRO, as described in required by Section III:III.C, Appendix A, or Appendix B. a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 23. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ▇▇▇▇▇ Pharmacy fails to engage and use an IROtimely submit (a) a complete Implementation Report or Annual Report, as required (b) a certification to OIG in accordance with the requirements of Section III.EV, Appendix A, Appendix B, and Appendix C.or (c) a complete response to any request for information from OIG. 34. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Peer Review Consultant, as required in Section III.D. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ▇▇▇▇▇ Pharmacy fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quarterly Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.C and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B. 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC ▇▇▇▇▇ Pharmacy fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC ▇▇▇▇▇ Pharmacy fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC ▇▇▇▇▇ ▇▇▇▇▇▇▇▇ as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIAIA. 127. A Stipulated Penalty of $1,000 for each day KDMC ▇▇▇▇▇ Pharmacy fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.C, and for each day ▇▇▇▇▇ Pharmacy fails to furnish accurate and complete records to the IRO, as required by Section III.C and Appendix A. 8. A Stipulated Penalty of $1,000 for each day ▇▇▇▇▇ Pharmacy fails to comply fully and adequately with any obligation of this CIAIA. OIG shall provide notice to KDMC ▇▇▇▇▇ Pharmacy stating the specific grounds for its determination that KDMC ▇▇▇▇▇ ▇▇▇▇▇▇▇▇ has failed to comply fully and adequately with the CIA IA obligation(s) at issue and steps KDMC the ▇▇▇▇▇ Pharmacy shall take to comply with the CIAIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date ▇▇▇▇▇ ▇▇▇▇▇▇▇▇ receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC Golden and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day Golden fails to establish, implement or comply with any of the following obligations as described in Section III: a. appoint a Compliance Officer and a Chief Clinical Officer as required by Section III.A;‌ b. written Policies and Procedures required by Section III.B;‌ c. post a notice in accordance with the requirements of Section III.C;‌ d. complete the training required for Covered Persons and maintain training records, in accordance with the requirements of Section III.D;‌ e. screen Covered Persons in accordance with the requirements of Section III.F; require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.F; or maintain copies of print screens from search results to demonstrate the required screening has been performed in accordance with the requirements of Section III.F;‌ f. notify OIG of a government investigation or legal proceeding, in accordance with the requirements of Section III.G;‌ g. establish policies and procedures regarding the repayment of Overpayments;‌ h. repay any Overpayments as required by Section III.H and Appendix B;‌ i. report a Reportable Event in accordance with Section III.I; or‌ j. provide to OIG the certifications required by Section III.J relating to any third-party ▇▇▇▇▇▇ engaged by Golden during the term of the IA.‌ 2. A Stipulated Penalty of $1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Golden fails to establish engage and implement any of the following obligations use an IRO, as described in required by Section III:III.E, Appendix A or Appendix B.‌ a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 23. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Golden fails to engage and use an IROtimely submit‌ (a) a complete Implementation Report or Annual Report, as required (b) a certification to OIG in accordance with the requirements of Section III.EV, Appendix A, Appendix B, and Appendix C.or (c) a complete response to any request for information from OIG. 34. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Peer Review Consultant, as required in Section III.D. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Golden fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quarterly Claims Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B.‌ 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC Golden fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Golden fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Golden as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIA.IA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC Golden fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.E, and for each day Golden fails to furnish accurate and complete records to the IRO, as required by Section III.E and Appendix A.‌ 8. A Stipulated Penalty of $1,000 for each day Golden fails to comply fully and adequately with any obligation of this CIAIA. OIG shall provide notice to KDMC Golden stating the specific grounds for its determination that KDMC Golden has failed to comply fully and adequately with the CIA IA obligation(s) at issue and steps KDMC the Golden shall take to comply with the CIAIA. (This Stipulated Penalty shall begin to accrue 10 business days after KDMC the date Golden receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC InterMune and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC InterMune fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. d. written Policies and Procedures; f. e. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. ; f. a Disclosure Program; i. g. Ineligible Persons screening and removal requirements; j. notification h. Notification of Government investigations or legal proceedings; i. notification of communications regarding off-label related matters; and k. reporting j. a review of Reportable Eventsrecords reflecting the content of detailing sessions. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC InterMune fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, III.D and Appendix C.Appendices A and B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC InterMune fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or the Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC InterMune fails to submit the Implementation annual Report or associated with any Annual Reports to OIG of the Reviews in accordance with the requirements of Section V by the deadlines for submission.III.D and Appendix B. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission. 105. A Stipulated Penalty of $1,500 for each day KDMC InterMune fails to grant access to the information or documentation as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC InterMune fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC InterMune as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC InterMune fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC InterMune, stating the specific grounds for its determination that KDMC InterMune has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC InterMune shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC InterMune receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC ▇▇▇▇▇▇ and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ▇▇▇▇▇▇ fails to establish and implement any of the following obligations as described in Section IIIto: a. post a Compliance Officer;notice in accordance with the requirements of Section III.A;‌ b. a Compliance Committee;complete the training required for ▇▇▇▇▇▇ and Covered Persons and maintain training records, in accordance with the requirements of Section III.B;‌ c. screen Covered Persons in accordance with the Board requirements of Directors compliance obligations;Section III.D; or require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.D; and maintain documentation of screening and disclosure requirements in accordance with the requirements of Section III.D;‌ d. notify OIG of a written Code government investigation or legal proceeding, in accordance with the requirements of Conduct;Section III.E;‌ e. written Policies repay any Overpayments as required by Section III.F and Procedures;Appendix B; or‌ f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described report a Reportable Event in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events.accordance with Section III.G.‌ 2. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ▇▇▇▇▇▇ fails to engage and use an IRO, as required in by Section III.EIII.C, Appendix A, or Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ▇▇▇▇▇▇ fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌‌‌ 4. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ▇▇▇▇▇▇ fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quarterly Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.C and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B.‌ 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC ▇▇▇▇▇▇ fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC ▇▇▇▇▇▇ fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC ▇▇▇▇▇▇ as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIA.IA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC ▇▇▇▇▇▇ fails to comply fully and adequately with any obligation of this CIAIA. OIG shall provide notice to KDMC ▇▇▇▇▇▇ stating the specific grounds for its determination that KDMC ▇▇▇▇▇▇ has failed to comply fully and adequately with the CIA IA obligation(s) at issue and steps KDMC the ▇▇▇▇▇▇ shall take to comply with the CIAIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date ▇▇▇▇▇▇ receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Maximus and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Maximus fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. d. written Policies and Procedures; f. e. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. ; f. a Disclosure Program; i. g. Ineligible Persons screening and removal requirements;; and j. h. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Maximus fails to engage and use pay an IRO, invoice of OAS within 30 days of the receipt from OAS as required in Section III.E, Appendix A, Appendix B, and Appendix C.III.D. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Maximus fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Maximus fails to engage and use the Physician Executive(s), as required notify affected parties of a Potential Problem with Consulting Contract in accordance with requirements of Section III.A.6.III.H 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Maximus fails to submit the Implementation Report or any Annual Reports to OIG annual Consulting Contract Review in accordance with the requirements of Section V by the deadlines for submission.III.D. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission. 106. A Stipulated Penalty of $1,500 for each day KDMC Maximus fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Maximus fails to grant access.) 117. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC Maximus as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 128. A Stipulated Penalty of $1,000 for each day KDMC Maximus fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Maximus stating the specific grounds for its determination that KDMC Maximus has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Maximus shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Maximus receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC I&L and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC I&L fails to establish and establish, implement or comply with any of the following obligations as described in Section III: a. post a Compliance Officer;notice in accordance with the requirements of Section III.A;‌ b. a Compliance Committee;complete the training required for I&L and Covered Persons and maintain training records, in accordance with the requirements of Section III.B;‌ c. screen Covered Persons in accordance with the Board requirements of Directors compliance obligations;Section III.D; require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.D; or maintain copies of print screens from search results to demonstrate the required screening has been performed in accordance with the requirements of Section III.D;‌ d. notify OIG of a written Code government investigation or legal proceeding, in accordance with the requirements of Conduct;Section III.E;‌ e. written Policies repay any Overpayments as required by Section III.F and Procedures;Appendix B;‌ f. report a Reportable Event in accordance with Section III.G; or‌ g. provide to OIG the training certifications required by Section III.H relating to any third party ▇▇▇▇▇▇ engaged by I&L during the term of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events.IA.‌ 2. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC I&L fails to engage and use an IRO, as required in by Section III.EIII.C, Appendix A, or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC I&L fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC I&L fails to submit the Implementation any Quarterly Claims Review Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quarterly Drug Inventory Review Report in accordance with the requirements of Section III.D, Section III.E III.C and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B.‌ 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC I&L fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC I&L fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC I&L as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIA.IA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC I&L fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.C, and for each day I&L fails to furnish accurate and complete records to the IRO, as required by Section III.C and Appendix A.