CORPORATE COMPLIANCE POLICIES AND PROCEDURES DRA NOTICE POLICY (CPL-007) Last Revision Date: September 9, 2014

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1 CORPORATE COMPLIANCE POLICIES AND PROCEDURES DRA NOTICE POLICY (CPL-007) Last Revision Date: September 9, 2014 Original Date: March 5, 2013

2 OMNICARE DRA NOTICE POLICY CPL-007 (SEPTEMBER 2014) I. PURPOSE Omnicare, Inc. ( Omnicare ) has a longstanding commitment to adhering to high standards of professional practice and ethics, as well as all applicable laws and regulations that govern our industry. In addition, Omnicare has entered into a Corporate Integrity Agreement ( CIA ) with the Office of Inspector General of the United States Department of Health and Human Services to promote compliance with the statutes, regulations, and written directives of Medicare, Medicaid, and all other Federal health care programs (as defined in 42 U.S.C. 1320a-7b(f)) (Federal health care program requirements). The specific purpose of this DRA Notice Policy ( Policy ) is to ensure Omnicare s compliance with the affirmative obligations of Section 6032 of the Federal Deficit Reduction Act of 2005 ( DRA ). The DRA requires organizations that make or receive annual Medicaid payments of $5 million to provide to employees, agents and contractors detailed information about the federal False Claims Act ( FCA ) and any state laws that pertain to civil or criminal penalties under such laws, including the role of such laws in preventing and detecting fraud, waste and abuse in federal health care programs. II. POLICY A. Scope. This Policy governs Omnicare s processes and procedures for providing the notice(s) required by the DRA for all employees and all locations. B. Definitions. [N/A] C. Requirements. Omnicare shall distribute to its employees, contractors, and agents detailed information regarding the federal False Claims Act and applicable state false claims acts. This notice shall be provided through Omnicare s Code of Business Conduct and Ethics and through other means and shall include the following specific topics: 1. Definition of a False Claim. The federal government defines (in part) a false claim as knowingly and willfully offering, paying, soliciting or receiving any money, gifts, kick-backs, rebates or any other type of value, remuneration or services in return for the referral of patients or to induce the purchase, lease or ordering of any item, good or service for which payment may be made by the federal or state government. 1

3 2. Examples of Activities that Could Result in False Claims: a. Payment of an incentive each time a patient is referred to Omnicare. b. Provision or receipt of free or significantly discounted billing, rent or other services. c. Payment for services in excess of their fair market value. d. Forgiveness of a debt absent a charitable or risk management purpose. e. Billing for supplies or services not provided or provided in less than billed amounts. f. Misrepresenting or overcharging for products or services actually provided. g. Duplicate billing for services actually rendered. h. Falsely certifying that services were medically necessary or failure to perform a service. i. Falsely certifying that an individual meets the Medicare requirements for certain services. j. Seeking to increase reimbursement by improper billing procedures such as upcoding (changing a procedure code in order to obtain higher reimbursement for the procedure actually performed), or unbundling (dividing a procedure or service into two or more parts to obtain higher reimbursement). k. Offering to or transferring money, gifts, or other items of value to a private party in order to receive that party s business. l. Accepting money, gifts, or other items of value from a private party. m. Accepting of overpayments from the government. 3. Damages and Penalties. Under the federal FCA, any entity or person who knowingly submits or causes a false claim to be submitted to the government may be liable for damages. Damages can consist of up to three times the payment that was made in error, plus additional penalties of $5,500 to $11,000 per false claim. 4. Qui Tam Whistleblower Provisions and Rights of Employees, Agents and Contractors. The FCA permits a person with actual knowledge of false claims activity to file a lawsuit on behalf of the federal government. These socalled qui tam or whistleblower provisions of the FCA contain detailed procedures for how to file such a lawsuit. In certain circumstances, the person who files the lawsuit, known as a qui tam relator, may be entitled to share a percentage of any recovery received by the federal government as a result of the lawsuit. Once the suit is filed by the relator/whistleblower, the Department of Justice then decides on behalf of the government whether to join the relator/whistleblower in prosecuting these cases. If the case is successful, the 2

4 relator may share in the recovery amount. The FCA also protects employees from retaliation or discrimination in the terms and conditions of their employment based on lawful acts of the employee done in furtherance of an action under the FCA. 5. Applicable State Law. A growing number of states have false claims acts that are either identical or similar to the federal FCA. Those statutes typically allow individuals to bring issues to the attention of the state government and possibly share in a portion of any recoveries. These laws also protect employees from retaliation or discrimination in the terms and conditions of their employment based on lawful acts done in furtherance of an action under the state false claims act. A number of states also have statutes which impose civil or criminal penalties for fraud against state health care programs, including Medicaid. Additionally, a number of states provide for administrative penalties in cases of fraud against the Medicaid program. Finally, most states have criminal provisions of general application that prohibit fraud, larceny, and false statements to government agencies that may be applicable in addressing health care fraud, waste, and abuse. Omnicare is committed to complying with all such laws. In addition to the descriptions of the relevant federal laws in this policy and elsewhere, the Company maintains and makes available state-bystate descriptions of the relevant state laws that create civil or criminal penalties for false claims and statements and the whistleblower protections under such state laws. 6. Federal Administrative Remedies for False Claims and Statements. The Program Fraud Civil Remedies Act of 1986, codified at 31 USC 3801 to 3812, was enacted to allow federal agencies, including the United States Department of Health and Human Services, to pursue administrative actions against individuals or organizations who knowingly submit false, fictitious or fraudulent claims or statements for benefits or payments under a federal agency program. Penalties under this law include civil money penalties of up to $5,000 per false claim or statement and up to twice the amount claimed in lieu of damages. This law was enacted as a means to address lower dollar frauds, generally applying to claims of $150,000 or less, and offers an opportunity to resolve false claims cases through an administrative process that can be more streamlined than typical FCA cases, which are prosecuted in the federal court system. 3

5 III. REFERENCES Deficit Reduction Act of 2004, Pub. L (2006) ( DRA ) 31 U.S.C to 3733 [Federal False Claims Act] 31 U.S.C to 3812 [Federal Administrative Remedies for False Claims and Statements] Omnicare DRA Notice Policy Procedures CPL-007- PROC (September 2014) 4

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