- C. External Reviews.

External legal counsel, accountants, auditors and other consultants or professionals may be retained for purposes of monitoring and auditing activities under the Compliance Program.

##### POLICY No. 29 n POLICY ON CORRECTIVE ACTION AND DISCIPLINARY PROCEDURES

## CORPORATE COMPLIANCE PROGRAM

##### \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

### \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ It is the Practice’s policy to ensure that all reasonable steps are taken to facilitate compliance with applicable federal, State and local laws and regulations, including, but not limited to, those involving the Medicare and Medicaid programs. Toward that end, the enforcement of the Compliance Plan and the Practice’s Policies is meant to prevent, detect and deter instances of non-compliance and wrongdoing. It also is the Practice’s policy that the standards of conduct set forth in the Compliance Plan and the Practice’s Policies shall be consistently enforced through appropriate disciplinary mechanisms. If a violation of any applicable law, regulation or standard of conduct relating to the Practice’s operations is detected, the Practice shall take all reasonable steps to respond appropriately to the violation and to prevent further similar violations from occurring including, where appropriate, through modifications to the Compliance Program. It is further the Practice’s policy that if it learns: (i) of a material violation of any applicable law or regulation that is not known to the relevant governmental agency but is reasonably likely to be of interest to that agency; or (ii) that any statement previously made by or on behalf of the Practice to any governmental agency is false or incorrect in any material respect, then, upon the advice of counsel, the Practice shall, when appropriate, voluntarily and promptly (after internal investigation) self-report the matter to that agency. Nothing in this Compliance Plan shall be deemed to require a waiver of any right, privilege or immunity conferred upon the Practice by State or federal law.

The Practice considers the actions of each employee under the Compliance Plan, including the Code of Conduct, to be significant indications of judgment and competence in job performance. Accordingly, those actions constitute an important element in the evaluation of the employee for position assignments and promotions. Any employee who disregards the Practice’s Policies shall be subject to appropriate disciplinary action depending on the severity of the violation, including probation, suspension and dismissal from employment. This includes any employee who fails to report an instance of non-compliance or wrongdoing of which he/she has knowledge, which failure to report is itself a violation of the Compliance Plan. Claims of ignorance, good intentions or bad advice shall not be acceptable excuses for non-compliance or wrongdoing. Any instances of an employee’s non-compliance with the Compliance Plan or any of the Practice’s Policies shall be appropriately documented in the employee’s performance review and personnel file, and may affect his/her compensation level and promotion consideration.

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