‌ 8. A Stipulated Penalty of $1,000 for each day I&L fails to comply fully and adequately with any obligation of this CIAIA. OIG shall provide notice to KDMC I&L‌ stating the specific grounds for its determination that KDMC I&L has failed to comply fully and adequately with the CIA IA obligation(s) at issue and steps KDMC the I&L shall take to comply with the CIAIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date I&L receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Mid ▇▇▇▇▇▇ and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Mid ▇▇▇▇▇▇ fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; ; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. h. Ineligible Persons screening and removal requirements; j. i. notification of Government government investigations or legal proceedings; and k. j. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Mid ▇▇▇▇▇▇ fails to engage and use an IRO, as required in Section III.EIII.D, Appendix A, Appendix B, and Appendix C. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Mid ▇▇▇▇▇▇ fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Mid ▇▇▇▇▇▇ fails to submit the Implementation any Claims Review Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Surgical Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quality Review Report in accordance with the requirements of Section III.D, Section III.E Appendix A, Appendix B, and Appendices B and C by the deadlines for submission.Appendix C. 105. A Stipulated Penalty of $1,500 for each day KDMC Mid ▇▇▇▇▇▇ fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Mid ▇▇▇▇▇▇ fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Mid ▇▇▇▇▇▇ as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Mid ▇▇▇▇▇▇ fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC stating the specific grounds for its determination that KDMC has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC ▇▇▇ ▇▇▇▇▇▇ receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1–6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Orthofix and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Orthofix fails to establish and implement any of the following obligations as described in Section III: a. a Chief Compliance Officer; b. a Compliance Committee; c. the Board of Directors Audit Committee compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the all training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; requirements pursuant to Section III.C; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 III.D.2 and III.F.2; III.D.3; h. a Disclosure ProgramProgram pursuant to Section III.E; i. an Internal Monitoring Program and Consultant Monitoring pursuant to Section III.J; j. Ineligible Persons screening and removal requirementsrequirements pursuant to Section III.F; j. k. notification of Government investigations or legal proceedingsproceedings pursuant to Section III.G; and k. l. reporting of Reportable Events.Events pursuant to Section III.I. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Orthofix fails to engage and use an IRO, as required in Section III.E, Appendix III.D and Appendices A, Appendix B, and Appendix -C. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Orthofix fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Orthofix fails to submit the Implementation any Claims Review Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.DIII.D.1, Section III.E Appendix B, and Appendices B and C by the deadlines for submission.Appendix C. 105. A Stipulated Penalty of $1,500 for each day KDMC Orthofix fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Orthofix fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC Orthofix as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Orthofix fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Orthofix stating the specific grounds for its determination that KDMC Orthofix has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Orthofix shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Orthofix receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC Diversicare and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day KDMC Diversicare fails to establish and establish, implement or comply with any of the following obligations as described in Section III:III:‌‌ a. a Compliance Officer; b. Compliance Directors c. a Compliance Committee; c. d. the Board compliance obligations and the engagement of Directors compliance obligations; d. a written Code Compliance Expert, the performance of Conducta Compliance Program Review and the preparation of a Compliance Program Review Report, as required by Section III.A.4; e. the management certification obligations and the development and implementation of a written process for Certifying Employees, as required by Section III.A.5; f. written Policies and Procedures; f. g. the development of a written training plan and the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Persons and Board Members, members; h. a risk assessment and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. internal review process; i. a Disclosure Program; i. j. Ineligible Persons screening and removal requirements; j. k. notification of Government investigations or legal proceedings; l. policies and procedures regarding the repayment of Overpayments; and k. m. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Diversicare fails to engage and use an IRO, as required in by Section III.E, Appendix A, Appendix BIII.D, and Appendix C.Appendices A through C.‌‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Diversicare fails to engage and use timely submit (a) a Peer Review Consultantcomplete Implementation Report or Annual Report, as required (b) a certification to OIG in accordance with the requirements of Section III.D.V, or (c) a complete response to any request for information from OIG.‌ 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Diversicare fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendices B and C.‌ 105. A Stipulated Penalty of $1,500 for each day KDMC Diversicare fails to grant access as required in Section VII. VII (This Stipulated Penalty shall begin to accrue on the date KDMC Diversicare fails to grant access.)access.).‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Diversicare as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 127. A Stipulated Penalty of $2,500 for each day Diversicare fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.D, and for each day Diversicare fails to furnish accurate and complete records to the IRO, as required by Section III.D and Appendix A.‌ 8. A Stipulated Penalty of $1,000 for each day KDMC Diversicare fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Diversicare stating the specific grounds for its determination that KDMC Diversicare has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Diversicare shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 business days after KDMC the date Diversicare receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC Hanflink and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Hanflink fails to establish and establish, implement or comply with any of the following obligations as described in Section III: a. post a Compliance Officer;notice in accordance with the requirements of Section III.A;‌ b. a Compliance Committee;complete the training required for Hanflink and Covered Persons and maintain training records, in accordance with the requirements of Section III.B;‌ c. screen Covered Persons in accordance with the Board requirements of Directors compliance obligations;Section III.D; require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.D; or maintain copies of print screens from search results to demonstrate the required screening has been performed in accordance with the requirements of Section III.D;‌ d. notify OIG of a written Code government investigation or legal proceeding, in accordance with the requirements of Conduct;Section III.E;‌ e. written Policies repay any Overpayments as required by Section III.F and Procedures;Appendix B;‌ f. report a Reportable Event in accordance with Section III.G; or‌ g. provide to OIG the training certifications required by Section III.H relating to any third party ▇▇▇▇▇▇ engaged by Hanflink during the term of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events.IA.‌ 2. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Hanflink fails to engage and use an IRO, as required in by Section III.EIII.C, Appendix A, or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Hanflink fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Hanflink fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quarterly Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.C and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B.‌ 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC Hanflink fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Hanflink fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Hanflink as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIA.IA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC Hanflink fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.C, and for each day Hanflink fails to furnish accurate and complete records to the IRO, as required by Section III.C and Appendix A.‌ 8. A Stipulated Penalty of $1,000 for each day Hanflink fails to comply fully and adequately with any obligation of this CIAIA. OIG shall provide notice to KDMC Hanflink stating the specific grounds for its determination that KDMC Hanflink has failed to comply fully and adequately with the CIA IA obligation(s) at issue and steps KDMC the Hanflink shall take to comply with the CIAIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date Hanflink receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC ▇▇▇▇▇ and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day KDMC Prime fails to establish and establish, implement or comply with any of the following obligations as described in Section Sections III: a. a Corporate Compliance Officer;Officer or Deputy Compliance Officers;‌ b. a Compliance Committee;Committee;‌ c. the Board of Directors compliance obligations;, the engagement of a Compliance Expert, the performance of a Compliance Program Review, and the preparation of a Compliance Program Review Report, as required by Section III.A.4.;‌ d. the management certification obligations and the development and implementation of a written Code of Conduct;process for Certifying Employees, as required by Section III.A.5;‌ e. written Policies and Procedures;Procedures;‌ f. the development of a written training plan and the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; members;‌ g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; Requirements;‌ h. a Disclosure Program;risk assessment and internal review process;‌ i. a Disclosure Program;‌ j. Ineligible Persons screening and removal requirements;requirements;‌ j. k. notification of Government investigations or legal proceedingsproceedings;‌ l. policies and procedures regarding the repayment of Overpayments; andand‌‌ k. m. reporting of Reportable Events.Events.‌ 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Prime fails to engage and use an IRO, as required in by Section III.E, Appendix A, Appendix B, and Appendix C.Appendices A through D.‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Prime fails to engage and use timely submit (a) a Peer Review Consultantcomplete Implementation Report or Annual Report, as required (b) a certification to OIG in accordance with the requirements of Section III.D.V, or (c) a complete response to any request for information from OIG.‌ 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Prime fails to engage submit any Arrangements Review Report in accordance with the requirements of Section III.E and use the Physician Executive(s), as required in Section III.A.6.Appendix B.‌ 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Prime fails to submit the Implementation any Claims Review Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Inpatient Medical Necessity Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B C and C D, respectively, or fails to repay any Overpayment identified by the deadlines for submission.IRO as required by Appendices C and D.‌ 106. A Stipulated Penalty of $1,500 for each day KDMC Prime fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Prime fails to grant access.)access.)‌ 117. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Prime as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 128. A Stipulated Penalty of $2,500 for each day Prime fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.E., and for each day Prime fails to furnish accurate and complete records to the IRO, as required by Section III.E and Appendix A.‌ 9. A Stipulated Penalty of $1,000 for each day KDMC Prime fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Prime stating the specific grounds for its determination that KDMC Prime has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Prime shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 business days after KDMC the date Prime receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 8 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC CareMed and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the business day after the date the obligation became due) for each day KDMC CareMed fails to establish and implement any of the following obligations as described in Section IIISections III and IV: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. the management certification obligations; e. a written Code of ConductEthics; e. f. written Policies and Procedures; f. g. the development and/or implementation of a Training Plan for the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, ; h. a risk assessment and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described mitigation process as required in Sections III.F.1 and III.F.2; h. Section III.E; i. a Disclosure Program; i. j. Ineligible Persons screening and removal requirements; j. k. notification of Government investigations or legal proceedings; andCorporate Integrity Agreement between the Office of Inspector General and Sorkin’s Rx Ltd. d/b/a CareMed Pharmaceutical Services k. l. policies and procedures regarding the repayment of Overpayments; m. the repayment of Overpayments as required by Section III.I; n. reporting of Reportable Events; and o. disclosure of changes to business units or locations. