NETWORK POLICY & PROCEDURE Page 1 of 5

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1 NETWORK POLICY & PROCEDURE Page 1 of 5 APPROVED FOR: COMMUNITY HEALTH NETWORK FOUNDATION, INC. COMMUNITY HEALTH NETWORK, INC. COMMUNITY HOME HEALTH SERVICES, INC. COMMUNITY HOSPITAL SOUTH, INC. COMMUNITY HOWARD REGIONAL HEALTH, INC. COMMUNITY PHYSICIAN NETWORK (A TRADE NAME OF COMMUNITY PHYSICIANS OF INDIANA, INC.) COMMUNITY WESTVIEW HOSPITAL (A TRADE NAME OF INDIANAPOLIS OSTEOPATHIC HOSPITAL, INC.) (EFFECTIVE 7/1/15 A FACILITY OF COMMUNITY HOSPITAL EAST) INDIANA PROHEALTH NETWORK, LLC. COMMUNITY HEART AND VASCULAR HOSPITAL (A TRADE NAME OF INDIANA HEART HOSPITAL) (EFFECTIVE 10/1/14 A FACILITY OF COMMUNITY HOSPITAL EAST) VISIONARY ENTERPRISES, INC. FORMULATED BY: Chief Risk and Compliance Officer EFFECTIVE/REVIEWED/REVISED: [Formerly Corp. ADM H-012] 4/1/11 Reviewed/ Revised 9/1/15 Reviewed/ Revised The Social Security Act (SSA) prohibits health care providers from using federal funds for any items or services furnished, ordered, or prescribed by an excluded individual or entity. Further, the SSA prohibits federal health care program payments made for anything that an excluded person furnishes, orders, or prescribes. This payment prohibition applies to the excluded person, anyone who employs or contracts with the excluded person, any hospital or other provider where the excluded person provides services, and anyone else. The U.S. Health and Human Services Administration, Office of Inspector General (OIG) has indicated that an effective compliance program requires an organization to address the non-employment or retention of sanctioned individuals. The Indiana Medicaid program requires Indiana Medicaid providers to check the government website for excluded individuals monthly. The Community Health Network (CHNw) meets this requirement through various exclusion checks and related activities. STATEMENT OF PURPOSE: The purpose of this policy is to describe elements of the exclusion review processes.

2 NETWORK POLICY & PROCEDURE Page 2 of 5 POLICY / PROCEDURE: 1. New Hire Exclusion Checks CHNw employment applications require the applicant to certify that s/he is not debarred, excluded or otherwise ineligible for participation in any federal health care program. Any applicant who is unable to certify to the above will not be considered for employment. A. Offers for employment are made, contingent on the results of various reference checks and federal exclusion checks. B. The CHNw human resources departments, or contracted vendor, check prospective new hires against the System for Award Management website ( and the OIG s cumulative sanction report/exclusion list ( prior to their start date. C. Documentation of the exclusion checks are maintained in the employee s personnel file. D. Any potential employee whose name is found on either the SAM or OIG exclusion lists is ineligible for employment and any offer of employment shall be withdrawn. 2. Medical Staff Credentialing A. All providers applying for medical staff privileges at a CHNw facility are checked against both the SAM and OIG exclusion lists by Medical Staff Services before membership and privileges are granted and at the time of reappointment. (The exclusion checks are performed upon initial application and at least every 2 years with the reappointment application.) B. Documentation of the exclusion checks will be maintained in the provider s credentials file. C. Medical Staff Bylaws require automatic suspension of a provider s privileges if s/he is excluded from participation in a federally-funded program (i.e., Medicare, Medicaid, and TriCare.) Providers may be reinstated after the sanction by the federally funded program is lifted. D. Members of the various medical staffs are also required by the Bylaws to notify the facility of any action taken against the practitioner by a federally funded program. E. On a monthly basis, Medical Staff Services will compare all providers in the medical staff database (e.g., CACTUS) against the OIG exclusion list. Results of these reviews will be made available to medical staff leadership and the Chief Risk and Compliance Officer upon request. 3. Indiana ProHealth Network, Inc. (ProHealth) Provider Credentialing A. At the time of initial credentialing and recredentialing (every 3 years), Indiana ProHealth Network, LLC. (ProHealth) providers are checked against both the SAM

