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This is an audio presentation Compliance Program Training for First Tier, Downstream and Related Entities
CONFIDENTIAL© Prime Therapeutics LLC Agenda What is the Compliance Program? What does this mean to me? Compliance Program Training 3
© Prime Therapeutics LLC Prime's Compliance Department and Program
CONFIDENTIAL© Prime Therapeutics LLC 5 Our Mission Compliance Program Training
CONFIDENTIAL© Prime Therapeutics LLC Do business with integrity and in accordance with all applicable laws and regulations Halt any such behavior as soon as reasonably possible after its discovery Implement any policy and procedure changes needed to prevent recurrences of a violation Prevent unethical or unlawful behavior Use disciplinary action as necessary Compliance Program Training
CONFIDENTIAL© Prime Therapeutics LLC Prime’s Compliance Program includes the following components: 7 Written Standards Compliance Officer and Committee Delegation of Authority Communication of Standards (Training) Monitoring, Auditing and Reporting Enforcement and Discipline Response and Prevention Fraud, Waste & Abuse Compliance Program Training
CONFIDENTIAL© Prime Therapeutics LLC Compliance Officers and Compliance Committees 8 Prime has a Chief Compliance Officer who reports directly to the Audit and Finance Committee of the Board of Directors and the CEO > The Chief Compliance Officer chairs the Compliance Committee which consists of Prime’s executives. > The Compliance Committee meets regularly and oversees a number of areas, including, but not limited to, implementation of Compliance Training, Corrective Action Plans and coverage gaps as reported from our internal audit team. > The Chief Compliance Officer also oversees the Compliance Department and the Compliance Program. Prime has a Government Programs Compliance Officer who reports directly to the Chief Compliance Officer. > The Government Programs Compliance Officer chairs the Government Programs Compliance Committee which consists of individuals from within a cross-functional group of departments within Prime. > The Government Programs Compliance Committee meets regularly and develops strategies to promote compliance, reviews significant compliance risks and ensures proper communication of compliance issues, among other functions. Compliance Program Training
CONFIDENTIAL© Prime Therapeutics LLC Prime’s Compliance Department 9 Audit (Compliance Audit and Pharmacy Audit) Government Programs Compliance Regulatory Response Licensing Privacy Compliance Program Training
CONFIDENTIAL© Prime Therapeutics LLC Prime’s active Compliance Program 10 Non-Retaliation > Prime prohibits retaliation against anyone for reporting concerns. Investigations into Compliance Issues > All reports of improper behavior are fully investigated. Corrective Actions > You are expected to perform all assigned tasks and responsibilities to meet your job expectations and standards. Compliance Program Training
CONFIDENTIAL© Prime Therapeutics LLC Reporting violations of the Code and the Compliance Program Supervisor Human Resources Manager Legal Department Compliance Department Compliance Officer Anonymous 24 Hour Hotline: Anonymous reporting on the website: services.com/primehttp://www.lighthouse- services.com/prime Anonymous REMEMBER: You can report Compliance Concerns without fear of retaliation or retribution Compliance Program Training
CONFIDENTIAL© Prime Therapeutics LLC Thank you for taking Prime’s Compliance Program training. Please make sure you are familiar with the various requirements in the Compliance Program. > Questions? Please contact the Compliance Department. > Thank you Compliance Program Training
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