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the business day after the date the obligation became due) for each day KDMC CareMed fails to engage and use an IRO, as required in Section III.EIII.D, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the business day after the date the obligation became due) for each day KDMC fails to engage and use a Peer Review Consultant, as required in Section III.D. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CareMed fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 84. A Stipulated Penalty of $2,500 (which shall begin to accrue on the business day after the date the obligation became due) for each day KDMC CareMed fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems any Claims Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Restocking Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC CareMed fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC CareMed fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC CareMed as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC CareMed fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC CareMed stating the specific grounds for its determination that KDMC CareMed has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC CareMed shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC CareMed receives this notice from OIG of the failure to comply.) A Stipulated Penalty as Corporate Integrity Agreement between the Office of Inspector General and Sorkin’s Rx Ltd. d/b/a CareMed Pharmaceutical Services described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC ▇▇▇▇▇ and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ▇▇▇▇▇ fails to establish and implement any of the following obligations as described in Section IIISections III and IV: a. a Compliance Officer;Officer;‌ b. a Compliance Committee;Committee;‌ c. the Board of Directors compliance obligations;obligations;‌ d. the management certification obligations;‌ e. a written Code of Conduct;Conduct;‌ e. f. written Policies and Procedures;Procedures;‌‌ f. g. the development and/or implementation of a Training Plan for the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; g. Members;‌ h. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 III.D.1 and III.F.2; h. III.D.2;‌ i. a risk assessment and internal review process as required by Section III.F;‌ j. a Disclosure Program;Program;‌ i. k. Ineligible Persons screening and removal requirements;requirements;‌ j. l. notification of Government investigations or legal proceedings; andproceedings;‌ k. m. policies and procedures regarding the repayment of Overpayments;‌ n. the repayment of Overpayments as required by Section III.J and Appendix B;‌ o. reporting of Reportable Events.; and‌ p. disclosure of changes to business units or locations.‌ 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ▇▇▇▇▇ fails to engage and use an IRO, as required in by Section III.E, Appendix A, or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ▇▇▇▇▇ fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ▇▇▇▇▇ fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B.‌‌ 105. A Stipulated Penalty of $1,500 for each day KDMC ▇▇▇▇▇ fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC ▇▇▇▇▇ fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC ▇▇▇▇▇ as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC ▇▇▇▇▇ fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC ▇▇▇▇▇ stating the specific grounds for its determination that KDMC ▇▇▇▇▇ has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC ▇▇▇▇▇ shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date ▇▇▇▇▇ receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC UHS and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC UHS fails to establish and implement establish, implement, or comply with any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code Quality of ConductCare Review Program; e. a Dashboard; f. the management certification obligations and the development and implementation of a written process for Certifying Employees, as required by Section III.A.4; g. written Policies and Procedures; f. h. the development of a written training plan and the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Persons and Board Members, ; i. retention of a Monitor; j. a risk assessment and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. internal review process; k. a Disclosure Program; i. l. Ineligible Persons screening and removal requirements; j. m. notification of Government investigations or legal proceedings; n. policies and procedures regarding the repayment of Overpayments; and k. o. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC UHS fails to engage and use an IRO, as required in by Section III.E, Appendix A, or Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC UHS fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Reports, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 1,500 for each day UHS fails to grant access as required in Section VII (which This Stipulated Penalty shall begin to accrue on the day after the date the obligation became due) for each day KDMC UHS fails to engage and use the Physician Executive(sgrant access.), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC UHS fails to engage submit any Claims Review Report in accordance with the requirements of Section III.E and use a Medical Director of Appendix B or fails to repay any Overpayment identified by the Cardiac Catheterization LaboratoryIRO, as required in Section III.A.7.by Appendix B. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) 50,000 for each day KDMC fails false certification submitted by or on behalf of UHS as part of its Implementation Report, any Annual Report, additional documentation to engage and use a report (as requested by the Board Compliance ExpertOIG), as or otherwise required in Section III.A.4by this CIA. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC UHS fails to submit the Implementation Report or any Annual Reports to OIG pay a Monitor, as required in accordance with the requirements of Section V by the deadlines for submissionIII.D.5. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission. 10. A Stipulated Penalty of $1,500 for each day KDMC fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC fails to grant access.) 11. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 12. A Stipulated Penalty of $1,000 for each day KDMC UHS fails to comply fully and adequately with any of its obligations with respect to the Monitor, including but not limited to the obligation to grant the Monitor access, as set forth in Section III.D.2, and the obligation to adequately and timely respond to any written recommendation of this CIAthe Monitor, as set forth in Section III.D.6. OIG shall provide notice to KDMC UHS stating the specific grounds for its determination that KDMC UHS has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC UHS shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC UHS receives this notice from OIG of the failure to comply.) 9. A Stipulated Penalty of $2,500 for each day UHS fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.E, and for each day UHS fails to furnish accurate and complete records to the IRO, as required by Section III.E and Appendix A. 10. A Stipulated Penalty of $1,000 for each day UHS fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to UHS stating the specific grounds for its determination that UHS has failed to comply fully and adequately with the CIA obligation(s) at issue and steps UHS shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after the date UHS receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 9 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Practitioner and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day Practitioner fails to establish, implement or comply with any of the following obligations as described in Section III: a. post a notice in accordance with the requirements of Section III.A; b. complete the training required for Practitioner and Covered Persons and maintain training records, in accordance with the requirements of Section III.B; c. screen Covered Persons in accordance with the requirements of Section III.D; require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.D; or maintain copies of print screens from search results to demonstrate the required screening has been performed in accordance with the requirements of Section III.D; d. notify OIG of a government investigation or legal proceeding, in accordance with the requirements of Section III.E; e. repay any Overpayments as required by Section III.F and Appendix B; or f. report a Reportable Event in accordance with Section III.G. g. provide to OIG the certifications required by Section III.H relating to any third-party ▇▇▇▇▇▇ engaged by Practitioner during the term of the IA. 2. A Stipulated Penalty of $1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Practitioner fails to establish engage and implement any of the following obligations use an IRO, as described in required by Section III:III.C, Appendix A, or Appendix B. a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 23. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Practitioner fails to engage and use an IROtimely submit (a) a complete Implementation Report or Annual Report, as required (b) a certification to OIG in accordance with the requirements of Section III.EV, Appendix A, Appendix B, and Appendix C.or (c) a complete response to any request for information from OIG. 34. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Peer Review Consultant, as required in Section III.D. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Practitioner fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quarterly Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.C and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B. 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC Practitioner fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Practitioner fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Practitioner as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIAIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Practitioner fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.C, and for each day Practitioner fails to furnish accurate and complete records to the IRO, as required by Section III.C and Appendix A. 8. A Stipulated Penalty of $1,000 for each day Practitioner fails to comply fully and adequately with any obligation of this CIAIA. OIG shall provide notice to KDMC Practitioner stating the specific grounds for its determination that KDMC Practitioner has failed to comply fully and adequately with the CIA IA obligation(s) at issue and steps KDMC the Practitioner shall take to comply with the CIAIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date Practitioner receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC ABC and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ABC fails to establish and establish, implement or comply with any of the following obligations as described in Section III: a. a Chief Compliance Officer;Officer;‌ b. a Compliance Committee;Committee;‌ c. the Board of Directors compliance obligationsobligations and the engagement of a Compliance Expert, the performance of a‌ Compliance Program Review, and the preparation of a Compliance Program Review Report, as required by Section III.A.3.; d. the management certification obligations and the development and implementation of a written Code of Conduct;process for Certifying Employees, as required by Section III.A.4.;‌ e. written Policies and Procedures;Procedures;‌ f. the development of a written training plan and the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Persons and Board Members, Members;‌ g. a risk assessment and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; internal review process;‌ h. a Disclosure Program;Program;‌ i. Ineligible Persons screening and removal requirements;requirements;‌ j. the establishment of Incentive Compensation Restriction and Financial Recoupment Programs;‌ k. notification of Government investigations or legal proceedings; andproceedings;‌ k. l. policies and procedures regarding the repayment of Overpayments;‌ m. reporting of Reportable Events.Events;‌ n. notification of written communications with FDA; and‌ o. notification to health care providers.‌ 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ABC fails to engage and use an IRO, IRO as required in by Section III.E, Appendix A, Appendix B, III.E and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ABC fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ABC fails to submit the Implementation Report or any Annual Reports to OIG IRO Review report in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B.