3 NETWORK POLICY & PROCEDURE Page 3 of 5 and OIG exclusion lists to ensure that participating providers have not been sanctioned. B. On a monthly basis, ProHealth will review an updated list of newly excluded individuals, published by the OIG, to ensure that no credentialed provider has been excluded during the prior month. Results of these reviews will be made available to leadership and the Chief Risk and Compliance Officer upon request. C. Documentation of the exclusion checks will be maintained in the provider s credentials file. D. ProHealth is regularly subject to audits by payers, who also review compliance with exclusion checks for credentialed providers. Results of these third party audits are available to leadership and the Chief Risk and Compliance Officer, upon request. E. Credentialed providers are also required to notify ProHealth of any action taken against them by a federally funded program. 4. Vendor Certification A. Vendors new to the CHNw are required to complete a vendor information packet, available through Network Purchasing. The application for certification asks vendors if they have been excluded from participation in a federal program. CHNw will not conduct business with a vendor who answers yes to this question. B. Network Purchasing utilizes a Vendor Management Program (VendorMate), which checks all vendors (entities, principals and representatives) in VendorMate against the SAM and OIG exclusion lists when a new vendor is entered and on a monthly basis for most vendors. If an active exclusion is identified, Network Purchasing is notified and the vendor is not utilized. C. Lower risk vendors are checked against the SAM and OIG exclusion lists on an annual basis, rather than monthly. Lower risk vendors include those with less than $5,000 spend by the Network, representatives who do not have direct patient contact, representatives who do not have access to procedural areas and are not onsite. D. Documentation of the exclusion checks will be maintained in VendorMate. E. Any department/person who initiates a contract outside of the Network Purchasing process must do the following before offering the contract to the vendor: 1. Ask the vendor to certify in writing that they have not been excluded from participation in a federal program; and 2. Either: a. Contact the Network Purchasing contract management office to verify that the vendor is not excluded from participation in a federal program; or b. Perform a check of the SAM and OIG exclusion lists;

4 NETWORK POLICY & PROCEDURE Page 4 of 5 F. Any department/person who initiates a contract outside of the Network Purchasing process must check the SAM and OIG exclusion lists monthly to ensure that the contracted vendor has not been excluded from participation in a federal program. 4. Periodic Employee Exclusion Checks A. On a monthly basis, the CHNw human resources departments will review an updated list of newly excluded individuals, published by the OIG, to ensure that no employee has been excluded in the prior month. Results of these reviews will be made available to human resources leadership and to the Chief Risk and Compliance Officer upon request. B. Annually, the Organizational Risk department coordinates an electronic review that compares all employees to the SAM and OIG exclusion lists. C. Potential matches are forwarded to the CHNw human resource departments. The human resource departments perform manual checks of those potential matches and report the results to the Organizational Risk department. D. Any employee whose name is found on either the SAM or OIG exclusion lists is ineligible for employment and his or her employment will be terminated upon confirmation of the match. 5. Non-Staff Providers A. Services ordered by a provider who is not on the medical staff (i.e., non-staff providers ) shall not be billed until the provider has been checked against the OIG s exclusion list and it is confirmed that the provider has not been excluded. B. When a patient presents with an order from a provider who is not in the hospital system (Epic, Cerner, CPSI, etc.), the patient will be registered and services provided. Information about the non-staff physician will be sent to the Medical Staff office to verify whether the provider is excluded per the OIG s exclusion list. If the provider has been excluded, the Medical Staff office will notify registration and/or billing staff that the provider is excluded and the services will not be billed. C. Medical Staff office will also notify the Chief Risk and Compliance Officer and/or Compliance Liaison when an excluded provider is identified. 6. Follow-up if Excluded Individual is Identified A. In the event that an excluded individual is identified via paragraphs 1-5 above, the Chief Risk and Compliance Officer and the appropriate Compliance Liaison(s) will be notified. The Chief Risk and Compliance Officer and Compliance Liaisons will ensure that the appropriate departments (Human Resources; Medical Staff; Purchasing; Registration; ProHealth Credentialing; etc.) within the affected

5 NETWORK POLICY & PROCEDURE Page 5 of 5 business units are notified and necessary steps are taken with respect to the excluded individual. B. CHNw shall remove such excluded person identified in paragraphs 1-5 above from responsibility for, or involvement with, CHNw s business operations related to Federal health care programs and shall remove such excluded person from any position for which the excluded person s compensation or the items or services furnished, ordered, or prescribed by the excluded person are paid in whole or part, directly or indirectly, by Federal health care programs or otherwise with Federal funds at least until such time as the excluded person is reinstated into participation in the Federal health care programs. C. If CHNw learns that an individual has been charged with a criminal offense that may result in an exclusion from Federal health care programs under 42 U.S.C. 1320a-7(a), 1320a-7(b)(1)-(3), or is proposed for exclusion during the individual s employment or contract term or during the term of a physician s or other practitioner s medical staff privileges, CHNw will take all appropriate actions to ensure that the responsibilities of that individual have not and will not adversely affect the quality of care rendered to any beneficiary, patient, or resident, or any claims submitted to any Federal health care program. RELATED DOCUMENTS: COMP-010, Compliance Education COMP-017, Non-Retaliation and Whistleblower Protections HR-003, Corrective Action NRCP Resource Manual APPROVED BY: _[~ORIGINAL SIGNATURE ON FILE IN ADMINISTRATION~] Bryan A. Mills, President and CEO, Community Health Network