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Policy on Excluded or Debarred Persons or Entities <br /> PURPOSE: <br /> NSMT has adopted this Excluded or Debarred Persons or Entities Policy in order to ensure compliance with all <br /> applicable federal or state laws and regulations related to the employment of individuals or entities who are <br /> ineligible to participate in any federal or <br /> state healthcare reimbursement program including, but not limited to, Medicare and Medicaid. <br /> POLICY ANDPROCEDURE: <br /> I. INTRODUCTION <br /> NSMT is committed to hire and retain employees; independent contractors and officers ("employees")who will <br /> meet NSMT's high ethical standards for employment. NSMT has a duty to avoid hiring or retaining employees <br /> or contractors who have engaged in unlawful conduct including fraud or financial irregularities or other conduct <br /> which may harm other employees, patients, or the general public. <br /> NSMT will not knowingly employ any individual or entity that is listed by a federal agency as excluded, <br /> debarred, or otherwise ineligible for federal programs. NSMT shall not allow any person convicted in any local, <br /> state or federal court of any felony to hold the position of officer or director of the Company. <br /> II. SCREENING <br /> Prior to hiring any new employee, or contracting with entities, the OIG (Office of Inspector General) List of <br /> Excluded Individuals and Entities (LEIS) and GSA (General <br /> Services Administration) Excluded Parties List(EPLS) are reviewed to ensure none are excluded from <br /> participating in federal programs. For new employees, the OIG and GSA exclusion checks are conducted as part <br /> of an overall background check. If the potential employee is a clinician, it is the responsibility of NSMT to <br /> conduct the above verification on all potential hires. For new contractors,the exclusion checks shall be <br /> conducted as part of the initial due diligence process. A copy of verification of the screening for the new <br /> contractor will be sent to the Compliance Department and maintained on file. After the initial screening checks <br /> are conducted, the Compliance Depai tinent, or its designee shall conduct regular checks of the OIG and GSA <br /> exclusion lists to ensure no employees and/or contractors are listed as excluded or debarred. <br /> III. DOCUMENTATION OF COMPLETED SCREENINGS <br /> The Compliance Department designee will maintain confirmation that the screenings have been completed. As <br /> requested, or contractually required, the Compliance Officer or their designee will maintain a log that regular <br /> screenings have occurred and the results of the screenings. <br /> POLICY REVIEW <br /> The NSMT Compliance Officer will review and update this Policy and all Compliance policies when <br /> necessary in the normal course of its review of the NSMT Compliance Program. <br /> 10 <br />