‌ 105. A Stipulated Penalty of $1,500 for each day KDMC ABC fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC ABC fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC ABC as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 127. A Stipulated Penalty of $2,500 for each day ABC fails to grant the IRO access to all records and personnel necessary to complete the reviews required by Section III.E and for each day ABC fails to furnish accurate and complete records to the IRO, as required by Section III.E and Appendix A; and‌ 8. A Stipulated Penalty of $1,000 for each day KDMC ABC fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC ABC stating the specific grounds for its determination that KDMC ABC has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC ABC shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date ABC receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 7 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Maxim and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Maxim fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Corporate Compliance Committee; c. the Board of Directors compliance obligationsresolution; d. the Certifying Employee certifications; e. a written Code of Conduct; e. f. written Policies and Procedures; f. g. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; MSS Contractors; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Maxim fails to engage and use an IRO, as required in Section III.EIII.D, Appendix A, and Appendix BB or fails to engage and use a Consultant, as required in Section III.E and Appendix C. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Maxim fails to engage and use a Peer Review Consultantsubmit any Monitor Reports, as required the Implementation Report, or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Maxim fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Claims Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Unallowable Cost Review Report, or Unallowable Cost Compliance Review Report in accordance with the requirements of Section III.D, Section Sections III.D and III.E and Appendices B and C by the deadlines for submission.C. 105. A Stipulated Penalty of $1,500 for each day KDMC Maxim fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Maxim fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC Maxim as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Maxim fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Maxim stating the specific grounds for its determination that KDMC Maxim has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Maxim shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Maxim receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC ▇▇▇ and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC HOK fails to establish and establish, implement or comply with any of the following obligations as described in Section III: a. appoint a Compliance Officer;Officer as required by Section III.A;‌ b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures;Procedures required by Section III.B;‌ c. post a notice in accordance with the requirements of Section III.C;‌ d. complete the training required for Covered Persons and maintain training records, in accordance with the requirements of Section III.D;‌ e. screen Covered Persons in accordance with the requirements of Section III.F; require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.F; or maintain copies of print screens from search results to demonstrate the required screening has been performed in accordance with the requirements of Section III.F;‌ f. notify OIG of a government investigation or legal proceeding, in accordance with the training requirements of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, Section III.G;‌ g. establish policies and Executive Managementprocedures regarding the repayment of Overpayments;‌ h. repay any Overpayments as required by Section III.H and Appendix B; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program;or‌ i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of report a Reportable Events.Event in accordance with Section III.I.‌ 2. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC HOK fails to engage and use an IRO, as required in by Section III.E, Appendix A, A or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC HOK fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC HOK fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B.‌ 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC HOK fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC HOK fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC HOK as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIA.IA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC HOK fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.E, and for each day HOK fails to furnish accurate and complete records to the IRO, as required by Section III.E and Appendix A.‌ 8. A Stipulated Penalty of $1,000 for each day HOK fails to comply fully and adequately with any obligation of this CIAIA. OIG shall provide notice to KDMC HOK stating the specific grounds for its determination that KDMC HOK has failed to comply fully and adequately with the CIA IA obligation(s) at issue and steps KDMC the HOK shall take to comply with the CIAIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date HOK‌ receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC ▇▇▇ ▇▇▇▇▇ and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Kai Heart fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; ; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. h. Ineligible Persons screening and removal requirements; j. i. notification of Government investigations or legal proceedings; and k. j. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Kai Heart fails to engage and use an IRO, as required in Section III.EIII.D, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Kai Heart fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Kai Heart fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Claims Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC Kai Heart fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Kai Heart fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC Kai Heart as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Kai Heart fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Kai Heart stating the specific grounds for its determination that KDMC Kai Heart has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Kai Heart shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC ▇▇▇ ▇▇▇▇▇ receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC EPIPG and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day EPIPG fails to establish, implement or comply with any of the following obligations as described in Section III: a. appoint a Compliance Officer as required by Section III.A;‌ b. written Policies and Procedures required by Section III.B;‌ c. post a notice in accordance with the requirements of Section III.C;‌ d. complete the training required for Covered Persons and maintain training records, in accordance with the requirements of Section III.D;‌ e. screen Covered Persons in accordance with the requirements of Section III.F; require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.F; or maintain copies of print screens from search results to demonstrate the required screening has been performed in accordance with the requirements of Section III.F;‌‌‌ f. notify OIG of a government investigation or legal proceeding, in accordance with the requirements of Section III.G;‌ g. establish policies and procedures regarding the repayment of Overpayments;‌ h. repay any Overpayments as required by Section III.H and Appendix B; or‌ i. report a Reportable Event in accordance with Section III.I.‌ 2. A Stipulated Penalty of $1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC EPIPG fails to establish engage and implement any of the following obligations use an IRO, as described in required by Section III:III.E, Appendix A or Appendix B.‌ a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 23. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC EPIPG fails to engage and use an IROtimely submit‌‌ (a) a complete Implementation Report or Annual Report, as required (b) a certification to OIG in accordance with the requirements of Section III.EV, Appendix A, Appendix B, and Appendix C.or (c) a complete response to any request for information from OIG. 34. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Peer Review Consultant, as required in Section III.D. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC EPIPG fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quarterly Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B.‌ 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC EPIPG fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC EPIPG fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC EPIPG as part of its Implementation Report, Annual any Annual‌ Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIA.IA.‌‌ 127. A Stipulated Penalty of $1,000 for each day KDMC EPIPG fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.E, and for each day EPIPG fails to furnish accurate and complete records to the IRO, as required by Section III.E and Appendix A.‌ 8. A Stipulated Penalty of $1,000 for each day EPIPG fails to comply fully and adequately with any obligation of this CIAIA. OIG shall provide notice to KDMC EPIPG stating the specific grounds for its determination that KDMC EPIPG has failed to comply fully and adequately with the CIA IA obligation(s) at issue and steps KDMC the EPIPG shall take to comply with the CIAIA. (This Stipulated Penalty shall begin to accrue 10 business days after KDMC the date EPIPG receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC WCH and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC WCH fails to establish and establish, implement or comply with any of the following obligations as described in Section Sections III: a. a Compliance Officer;Officer;‌ b. a Compliance Committee;Committee;‌ c. the Board of Directors compliance obligations;obligations;‌ d. a written Code of Conduct;the management certification obligations;‌ e. written Policies and Procedures;Procedures;‌ f. the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; Members;‌ g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; Requirements;‌ h. a Disclosure Program;risk assessment and internal review process;‌ i. a Disclosure Program;‌ j. Ineligible Persons screening and removal requirements;requirements;‌ j. k. notification of Government investigations or legal proceedingsproceedings;‌ l. policies and procedures regarding the repayment of Overpayments; andand‌ k. m. reporting of Reportable Events.Events‌ 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC WCH fails to engage and use an IRO, as required in by Section III.E, Appendix A, or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC WCH fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC WCH fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B.‌ 105. A Stipulated Penalty of $1,500 for each day KDMC WCH fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC WCH fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC WCH as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC WCH fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC WCH stating the specific grounds for its determination that KDMC WCH has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC WCH shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date WCH receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Biomet, Biomet Orthopedics and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Biomet or Biomet Orthopedics fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. d. written Policies and Procedures; f. e. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. ; f. a Disclosure Program; i. g. Ineligible Persons screening and removal requirements;; and j. notification h. Notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Biomet Orthopedics fails to engage establish and use an IRO, as required implement the Arrangements Procedures and/or Arrangements Requirements described in Section III.E, Appendix A, Appendix B, Sections III.D.1 and Appendix C.III.D.2. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Biomet Orthopedics fails to engage and use a Peer Review Consultantan IRO, as required in Section III.D.III.E and Appendix B. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails Biomet and Biomet Orthopedics fail to engage and use submit the Physician Executive(s)Implementation Report, as documentation required under Section V.B, or the Annual Reports to OIG in accordance with the requirements of Section III.A.6V by the deadlines for submission. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Biomet Orthopedics fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.III.E. 106. A Stipulated Penalty of $1,500 for each day KDMC Biomet or Biomet Orthopedics fails to grant access to the information or documentation as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Biomet fails to grant access.) 117. