2023 Board Resources

• The Charter of the Audit Committee establishes that this Committee is responsible for overseeing the system’s compliance activities to ensure compliance with applicable laws and regulations. The Audit Committee’s role in providing oversight for Banner’s Compliance Program as well as its obligation to adopt an annual resolution under the CIA is set forth in the policy entitled Board Compliance Program Oversight and Resolution Process. Pursuant to this policy, the Chief Compliance Officer must provide quarterly reports on the effectiveness of Banner’s Compliance Program, which may include the following: o A summary of quarterly certifications and exception reports submitted by senior management; o Minutes of the Senior Compliance Committee; o Completion rates for compliance courses; o Compliance audit plan, including the status of any audits and expected completion dates; o Information about internal investigations of significant compliance issues; o Updates regarding any audits or investigations conducted by the government or government contractors that resulted in corrective action plans, litigation, sanctions, or increased government scrutiny; o Details about compliance reportable events; and o Other relevant information about Compliance Program. As part of this process, the Chief Compliance Officer would also report compliance violations to the Audit Committee and, when appropriate, to the entire Board. What policies govern the reporting to government authorities of probable violations of the law? • Banner’s CIA requires that the OIG Monitor receive notification upon the determination that the following events have occurred: o Substantial overpayment o A matter that a reasonable person would consider a probable violation of criminal, civil, or administrative laws applicable to any Federal health care program for which penalties or exclusion may be authorized; o The employment of or contracting with an ineligible person; and o The filing of a bankruptcy petition by Banner. Banner’s 60 Day Report/Repay Overpayments policy requires that Banner reports and returns overpayments to Federal health care programs within 60 days as required by law. Overpayments may be returned to the applicable Federal health care program using a claims adjustment, credit balance, self- reported refund, or other reporting process. When an overpayment is associated with a reportable event under the CIA, Banner provides the OIG Monitor with a copy of the notification and repayment.