has provided training to
applicable Covered Persons that satisfies the requirements set forth above in
Section III.C.2 within 60 days prior to the Effective Date, OIG will credit that
training for purposes of satisfying Tenet's Specific Training obligations for
the first Reporting Period of this CIA.
3.
CERTIFICATION.
EACH INDIVIDUAL WHO IS REQUIRED TO ATTEND
TRAINING SHALL CERTIFY, IN WRITING OR IN ELECTRONIC FORM, IF APPLICABLE, THAT HE
OR SHE HAS RECEIVED THE REQUIRED TRAINING.
THE CERTIFICATION SHALL SPECIFY THE
TYPE OF TRAINING RECEIVED AND THE DATE RECEIVED.
THE COMPLIANCE OFFICER (OR
DESIGNEE) SHALL RETAIN THE CERTIFICATIONS, ALONG WITH ALL COURSE MATERIALS.
THESE SHALL BE MADE AVAILABLE TO OIG, UPON REQUEST.
4.
QUALIFICATIONS OF TRAINER.
PERSONS PROVIDING THE TRAINING SHALL
BE KNOWLEDGEABLE ABOUT THE SUBJECT AREA.
5.
UPDATE OF TRAINING.
TENET SHALL REVIEW THE TRAINING ANNUALLY,
AND, WHERE APPROPRIATE, UPDATE THE TRAINING TO REFLECT CHANGES IN FEDERAL HEALTH
CARE PROGRAM REQUIREMENTS, ANY ISSUES DISCOVERED DURING AUDITS OR REVIEWS, AND
ANY OTHER RELEVANT INFORMATION.
6.
COMPUTER-BASED TRAINING.
TENET MAY PROVIDE THE TRAINING REQUIRED
UNDER THIS CIA THROUGH APPROPRIATE COMPUTER-BASED TRAINING APPROACHES.
IF TENET
CHOOSES TO PROVIDE COMPUTER-BASED TRAINING, IT SHALL MAKE AVAILABLE
APPROPRIATELY QUALIFIED AND KNOWLEDGEABLE STAFF OR TRAINERS TO ANSWER QUESTIONS
OR PROVIDE ADDITIONAL INFORMATION TO THE INDIVIDUALS RECEIVING SUCH TRAINING.
7.
EXCEPTED PHYSICIANS.
NOTWITHSTANDING ANY OTHER PROVISION OF THIS
SECTION III.C, TENET SHALL:
(A) MAKE THE GENERAL AND SPECIFIC TRAINING
AVAILABLE TO EXCEPTED PHYSICIANS; (B) USE ITS BEST EFFORTS TO ENCOURAGE THE
ATTENDANCE AND PARTICIPATION OF EXCEPTED PHYSICIANS IN THE GENERAL AND SPECIFIC
TRAINING; AND (C) MAINTAIN RECORDS OF THE PERCENTAGE OF ALL EXCEPTED PHYSICIANS
WHO ATTEND SUCH TRAINING.
8.
COVERED CONTRACTORS.
TO THE EXTENT THAT TENET ENGAGES
CONTRACTORS WHO ARE COVERED PERSONS (COVERED CONTRACTORS), TENET MAY COMPLY WITH
THE SPECIFIC TRAINING REQUIREMENTS UNDER SECTION III.C.2 WITH RESPECT TO THE
COVERED CONTRACTOR BY OBTAINING, AND PROVIDING TO OIG UPON REQUEST, A
CERTIFICATION FROM EACH COVERED CONTRACTOR THAT THE COVERED CONTRACTOR:
(A)
PRESENTLY HAS A PROGRAM DESIGNED TO ENSURE COMPLIANCE WITH ALL FEDERAL HEALTH
CARE PROGRAM REQUIREMENTS; AND (B) HAS RECEIVED TRAINING EQUIVALENT TO THE
SPECIFIC TRAINING REQUIRED UNDER SECTION III.C AND IN A MANNER RELEVANT TO THE
COVERED CONTRACTOR'S RESPONSIBILITIES.
D.
REVIEW PROCEDURES.
1.
TYPE OF REVIEWS.
THE FOLLOWING REVIEWS SHALL BE PERFORMED BY AN
ENTITY (OR ENTITIES), SUCH AS AN ACCOUNTING, AUDITING, OR CONSULTING FIRM
(HEREINAFTER "INDEPENDENT REVIEW ORGANIZATION" OR "IRO"), TO BE ENGAGED BY TENET
DURING THE TERM OF THE CIA:
(A) OUTLIER PAYMENTS REVIEW; (B) DRG CLAIMS REVIEW;
(C) UNALLOWABLE COSTS REVIEW; (D) FOCUS ARRANGEMENTS REVIEW; AND (E) CLINICAL
QUALITY SYSTEMS REVIEW (COLLECTIVELY THE "IRO REVIEWS").
THE WORK PLANS FOR THE
IRO REVIEWS ARE ATTACHED TO THE CIA IN APPENDICES A-E AND ARE HEREBY
INCORPORATED BY REFERENCE INTO THE CIA.
15
2.
ENGAGEMENT OF IRO(S).
WITHIN 120 DAYS AFTER THE EFFECTIVE DATE,
TENET SHALL ENGAGE THE IRO(S) TO PERFORM THE IRO REVIEWS.
TENET SHALL NOTIFY
OIG OF THE IDENTITY OF THE IRO IN THE IMPLEMENTATION REPORT REQUIRED UNDER
SECTION V.A OF THE CIA.
WITHIN 30