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC Biomet or Biomet Orthopedics as part of its their Implementation Report, Annual ReportReports, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 128. A Stipulated Penalty of $1,000 for each day KDMC Biomet or Biomet Orthopedics fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Biomet or Biomet Orthopedics, stating the specific grounds for its determination that KDMC Biomet or Biomet Orthopedics has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Biomet or Biomet Orthopedics shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Biomet receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC 21st Century and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC 21st Century fails to establish and implement any of the following obligations as described in Section IIISections III and IV: a. a Chief Compliance Officer; b. Regional Compliance Officers; c. a Compliance Committee; c. d. the Board of Directors compliance obligations and the engagement of a Compliance Expert, the performance of a Compliance Program Review and the preparation of a Compliance Program Review Report, as required by Section III.A.3. e. the management certification obligations; d. f. a written Code of Conduct; e. g. written Policies and Procedures; f. h. the development and/or implementation of a Training Plan for the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, ; i. a risk assessment and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. internal review process as required by Section III.E; j. a Disclosure Program; i. k. Ineligible Persons screening and removal requirements; j. l. notification of Government investigations or legal proceedings; and; k. m. policies and procedures regarding the repayment of Overpayments; n. the repayment of Overpayments as required by Section III.I and Appendix B; o. reporting of Reportable Events; and p. disclosure of changes to business units or locations. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC 21st Century fails to engage and use an IRO, as required in by Section III.EIII.D, Appendix A, or Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC 21st Century fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC 21st Century fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC 21st Century fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC 21st Century fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC 21st Century as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC 21st Century fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC 21st Century stating the specific grounds for its determination that KDMC 21st Century has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC 21st Century shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date 21st Century receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC King and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions.. Corporate Integrity Agreement King Pharmaceuticals, Inc. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC King fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. d. written Policies and Procedures; f. e. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. ; f. a Disclosure Program; i. g. Ineligible Persons screening and removal requirements;; and j. notification h. Notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC King fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, III.D and Appendix C.A. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC King fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or the Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC King fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Engagement Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC King fails to grant access to Corporate Integrity Agreement King Pharmaceuticals, Inc. 28 the information or documentation as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC King fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC King as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC King fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC King, stating the specific grounds for its determination that KDMC King has failed to comply fully and adequately with the CIA obligation(s) at issue and the steps KDMC King shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC King receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Medco and HHS-OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Medco fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. d. written Policies and Procedures;; Medco CIA f. e. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. ; f. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 III.D.l and III.F.2; h. III.D.2; g. a Disclosure Program; i. h. Ineligible Persons screening and removal requirements;; and j. notification i. Notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Medco fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, III.E and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Medco fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or the Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Medco fails to submit the Implementation annual Focus Arrangements Review Report or any Annual Reports to OIG and Unallowable Cost Review Report, if applicable, in accordance with the requirements of Section V by the deadlines for submission.III.E. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission. 105. A Stipulated Penalty of $1,500 for each day KDMC Medco fails to grant access to the information or documentation as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Medco fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC Medco as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Medco fails to comply fully and adequately with any obligation of this CIA. HHS-OIG shall provide notice to KDMC Medco, stating the specific grounds for its determination that KDMC Medco has failed to comply fully Medco CIA and adequately with the CIA obligation(s) at issue and steps KDMC Medco shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Medco receives this notice from HHS-OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which HHS-OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC HealthNet and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC HealthNet fails to establish and establish, implement or comply with any of the following obligations as described in Section Sections III: a. a Compliance Officer;Officer;‌ b. a Compliance Committee;Committee;‌ c. the Board of Directors compliance obligations;obligations;‌ d. a written Code of Conduct;the management certification obligations;‌ e. written Policies and Procedures;Procedures;‌ f. the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; Members;‌ g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; Requirements;‌ h. a Disclosure Program;risk assessment and internal review process;‌ i. a Disclosure Program;‌ j. Ineligible Persons screening and removal requirements;requirements;‌ j. k. notification of Government investigations or legal proceedingsproceedings;‌ l. policies and procedures regarding the repayment of Overpayments; andand‌ k. m. reporting of Reportable Events.Events.‌ 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC HealthNet fails to engage and use an IRO, as required in by Section III.E, Appendix A, or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC HealthNet fails to engage and use a Peer Review Consultantsubmit a‌ complete Implementation Report, as required Annual Report, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC HealthNet fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B.‌ 105. A Stipulated Penalty of $1,500 for each day KDMC HealthNet fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC HealthNet fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC HealthNet as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC HealthNet fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC HealthNet stating the specific grounds for its determination that KDMC HealthNet has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC HealthNet shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date HealthNet receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC CHSI and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CHSI fails to establish and implement any of the following obligations as described in Section III: a. a Corporate Compliance and Privacy Officer, Corporate Compliance Directors, and/or Facility Compliance Officers; b. a Corporate Compliance CommitteeWork Group; and/or Facility Compliance Committees; c. the Board of Directors compliance obligations;; Community Health Systems, Inc. Corporate Integrity Agreement, Amended d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; ; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. h. Ineligible Persons screening and removal requirements; j. i. notification of Government investigations or legal proceedings; and k. j. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CHSI fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CHSI fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CHSI fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Claims Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Unallowable Cost Review Report, or Unallowable Cost Arrangements Review Report in accordance with the requirements of Section III.DIII.E, Section III.E Appendix B, and Appendices B and C by the deadlines for submission.Appendix C. 105. A Stipulated Penalty of $1,500 for each day KDMC CHSI fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC CHSI fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC CHSI as part of its Implementation Report, Annual Report, Community Health Systems, Inc. Corporate Integrity Agreement, Amended additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC CHSI fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC CHSI stating the specific grounds for its determination that KDMC CHSI has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC CHSI shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC CHSI receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC HOTC and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC HOTC fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; ; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. h. Ineligible Persons screening and removal requirements; j. i. notification of Government investigations or legal proceedings; and k. j. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC HOTC fails to engage and use an IRO, as required in Section III.EIII.D, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC HOTC fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC HOTC fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Eligibility Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC HOTC fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC HOTC fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC HOTC as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC HOTC fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC HOTC stating the specific grounds for its determination that KDMC HOTC has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC HOTC shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC HOTC receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Odyssey and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Odyssey fails to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. d. written Policies and Procedures; f. e. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. ; f. a Disclosure Program; i. g. Ineligible Persons screening and removal requirements;; and j. notification h. Notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Odyssey fails to engage and use an IROIVO, as required in Section III.E, Appendix A, Appendix B, III.D and Appendix C.Appendices A and B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Odyssey fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or the Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Odyssey fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost IVO Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B A and C by the deadlines for submission.B. 105. A Stipulated Penalty of $1,500 for each day KDMC Odyssey fails to grant access to the information or documentation as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Odyssey fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC Odyssey as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Odyssey fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Odyssey, stating the specific grounds for its determination that KDMC Odyssey has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Odyssey shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 30 days after KDMC Odyssey receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Aegerion and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Aegerion fails to establish and implement establish, implement, or comply with any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors Board’s compliance obligations; d. a written Code of Conductthe management certification obligations; e. written Policies and Procedures; f. the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; members; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; a RAMP; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and; k. reporting of Reportable Events.; l. notification of written communications with FDA as required by Section III.K; m. the FFMP required by Section III.L; n. the NPMP required by Section III.M; o. notification to HCPs and HCIs as required by Section III.N; p. posting of any Payment-related information as required by Section III.O; and q. implementation of the other requirements described in Section III.P. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Aegerion fails to engage and use an IRO, IRO as required in by Section III.E, Appendix A, Appendix B, III.E and Appendix C.Appendices A and B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Aegerion fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Aegerion fails to submit the Implementation Report or any Annual Reports to OIG IRO Review report in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC Aegerion fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Aegerion fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Aegerion as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Aegerion fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Aegerion stating the specific grounds for its determination that KDMC Aegerion has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Aegerion shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date Aegerion receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Cordant and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day KDMC Cordant fails to establish and establish, implement or comply with any of the following obligations as described in Section Sections III: a. a Compliance Officer; b. a Compliance Committee; c. the Board compliance obligations and the engagement of Directors compliance obligationsa Compliance Expert, the performance of a Compliance Program Review, and the preparation of a Compliance Program Review Report, as required by Section III.A.3; d. the management certification obligations and the development and implementation of a written Code of Conductprocess for Certifying Employees, as required by Section III.A.4; e. written Policies and Procedures; f. the development of a written training plan and the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; members; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 Requirements; h. a risk assessment and III.F.2; h. internal review process; i. a Disclosure Program; i. j. Ineligible Persons screening and removal requirements; j. k. notification of Government investigations or legal proceedings; l. policies and procedures regarding the repayment of Overpayments; and k. m. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Cordant fails to engage and use an IRO, as required in by Section III.E, Appendix A, or Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Cordant fails to engage and use timely submit (a) a Peer Review Consultantcomplete Implementation Report or Annual Report, as required (b) a certification to OIG in accordance with the requirements of Section III.D.V, or (c) a complete response to any request for information from OIG. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Cordant fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC Cordant fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Cordant fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Cordant as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $2,500 for each day Cordant fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.D, and for each day Cordant fails to furnish to the IRO accurate and complete records, as required by Section III.E and Appendix A. 8. A Stipulated Penalty of $1,000 for each day KDMC Cordant fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Cordant stating the specific grounds for its determination that KDMC Cordant has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Cordant shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 business days after KDMC the date Cordant receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC ▇▇▇▇ and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC MCCG fails to establish and implement any of the following obligations as described in Section IIISections III and IV: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. the Management Certification obligations; e. a written Code of Conduct; e. f. written Policies and Procedures; f. g. the development and/or implementation of a Training Plan for the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Persons and Board Members, ; h. a risk assessment and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described mitigation process as required in Sections III.F.1 and III.F.2; h. Section III.E; i. a Disclosure Program; i. j. Ineligible Persons screening and removal requirements; j. k. notification of Government investigations or legal proceedings; l. policies and procedures regarding the repayment of Overpayments; m. the repayment of Overpayments as required by Section III.I; and k. n. reporting of Reportable Events; and o. disclosure of changes to business units or locations. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC MCCG fails to engage and use an IRO, as required in Section III.EIII.D, Appendix A, Appendix B, and Appendix C. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC MCCG fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC MCCG fails to submit the Implementation any Claims Review Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, Inpatient Medical Necessity and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Appropriateness Review Report in accordance with the requirements of Section III.D, Section III.E Appendix B, and Appendices B and C by the deadlines for submission.Appendix C. 105. A Stipulated Penalty of $1,500 for each day KDMC MCCG fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC MCCG fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC MCCG as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC MCCG fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC MCCG stating the specific grounds for its determination that KDMC MCCG has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC MCCG shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC MCCG receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Good Shepherd and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Good Shepherd fails to establish and implement any of the following obligations as described in Section IIISections III and IV: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance management certification obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the development and/or implementation of a Training Plan for the training of Covered Persons, Persons and Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 a risk assessment and III.F.2; internal review process as required by Section III.E; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and; k. policies and procedures regarding the repayment of Overpayments; l. the repayment of Overpayments as required by Section III.I; m. reporting of Reportable Events; and n. disclosure of changes to business units or locations. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Good Shepherd fails to engage and use an IRO, as required in Section III.EIII.D, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Good Shepherd fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Good Shepherd fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC Good Shepherd fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Good Shepherd fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Good Shepherd as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $10,000 (which shall begin to accrue on the day after the date the obligation became due) for each day Good Shepherd fails to cooperate and otherwise satisfy any of the obligations and requirements as described in Section III.K. 8. A Stipulated Penalty of $1,000 for each day KDMC Good Shepherd fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Good Shepherd stating the specific grounds for its determination that KDMC Good Shepherd has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Good Shepherd shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Good Shepherd receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Cephalon and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Cephalon fails to establish and implement establish, implement, or accomplish any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligationsresolution; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; ; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure ProgramProgram as required by Section III.E; i. h. Ineligible Persons screening and removal requirements; j. i. notification of Government investigations or legal proceedings; and; j. notification of communications with FDA regarding off-label matters; k. reporting Message Recall Studies (or alternative information permitted by Section III.J); l. a program for FFMP; m. notification to any health care providers or entities as required by Section III.L; or n. posting of Reportable Events.any Payments as required by Section III.M. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Cephalon fails to engage and use an IRO, as required in Section III.E, Appendix III.D and Appendices A, Appendix B, and Appendix C.-B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Cephalon fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or the Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Cephalon fails to submit the Implementation Report or any Annual Reports to OIG annual IRO Review Report(s) in accordance with the requirements of Section V by the deadlines for submission.Sections III.D and V.B.6 and Appendix B. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission. 105. A Stipulated Penalty of $1,500 for each day KDMC Cephalon fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Cephalon fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC Cephalon as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Cephalon fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Cephalon, stating the specific grounds for its determination that KDMC Cephalon has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Cephalon shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Cephalon receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC MPG and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions.provisions.‌‌ 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day MPG fails to establish, implement or comply with any of the following obligations as described in Section III: a. post a notice in accordance with the requirements of Section III.A;‌ b. complete the training required for MPG and Covered Persons and maintain training records, in accordance with the requirements of Section III.B;‌ c. screen Covered Persons in accordance with the requirements of Section III.D; require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.D; or maintain copies of print screens from search results to demonstrate the required screening has been performed in accordance with the requirements of Section III.D;‌ d. notify OIG of a government investigation or legal proceeding, in accordance with the requirements of Section III.E;‌ e. repay any Overpayments as required by Section III.F and Appendix B; or‌ f. report a Reportable Event in accordance with Section III.G.‌ 2. A Stipulated Penalty of $1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC MPG fails to establish engage and implement any of the following obligations use an IRO, as described in required by Section III:III.C, Appendix A, or Appendix B.‌ a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 23. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC MPG fails to engage and use an IROtimely submit (a) a complete Implementation Report or Annual Report, as required in (b) a certification to OIG in‌ accordance with the requirements of Section III.EV, Appendix A, Appendix B, and Appendix C.or (c) a complete response to any request for information from OIG.‌‌ 34. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Peer Review Consultant, as required in Section III.D. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC MPG fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quarterly Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.C and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B.‌ 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC MPG fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC MPG fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC MPG and/or ▇▇▇▇▇▇ ▇▇▇▇, M.D. as part of its the Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIA.IA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC MPG fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.C, and for each day MPG fails to furnish accurate and complete records to the IRO, as required by Section III.C and Appendix A.‌ 8. A Stipulated Penalty of $1,000 for each day MPG fails to comply fully and adequately with any obligation of this CIAIA. OIG shall provide notice to KDMC MPG stating the specific grounds for its determination that KDMC MPG has failed to comply fully and adequately with the CIA IA obligation(s) at issue and steps KDMC the MPG shall take to comply with the CIAIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date MPG receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC the U.S. Healthcare Parties and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails the U.S. Healthcare Parties or the ▇▇▇▇▇ Entities, as applicable, fail to establish and implement establish, implement, or comply with any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance management certification obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the e. training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, ; f. a risk assessment and Executive Management; internal review process; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; h. the prohibition on Third-Party Internet-Based Lead Generation Activities; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; k. policies and procedures regarding the repayment of Overpayments; and k. l. