Audit Policies.

Auditing is a significant part of the comapnys compliance efforts. Properly executed, audits
will enable to identify conduct which may violate the federal and state laws or detect
weaknesses in the claim development and submission process. Audits also will enable to
appropriately target and measure the effectiveness of its educational efforts, ensure that
appropriate corrective actions have been taken and quickly identify problems in the claim
development and submission process which give rise to civil or criminal exposure to the .

1. Auditing Process. The will conduct audits in accordance with an audit schedule established
from time-to-time by the Compliance Committee. The audits will be executed in accordance
with the policies and procedures contained in the applicable auditing tools or protocol utilized by
the . will devote such resources as are reasonably necessary to ensure that the audits are (1)
adequately staffed; (2) by persons with appropriate knowledge and experience to conduct the
audits; (3) utilizing audit tools and protocols which are periodically updated to reflect changes in
applicable laws and regulations.

2. Audit Plan.
(a) New Employee Audits. It is the policy of the and the responsibility of each manager to
ensure that employees who are new to a position which has a direct impact on the claim
development and submission process are provided adequate and appropriate training. One
mechanism for ensuring that each new employee adequately understands the essential element of
his/her job functions sufficiently to ensure the accuracy of the s claims is to audit the new
employees work. Accordingly, it is the policy of the to review the work of new employees in
the manner set forth below:


3 Conducting the Audit
(a) Participants. The will involve key members of the financial department and staff in the
auditing process. When appropriate, the will engage outside resources to assist it in the auditing
process.
(b) Sample Selection. Sample selection is an important part of the auditing process as the
integrity of the sampling process directly affects the reliability of the outcome. Sample selection
should be done in a manner that ensures the integrity of the samples selected. Where a sample
selection is used for auditing, the audit will utilize statistically valid sampling methodologies for
baseline, new employee or periodic audits.
(c) Use of Audit Tools. The audit tools which are a part of auditing process should be designed
to be simple and comprehensive tools for auditing various types of claims. Each audit tool should
contain both questions that need to be answered in the auditing of the claims as well as
references to applicable rules which relate to or support the question.
(d) Audit Results. When the audit process is completed, it is incumbent upon the auditors to
carefully review the audit results and do the following:
i. If the result of the audit suggests or demonstrates that the received an overpayment that is
more than insubstantial, the auditors will report their findings to the Compliance Officer in
order for an evaluation of whether the needs to make restitution.
ii. If the auditors uncover practices or procedures which, though not resulting in overpayments,
are out of technical compliance with state or federal requirements or good accounting practices,
the will promptly initiate steps to modify the claim development and submission process to
ensure that the governments technical billing requirements are met.