be designed and scheduled by the Compliance Officer. A minimum of one (1) educational or training session or in-service program shall be offered per year to each member of the Practice’s Personnel. Targeted training also may be provided to those supervisors and practitioners who create greater legal exposure to the Practice by virtue of their job responsibilities, including the coding and billing department. The Compliance Officer may also disseminate information regarding pertinent external conferences and seminars to appropriate Practice Personnel via internal memoranda. The Compliance Officer shall be responsible for scheduling educational and training sessions with sufficient advance notice and communicating the requirement of mandatory attendance to all Practice Personnel.

It is expected and required that employees will attend the educational and training sessions, conferences and seminars for which their attendance has been specified as mandatory (unless attendance is excused due to leave of absence, vacation, illness, suspension, etc.). Attendance at these sessions and programs shall be monitored through appropriate inquiry during each employee’s annual performance review. Failure to comply with training requirements will result in disciplinary action.

Examples of topics likely to be covered during the Practice’s internal sessions and programs include:

(i) Compliance with private insurance policy requirements relevant to the employee’s respective duties and responsibilities;

- (ii) Coding requirements;
- (iii) Claim development and submission processes;
- (iv) Signing a form for a physician without the physician’s authorization;
- (v) Proper documentation of services rendered;
- (vi) Proper billing standards and procedures and submission of accurate bills for services or items rendered to Federal health care program beneficiaries; and
- (vii) The legal sanctions for submitting deliberately false or reckless billings.

The Compliance Officer will be required to hire training instructors who are sufficiently experienced in the issues presented.

These sessions and programs shall allow participants to ask questions regarding ethics and compliance issues and identify resources within the Practice that can answer subsequent questions that may arise. In addition to Practice-sponsored compliance training sessions, the Practice’s employees regularly attend professional education courses sufficient to ensure that they remain current with changes within their field of expertise. The Compliance Officer shall maintain copies of all attendance logs and materials disseminated at compliance training sessions.

Each member of the Practice’s Personnel shall be provided with a copy of the Compliance Plan, and any other documents that are pertinent to the person’s job responsibilities along with appropriate updates of these items. Within a reasonable period of time following distribution of the Compliance Plan, each person shall be required to sign and return to the Compliance Officer a copy of the Compliance Plan Awareness Certification Form, a copy of which is attached as Exhibit B, certifying the person’s receipt of and familiarity with the Compliance Plan and the

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