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails the U.S. Healthcare Parties fail to engage and use an IRO, as required in by Section III.EIII.D, Appendix A, or Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails the U.S. Healthcare Parties fail to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails U.S. Healthcare Parties fail to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission. 10. A Stipulated Penalty of $1,500 for each day KDMC fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC fails to grant access.) 11. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 12. A Stipulated Penalty of $1,000 for each day KDMC fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC stating the specific grounds for its determination that KDMC has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC ResMed and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day KDMC ResMed fails to establish and establish, implement or comply with any of the following obligations as described in Section Sections III: a. a Compliance Officer;Officer;‌ b. a Compliance Committee;Committee;‌ c. the Board compliance obligations and the engagement of Directors compliance obligations;a Compliance Expert, the performance of a Compliance Program Review, and the preparation of a Compliance Program Review Report, as required by Section III.A.3;‌ d. the management certification obligations and the development and implementation of a written Code of Conduct;process for Certifying Employees, as required by Section III.A.4;‌ e. written Policies and Procedures;Procedures;‌ f. the development of a written training plan and the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; members;‌ g. the Focus Arrangements Procedures, Invoiced Sales Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; Requirements;‌ h. a Disclosure Program;risk assessment and internal review process;‌ i. a Disclosure Program;‌ j. Ineligible Persons screening and removal requirements;requirements;‌ j. k. notification of Government investigations or legal proceedings; andand‌ k. l. reporting of Reportable Events.Events‌ 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ResMed fails to engage and use an IRO, as required in by Section III.E, Appendix A, or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ResMed fails to engage and use timely submit‌‌ (a) a Peer Review Consultantcomplete Implementation Report or Annual Report, as required (b) a certification to OIG in accordance with the requirements of Section III.D.V, or (c) a complete response to any request for information from OIG. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC ResMed fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission.Appendix B.‌ 105. A Stipulated Penalty of $1,500 for each day KDMC ResMed fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC ResMed fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC ResMed as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 127. A Stipulated Penalty of $2,500 for each day ResMed fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.D, and for each day ResMed fails to furnish to the IRO accurate and complete records, as required by Section III.E and Appendix A.‌ 8. A Stipulated Penalty of $1,000 for each day KDMC ResMed fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC ResMed stating the specific grounds for its determination that KDMC ResMed has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC ResMed shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 business days after KDMC the date ResMed receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Kindred, RehabCare and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Kindred and/or RehabCare, as applicable, fails to establish and implement any of the following obligations as described in Section IIISections III and IV: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. the management certification obligations; e. a written Code of Conduct; e. f. written Policies and Procedures; f. g. the development and/or implementation of a Training Plan for the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, ; h. a risk assessment and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. internal review process as required by Section III.E; i. a Disclosure Program; i. j. Ineligible Persons screening and removal requirements; j. k. notification of Government investigations or legal proceedings; and; k. l. reporting of Reportable Events; and m. disclosure of changes to Kindred’s contract therapy business units or locations. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Kindred and/or RehabCare, as applicable, fails to engage and use an IRO, as required in by Section III.EIII.D, Appendix A, or Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Kindred and/or RehabCare, as applicable, fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s)Kindred and/or RehabCare, as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratoryapplicable, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Implementation Report or any Annual Reports to OIG report in accordance with the requirements of Section V by the deadlines for submission.III.D and Appendix B. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission. 105. A Stipulated Penalty of $1,500 for each day KDMC Kindred and/or RehabCare, as applicable, fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Kindred fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Kindred and/or RehabCare, as applicable, as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Kindred and/or RehabCare, as applicable, fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Kindred stating the specific grounds for its determination that KDMC Kindred and/or RehabCare, as applicable, has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Kindred shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date Kindred receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC ▇▇▇▇▇▇▇-▇▇▇▇▇▇ and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails Harmony-▇▇▇▇▇▇ fail to establish and implement any of the following obligations as described in Section III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligationssubmit ▇▇▇▇▇▇ ▇▇▇▇▇▇’▇ certification; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; ; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. h. Ineligible Persons screening and removal requirements; j. i. notification of Government investigations or legal proceedings; and k. j. reporting of Reportable Events. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails Harmony-▇▇▇▇▇▇ fail to engage and use an IRO, as required in Section III.EIII.D, Appendix A, Appendix B, and Appendix C.B. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails Harmony-▇▇▇▇▇▇ fail to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails Harmony-▇▇▇▇▇▇ fail to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Claims Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices B and C by the deadlines for submission.Appendix B. 105. A Stipulated Penalty of $1,500 for each day KDMC fails Harmony-▇▇▇▇▇▇ fail to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC fails Harmony-▇▇▇▇▇▇ fail to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC ▇▇▇▇▇▇▇-▇▇▇▇▇▇ as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC fails ▇▇▇▇▇▇▇-▇▇▇▇▇▇ fail to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC ▇▇▇▇▇▇▇-▇▇▇▇▇▇ stating the specific grounds for its determination that KDMC has ▇▇▇▇▇▇▇-▇▇▇▇▇▇ have failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC ▇▇▇▇▇▇▇-▇▇▇▇▇▇ shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC receives ▇▇▇▇▇▇▇-▇▇▇▇▇▇ receive this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC CHSI and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CHSI fails to establish and implement any of the following obligations as described in Section III: a. a Corporate Compliance and Privacy Officer;, Corporate Compliance Directors, and/or Facility Compliance Officers;‌ b. a Corporate Compliance Committee;Work Group; and/or Facility Compliance Committees;‌ c. the Board of Directors compliance obligations;obligations;‌ d. a written Code of Conduct;Conduct;‌ e. written Policies and Procedures;Procedures;‌ f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, and Board Members, and Executive Management; Members;‌ g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program;Program;‌ i. h. Ineligible Persons screening and removal requirements;requirements;‌ j. i. notification of Government investigations or legal proceedings; andand‌ k. j. reporting of Reportable Events.Events.‌ 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CHSI fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CHSI fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC CHSI fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Claims Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Unallowable Cost Review Report, or Unallowable Cost Arrangements Review Report in accordance with the requirements of Section III.DIII.E, Section III.E Appendix B, and Appendices B and C by the deadlines for submission.Appendix C.‌ 105. A Stipulated Penalty of $1,500 for each day KDMC CHSI fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC CHSI fails to grant access.)access.)‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC as part of its Implementation Report, Annual Report, certification‌ additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 127. A Stipulated Penalty of $1,000 for each day KDMC CHSI fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC CHSI stating the specific grounds for its determination that KDMC CHSI has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC CHSI shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC CHSI receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 1- 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC ▇▇▇▇▇ and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Prime fails to establish and establish, implement or comply with any of the following obligations as described in Section III: a. a Corporate Compliance Officer;Officer;‌ b. Divisional Compliance Directors;‌ c. a Compliance Committee;Committee;‌ c. d. the Board of Directors compliance obligations;obligations as required by Section III.A.4.;‌ d. e. the management certification obligations and the development and implementation of a written Code of Conduct;process for Certifying Employees, as required by Section III.A.5.;‌ e. f. written Policies and Procedures;Procedures;‌ f. g. the development of a written training plan and the training and education of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Persons and Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; Members;‌ h. a Disclosure Program;risk assessment and internal review process;‌ i. a Disclosure Program;‌ j. Ineligible Persons screening and removal requirements;requirements;‌ j. k. notification of Government investigations or legal proceedingsproceedings;‌ l. policies and procedures regarding the repayment of Overpayments; andand‌ k. m. reporting of Reportable Events.Events.‌ 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Prime fails to engage and use an IRO, as required in by Section III.EIII.D, Appendix A, or Appendix B, and Appendix C.B.‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Prime fails to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Prime fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B.‌ 105. A Stipulated Penalty of $1,500 for each day KDMC Prime fails to grant access as required in Section VII. VII (This Stipulated Penalty shall begin to accrue on the date KDMC Prime fails to grant access.)access.).‌ 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Prime as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 127. A Stipulated Penalty of $2,500 for each day Prime fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.D, and for each day Prime fails to furnish accurate and complete records to the IRO, as required by Section III.D and Appendix A.‌ 8. A Stipulated Penalty of $1,000 for each day KDMC Prime fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Prime stating the specific grounds for its determination that KDMC Prime has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Prime shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date Prime receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Biovail and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Biovail fails to establish and implement any of the following obligations as described in Section III: a. a Chief Compliance Officer; b. a U.S. Healthcare Compliance Policy Committee; c. the Risk and Compliance Committee of the Board of Directors compliance obligationsDirector’s resolution; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Persons and Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; ; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. h. Ineligible Persons screening and removal requirements; j. ; L notification of Government investigations or legal proceedings; i. notification of Government investigations of legal proceedings; j. notification of communications with the FDA as specified in Section III.I; k. posting of Payment information as required by Section III.J; and k. reporting l. a review of Reportable Events.records reflecting the content of detailing sessions as required by Section III.K. 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Biovail fails to engage and use an IRO, as required in Section III.E, Appendix A, Appendix B, III.D and Appendix C.A. 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Biovail fails to engage and use a Peer Review Consultant, as required submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Biovail fails to submit the Implementation Report or any Annual Reports to OIG annual IRO Review Report(s) in accordance with the requirements of Section V by the deadlines for submission.III.D and Appendix B. