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Policy on Reporting Issues and Areas of Non-Compliance <br /> PURPOSE: <br /> NSMT has adopted this Reporting Potential Issues or Areas of Non-Compliance Policy to provide an overview <br /> of the responsibilities of both the employees and the Compliance Department to ensure NSMT operates within <br /> the parameters of all applicable healthcare laws and regulations. <br /> POLICY AND PROCEDURE: <br /> I. INTRODUCTION <br /> Adherence to the NSMT Compliance Program is vital. Accordingly, violations of law or the program will <br /> not be tolerated. Violators will be subject to corrective and disciplinary action in accordance with NSMT <br /> disciplinary policy. Violators may also be subject to state and federal penalties. Management is <br /> responsible for ensuring that employees are aware of and adhere to the NSMT Compliance Program. For <br /> clarification or guidance on any point in the Compliance Program, please contact the NSMT Compliance <br /> Officer. <br /> II. DUTY TO REPORT AND COMPLIANCE OFFICER INVESTIGATIONS <br /> Employees are expected to report any suspected violations of the Compliance Program, or other <br /> irregularities to their supervisor, manager, or the Compliance Officer. If the employee wishes to remain <br /> anonymous, that employee may submit his/her report through the anonymous NSMT notification portal <br /> found in E-pro under the anonymous incident reporting tab. All reports must contain sufficient <br /> inforniation for the Compliance Officer to investigate the concerns raised. No adverse action or <br /> retribution of any kind will be taken by the Company against an employee solely because he or she <br /> reports in good faith a suspected violation of the Compliance Program or other irregularity by any person <br /> other than the reporting employee. The Company will attempt to treat such reports confidentially to <br /> protect the identity of the employee who has made a report to the maximum extent consistent with fair <br /> and rigorous enforcement of Compliance Program. <br /> Any manager, supervisor, or other high-ranking employee who receives a report of a suspected violation <br /> or irregularity shall contact the Compliance Officer regarding this report. <br /> Upon receipt of a suspected compliance violation, the NSMT Compliance Officer will immediately begin <br /> a detailed investigation. The investigation by the Compliance Officer shall include interviews and the <br /> review of relevant documents. If the Compliance Officer believes that the integrity of an investigation <br /> may be compromised because of the presence of employees under investigation, the employee(s) <br /> allegedly involved in the misconduct may be removed from his/her present work activity, with or without <br /> pay, pending the outcome of the investigation. G <br /> The Compliance Officer will strive to keep all concerns/complaints confidential to the extent it is possible <br /> to do so. <br /> III. CORRECTIVE ACTION <br /> 7 <br />