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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 Rowan SOM 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.
4. 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.

D. "Arrangements Covered Persons" - includes each Covered Person involved with the development, approval, management, or review of RowanSOM Arrangements.

E. "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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1. Each party involved in the Focus Arrangement;
2. The type of Focus Arrangement (e.g., physician employment contract, medical directorship, lease agreement);
3. The term of the Focus Arrangement, including the effective and expiration dates and any automatic renewal provisions;
4. The amount of compensation to be paid pursuant to the Focus Arrangement and the means by which compensation is paid;
5. The methodology for determining the compensation under the Focus Arrangement, including the methodology used to determine the fair market value of such compensation; and an attestation by the compliance officer that he/she finds the FMV analysis methodology reasonable for the arrangement.
6. Whether the amount of compensation to be paid pursuant to the Focus Arrangement is determined based on the volume or value of referrals between the parties;
7. Whether each party has fulfilled the requirements of Section III.D.2 of the CIA which shall include:
   1. ensuring that each Focus Arrangement is set forth in writing for a minimum of one year and signed by RowanSOM and the other parties to the Focus Arrangement;
   2. in the written agreement a requirement that all individuals who meet the definition of Arrangements Covered Persons shall comply with RowanSOM Compliance Program, including the training related to the Anti-Kickback Statute and the Stark Law; additionally it must be documented in the contract that RowanSOM has provided each party to the Focus Arrangement with a copy of its Code of Conduct and Stark Law and Anti-kickback Statute Policies and Procedures; and
   3. in each written Focus Arrangement a certification by the parties to the Focus Arrangement that the parties shall not violate the Anti-Kickback Statute and the Stark Law with respect to the performance of the Focus Arrangement.
8. Whether the Arrangement satisfies the requirements of an Anti-Kickback safe harbor and/or a Stark Law exception or a safe harbor, as applicable.

E. Focus Arrangements Requirements: Non-contractual transactions involving non-monetary compensation

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