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices B and C by the deadlines for submission. 105. A Stipulated Penalty of $1,500 for each day KDMC Biovail fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Biovail fails to grant access.) 116. A Stipulated Penalty of $50,000 5,000 for each false certification submitted by or on behalf of KDMC Biovail as part of its Implementation Report, Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Biovail fails to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC Biovail stating the specific grounds for its determination that KDMC Biovail has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC Biovail shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC Biovail receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 6 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. ‌ As a contractual remedy, KDMC APM, Park Center, ▇▇▇▇▇▇, and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails APM, Park Center, and ▇▇▇▇▇▇ fail to establish and establish, implement or comply with any of the following obligations as described in Section Sections III: a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance management certification obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. e. the development of a written training plan and the training and education of Covered Persons, Relevant Covered Persons, and Arrangements Covered Persons, Board Members, and Executive Management; g. ; f. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 Requirements;‌ g. a risk assessment and III.F.2; internal review process;‌ h. a Disclosure Program;Program;‌ i. Ineligible Persons screening and removal requirements;requirements;‌ j. notification of Government investigations or legal proceedings; andproceedings;‌ k. policies and procedures regarding the repayment of Overpayments; and‌ l. reporting of Reportable Events.Events‌ 2. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails APM, Park Center, and ▇▇▇▇▇▇ fail to engage and use an IRO, as required in by Section III.E, Appendix A, Appendix B, and or Appendix C.C.‌ 3. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails APM, Park Center, and ▇▇▇▇▇▇ fail to engage and use submit a Peer Review Consultantcomplete Implementation Report, as required Annual Report, or any certification to OIG in accordance with the requirements of Section III.D.V by the deadlines for submission.‌ 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails APM, Park Center, and ▇▇▇▇▇▇ fail to engage submit any Arrangements Review Report in accordance with the requirements of Section III.E and use the Physician Executive(s), as required in Section III.A.6.Appendix B.‌ 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage APM, Park Center, and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails ▇▇▇▇▇▇ fail to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Claims Review Report in accordance with the requirements of Section III.D, Section Section‌‌ III.E and Appendices B and Appendix C or fails to repay any Overpayment identified by the deadlines for submission.IRO as required by Appendix C. 106. A Stipulated Penalty of $1,500 for each day KDMC fails APM, Park Center, and ▇▇▇▇▇▇ fail to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC fails APM, Park Center, and ▇▇▇▇▇▇ fail to grant access.)access.)‌ 117. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC APM, Park Center, and ▇▇▇▇▇▇ as part of its their Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or otherwise required by this CIA.CIA.‌ 128. A Stipulated Penalty of $2,500 for each day APM, Park Center, and ▇▇▇▇▇▇ fail to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.E., and for each day APM, Park Center, and ▇▇▇▇▇▇ fail to furnish accurate and complete records to the IRO, as required by Section III.E and Appendix A.‌ 9. A Stipulated Penalty of $1,000 for each day KDMC fails APM, Park Center, and ▇▇▇▇▇▇ fail to comply fully and adequately with any obligation of this CIA. OIG shall provide notice to KDMC APM, Park Center, and ▇▇▇▇▇▇ stating the specific grounds for its determination that KDMC has APM, Park Center, and ▇▇▇▇▇▇ have failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC APM, Park Center, and ▇▇▇▇▇▇ shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC receives the date APM, Park Center, and ▇▇▇▇▇▇ receive this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 8 of this Section.Section.‌

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC Khanna and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day Khanna fails to establish, implement or comply with any of the following obligations as described in Section III: a. post a notice in accordance with the requirements of Section III.A; b. complete the training required for Khanna and Covered Persons and maintain training records, in accordance with the requirements of Section III.B; c. create and maintain a Prescription Tracking System, in accordance with the requirements of Section III.C; d. screen Covered Persons in accordance with the requirements of Section III.E; require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.E; or maintain copies of print screens from search results to demonstrate the required screening has been performed in accordance with the requirements of Section III.E; e. notify OIG of a government investigation or legal proceeding, in accordance with the requirements of Section III.F; f. repay any Overpayments as required by Section III.G and Appendix B; g. report a Reportable Event in accordance with Section III.H; or h. provide to OIG the certifications required by Section III.I relating to any third party ▇▇▇▇▇▇ engaged by Khanna during the term of the IA. 2. A Stipulated Penalty of $1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Khanna fails to establish engage and implement any of the following obligations use an IRO, as described in required by Section III:III.D, Appendix A, or Appendix B. a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 23. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Khanna fails to engage and use an IROtimely submit (a) a complete Implementation Report or Annual Report, as required (b) a certification to OIG in accordance with the requirements of Section III.EV, Appendix A, Appendix B, and Appendix C.or (c) a complete response to any request for information from OIG. 34. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Peer Review Consultant, as required in Section III.D. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Khanna fails to submit the Implementation any Quarterly Claims Review Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Prescription Review Report in accordance with the requirements of Section III.D, Section III.E III.D and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B. 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC Khanna fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC Khanna fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Khanna as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIAIA. 127. A Stipulated Penalty of $1,000 for each day KDMC Khanna fails to grant the IRO access to all records and personnel necessary to complete the reviews listed in Section III.D, and for each day Khanna fails to furnish accurate and complete records to the IRO, as required by Section III.D and Appendix A. 8. A Stipulated Penalty of $1,000 for each day Khanna fails to comply fully and adequately with any obligation of this CIAIA. OIG shall provide notice to KDMC Khanna stating the specific grounds for its determination that KDMC Khanna has failed to comply fully and adequately with the CIA IA obligation(s) at issue and steps KDMC the Khanna shall take to comply with the CIAIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC the date Khanna receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 7 of this Section.

Stipulated Penalties for Failure to Comply with Certain Obligations. As a contractual remedy, KDMC ▇▇▇▇▇▇▇▇ and OIG hereby agree that failure to comply with certain obligations as set forth in this CIA IA may lead to the imposition of the following monetary penalties (hereinafter referred to as “Stipulated Penalties”) in accordance with the following provisions. 1. A Stipulated Penalty of $2,500 1,000 (which shall begin to accrue on the day after the date the obligation became due) per obligation for each day Klurfeld fails to establish, implement or comply with any of the following obligations as described in Section III: a. appoint a Compliance Officer as required by Section III.A; b. written Policies and Procedures required by Section III.B; c. post a notice in accordance with the requirements of Section III.C; d. complete the training required for Covered Persons and maintain training records, in accordance with the requirements of Section III.D; e. screen Covered Persons in accordance with the requirements of Section III.F; require Covered Persons to disclose if they are excluded in accordance with the requirements of Section III.F; or maintain copies of print screens from search results to demonstrate the required screening has been performed in accordance with the requirements of Section III.F; f. notify OIG of a government investigation or legal proceeding, in accordance with the requirements of Section III.G; g. establish policies and procedures regarding the repayment of Overpayments; h. repay any Overpayments as required by Section III.H and Appendix B; or i. report a Reportable Event in accordance with Section III.I. 2. A Stipulated Penalty of $1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Klurfeld fails to establish engage and implement any of the following obligations use an IRO, as described in required by Section III:III.E, Appendix A or Appendix B. a. a Compliance Officer; b. a Compliance Committee; c. the Board of Directors compliance obligations; d. a written Code of Conduct; e. written Policies and Procedures; f. the training of Covered Persons, Relevant Covered Persons, Arrangements Covered Persons, Board Members, and Executive Management; g. the Focus Arrangements Procedures and/or Focus Arrangements Requirements described in Sections III.F.1 and III.F.2; h. a Disclosure Program; i. Ineligible Persons screening and removal requirements; j. notification of Government investigations or legal proceedings; and k. reporting of Reportable Events. 23. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Klurfeld fails to engage and use an IROtimely submit (a) a complete Implementation Report or Annual Report, as required (b) a certification to OIG in accordance with the requirements of Section III.EV, Appendix A, Appendix B, and Appendix C.or (c) a complete response to any request for information from OIG. 34. A Stipulated Penalty of $2,500 1,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Peer Review Consultant, as required in Section III.D. 4. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Physician Executive(s), as required in Section III.A.6. 5. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use a Medical Director of the Cardiac Catheterization Laboratory, as required in Section III.A.7. 6. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to engage and use the Board Compliance Expert, as required in Section III.A.4. 7. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC Klurfeld fails to submit the Implementation Report or any Annual Reports to OIG in accordance with the requirements of Section V by the deadlines for submission. 8. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Compliance Program Review Report, as required in Section III.A.4.a.v for the first, third, and fifth Reporting Periods. 9. A Stipulated Penalty of $2,500 (which shall begin to accrue on the day after the date the obligation became due) for each day KDMC fails to submit the Systems Review Report by the Peer Review Consultant, the annual Monitoring Reports by the Peer Review Consultant, the annual Interventional Cardiac Procedures Review Report, Arrangements Review Report, or Unallowable Cost Quarterly Claims Review Report in accordance with the requirements of Section III.D, Section III.E and Appendices Appendix B and C or fails to repay any Overpayment identified by the deadlines for submission.IRO, as required by Appendix B. 105. A Stipulated Penalty of $1,500 1,000 for each day KDMC ▇▇▇▇▇▇▇▇ fails to grant access as required in Section VII. (This Stipulated Penalty shall begin to accrue on the date KDMC ▇▇▇▇▇▇▇▇ fails to grant access.) 116. A Stipulated Penalty of $50,000 for each false certification submitted by or on behalf of KDMC Klurfeld as part of its Implementation Report, any Annual Report, additional documentation to a report (as requested by the OIG), or as otherwise required by this CIAIA. 127. A Stipulated Penalty of $1,000 for each day KDMC ▇▇▇▇▇▇▇▇ fails to comply fully grant the IRO access to all records and adequately with any obligation of this CIA. OIG shall provide notice personnel necessary to KDMC stating complete the specific grounds for its determination that KDMC has failed to comply fully and adequately with the CIA obligation(s) at issue and steps KDMC shall take to comply with the CIA. (This Stipulated Penalty shall begin to accrue 10 days after KDMC receives this notice from OIG of the failure to comply.) A Stipulated Penalty as described in this Subsection shall not be demanded for any violation for which OIG has sought a Stipulated Penalty under Subsections 1-11 of this Section.reviews listed in