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This policy applies to all RowanSOM operating units, including but not limited to hospitals, physician practices, and outpatient centers.

IV.   DEFINITIONS

1. Arrangements - every arrangement or transaction that:
1. Involves, directly or indirectly, the offer, payment, solicitation, or receipt of anything of value; and is between RowanSOM and any actual or potential source of health care business or referrals to RowanSOM or any actual or potential recipient of health care business or referrals from RowanSOM. The term "source" shall mean any physician, contractor, vendor, or agent; and the term "health care business or referrals" shall be read to include referring, recommending, arranging for, ordering, leasing or purchasing of any good, facility, item, or service for which payment may be made in whole or in part by a Federal health care program; or
2. Is between RowanSOM and a physician (or a physician's immediate family member as defined at 42 C.F.R. §411.351)) who makes a referral (as defined at 47 U.S.C. §1395nn(h)(5)) to RowanSOM for designated health services (as defined at 42 U.S.C. §1395nn(h)(6))
2. Focus Arrangement - every arrangement or transaction that:
1. Involves directly or indirectly, the offer or payment of anything of value and is between RowanSOM and any actual source of health care business or referrals to RowanSOM; or
2. Between RowanSOM and a physician (or a physician's immediate family member (as defined at 42 C.F.R. §411.351)) who makes a referral (as defined at 42 U.S.C. §1395nn(h)(5)) to RowanSOM for designated health services (as defined at 42 U.S.C. §1395nn(h)(6)).
3. The following shall not be considered Focus Arrangements: any Arrangement that satisfies the requirements of 42 C.F.R. 411.356 (ownership of investment interests), 42 C.F.R. 411.457(g) (remuneration unrelated to the provision of designated health services), 42 C.F.R. 411.357(i) (payments by a physician for items and services), 42 C.F.R. 411.357(m) (medical staff incidental benefits), 42 C.F.R. 411.357(o) (compliance training), 42 C.F.R. 411.357(q) (referral services), 42 C.F.R. 411.357(s) (professional courtesy), 42 C.F.R. 411.357(u) (community-wide health information systems), or any exception to the prohibition of 42 U.S.C. 1395nn enacted which does not require a written agreement
3. Covered Persons includes:
1. All officers, trustees, and employees of RowanSOM (excluding housekeeping, maintenance, and food service employees); and
2. All contractors, subcontractors, agents and other persons who provide patient care items or services or who perform billing or coding functions on behalf of RowanSOM excluding vendors whose sole connection with RowanSOM is selling or otherwise providing medical supplies or equipment to RowanSOM and who do not bill the Federal health care programs for such medical supplies or equipment; and
3. RowanSOM employed medical staff. Covered Persons does not include part-time or per diem employees, contractors, subcontractors, agents or other persons who are not reasonably expected to work more than 160 hours per year, except that any such individuals shall become Covered Persons at the point when they work more than 160 hours during the calendar year.
4. Arrangements Covered Persons includes each Covered Person involved with the development, approval, management, or review of RowanSOM Arrangements.
5. Database or Contract Management System is the electronic contract management system, authorized by the Senior Vice President and General Counsel to process, execute, and store all arrangements and focused arrangements entered into on behalf of RowanSOM.

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