2023 Board Resources

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Compliance Infrastructure Does the Compliance Officer have sufficient authority to implement the compliance program? Has management provided the Compliance Officer with the autonomy and sufficient resources necessary to perform assessments and respond appropriately to misconduct? • The Chief Compliance Officer reports directly to Banner’s President/CEO and has free access to the Chairman of the Audit Committee. As a result, he has sufficient authority to implement the Compliance Program. • The Chief Compliance Officer has access to the documents necessary to investigate compliance issues and perform assessments. He can implement a bill hold for a specified health care service or group of services in order to avoid improper billing while suspected or discovered irregularities are resolved or when required by outside audits/investigations. The Chief Compliance Officer has the capability to produce candid and timely reports for effective oversight. Have compliance-related responsibilities been assigned across the appropriate levels of the organization? Are employees held accountable for meeting these compliance related objectives during the performance reviews? • The Chief Compliance Officers has 1:1 meetings with the Senior Directors in the Ethics & Compliance Department about ongoing compliance matters in their areas. In turn, the Senior Directors have team meetings with their direct reports to communicate compliance-related responsibilities. A monthly department meeting is also held to discuss key compliance initiatives and current events at Banner. • At Banner, all employees are responsible for compliance. They are obligated to report potential compliance issues, which are defined as any suspected or actual violations of the Code of Conduct, Banner policies, and laws and regulations relating to Federal health care programs. In addition, all employees are required to complete their annual compliance lessons in which they annually certify that they understand the Code of Conduct. Finally, Banner’s CIA requires that adherence to the requirements of Banner’s Compliance Program are an element of evaluating the performance of all employees. Measures to Prevent Violations What is the scope of compliance-related education and training across the organization? Has the effectiveness of such training been assessed? What policies/measures have been developed to enforce training requirements and to provide remedial training as warranted? • Banner conducts its compliance training using on-line modules, videos, and live format. Training for employees is primarily provided through on-line modules through the MyHR | Workday, and Board members receive videos and reading materials that are emailed to them. Specialized compliance courses are also provided based on specific job requirements or identified risk areas. • Compliance training is annually reviewed to ensure that the material is relevant, current, and complies with applicable laws and regulations.

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