2023 Board Resources

responsible for (1) developing and implementing compliance policies and procedures; (2) providing at least quarterly reports to the Audit Committee of the Board of Directors; (3) monitoring the day-to-day compliance activities at Banner; and (4) managing the reporting obligations under the CIA. B. Area Compliance Program Directors Banner must appoint and maintain the Area Compliance Program Director (Compliance Officer) position for the duration of the CIA. The Compliance Officers will help implement the policies, procedures, and practices designed to ensure compliance with the CIA obligations and with Federal health care program requirements. The Compliance Officers will also monitor the day-to-day compliance activities. C. System Compliance Committee Banner must maintain its existing System Compliance Committee for the duration of the CIA. The Committee will meet at least quarterly and will support the Chief Compliance Officer in fulfilling his responsibilities. D. Audit Committee The Audit Committee of the Board of Directors will meet at least quarterly to review and oversee Banner’s Compliance Program. At the end of the year, the Audit Committee will adopt a resolution summarizing its review of the Compliance Program and concluding that, to the best of its knowledge, Banner has implemented an effective Compliance Program. The Audit Committee will also describe the documents and other materials reviewed, as well as any additional steps taken, in its oversight of the Compliance Program. E. Senior Management Certain Banner senior management (Certifying Employees) must monitor and annually certify that their department(s) and/or business area(s) are in compliance with applicable Federal health care program requirements and the obligations of the CIA. Certifying Employees are the members of Banner’s Senior Leadership Team and the Operating Committee. Specifically, Certifying Employees must sign a certification that: (1) they have been trained on and understand the compliance requirements and responsibilities of their areas; (2) their job responsibilities include ensuring compliance with all applicable Federal health care program requirements, CIA obligations, and Banner policies, and they have taken steps to promote such compliance; (3) to the best of their knowledge, their areas are in compliance with all applicable Federal health care program requirements and CIA obligations; and (4) they understand that their certifications will be provided to and relied upon by the United States. These certifications will be included in the Annual Report submitted to the OIG. Compliance Documents Banner must maintain written policies and procedures regarding the operation of its Compliance Program, including the Compliance Program requirements outlined in the CIA and Banner’s II.