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Maricopa County

Special Health Care District

Board of Directors Formal Meeting

March 26, 2014 1:00 p.m.

Agenda

Maricopa Medical Center Administration Building Auditoriums 1 and 2 2601 E. Roosevelt Phoenix, AZ 85008 Clerk’s Office 602-344-5177 Fax 602-344-0892

Wednesday, March 26, 2014 1:00 p.m.

If you wish to address the Board, please complete a speaker’s slip and deliver it to the Clerk of the Board. If you have anything you wish distributed to the Board and included in the official record, please hand it to the Clerk who will distribute the information to the Board Members and Maricopa Integrated Health System Senior Staff. Speakers are limited to (3) three minutes. (NOTE: One or more of the members of the Board of Directors of the Maricopa County Special Health Care District will attend either in person or by telephone conference call or video communications.) Pursuant to A.R.S. § 38-431.03(A)(3), or any applicable and relevant state or federal law, the Board may vote to recess into an Executive Session for the purpose of obtaining legal advice from the Board’s attorney or attorneys on any matter listed on the agenda. Pursuant to A.R.S. § 38-431.03(A)(4), or any applicable and relevant state or federal law, the Board may vote to recess into an Executive Session for the purpose of consulting with its attorneys to consider its position and instruct its attorneys regarding the Board’s position regarding any contracts that are subject to negotiations, in pending or contemplated litigation, or in settlement discussions conducted in order to avoid or resolve litigation, and that are listed on the General Session agenda for discussion or action or both. The Board also may wish to discuss any items listed for Executive Session discussion in General Session, or the Board may wish to take action in General Session on any items listed for discussion in Executive Session. To do so, the Board will recess Executive Session on any particular item and reconvene General Session to discuss that item or to take action on such item.

ITEMS MAY BE DISCUSSED IN A DIFFERENT SEQUENCE

Call to Order Roll Call Pledge of Allegiance

AGENDA – AMENDED Formal Meeting

Board of Directors of the

Maricopa County Special Health Care District

Board Members Mary A. Harden, R.N., Chair, District 1 Mark Dewane, Vice Chair, District 2 Susan Gerard, Director, District 3 Elbert Bicknell, Director, District 4 Terence McMahon, Director, District 5

Agendas are available within 24 hours of each meeting in the Office of the Board, Maricopa Medical Center, Administration Bldg, 2nd Floor 2601 E. Roosevelt, Phoenix, AZ 85008, Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m. Accommodations for Individuals with Disabilities, alternative format materials, sign language interpretation, and assistive listening devices are available upon 72 hours advance notice through the Office of the Board, Maricopa Medical Center, Administration Bldg, 2nd Floor 2601 E. Roosevelt, Phoenix, Arizona 85008, (602) 344- 5177. To the extent possible, additional reasonable accommodations will be made available within the time constraints of the request. 3/25/2014 8:27 AM

Call to the Public This is the time for the public to comment. The Board of Directors may not discuss items that are not specifically identified on the agenda. Therefore, pursuant to A.R.S. § 38-431.01(H), action taken as a result of public comment will be limited to directing staff to study the matter, responding to any criticism or scheduling a matter for further consideration and decision at a later date. General Session, Presentation, Discussion and Action: 1. Maricopa Integrated Health System Employees Department Spotlight 10 min Department Employees 2. Approval of Consent Agenda: 15 min

Note: Approval of contracts, minutes, IGA’s, proclamations, etc. Any matter on the Consent Agenda will be removed from the Consent Agenda and discussed as a regular agenda item upon the request of any Board member.

a. Minutes: Approve Special Health Care District Board of Directors Meeting Minutes dated:

i. February 21, 2014 Bond Advisory Committee ii. February 24, 2014 – Formal iii. February 26, 2014 – Formal

b. Contracts: i. Approve a new contract (90-14-146-1) with Bridgeway Health Solutions for facility and physician services ii. Approve Amendment #3 to the Grant (90-11-102-1-03) with Arizona Department of Health Services to extend the IGA Letter of Agreement (LOA) for one additional year iii. Approve Amendment #2 to the contract (90-12-152-1-02) with Ernst & Young, LLP for external auditing services including financial statement and program audit required under OMB Circular A-133

iv. Approve a new lease agreement (90-12-162-01) with Choices Network of Arizona in which MIHS leases approximately 540 sq. ft. of space at the Roeser Rd. location of the Choices Provider Network Organization

v. Approve a new cooperative contract (90-13-207-1) with IT Partners for Information Technology Equipment and Services

vi. Approve Amendment #7 to the Contract (90-12-084-1-07) for Professional

Services between the Maricopa County Special Health Care District and District Medical Group

vii Approve a new cooperative purchasing agreement (90-14-166-1) with Navigant Consulting, Inc. for review of deliverables and methodologies employed to arrive at recommendations of the Bond Advisory Committee c. Board Governance: i. Ratify Selection of Wilma Acosta as Maricopa Integrated Health System’s Chief Compliance Officer ii. Approve Dissolution of the Board of Directors’ Bond Advisory Committee iii. Approve Revisions to the Maricopa Integrated Health System Compliance

Program 2

General Session, Presentation, Discussion and Action (cont.): 2. Approval of Consent Agenda (cont.): c. Board Governance (cont.): iv. Approve Revisions to the Maricopa Integrated Health System Code of Conduct

and Ethics d. Medical Staff:

i. Approve MIHS Medical Staff Appointments, FPPEs, Reappointments, Change of Privileges/Status, and Resignations for March 2014

ii. Approve MIHS Allied Health Professional Staff Appointments, FPPEs,

Reappointments, and Resignations for March 2014 iii. Approve Proposed Revisions to the Radiology Privileging Criteria for Invasive

Radiology and Ultrasound Guided Percutaneous Tenotomy/Fasciotomy

iv. Approve Proposed Revision to Policy #39026T: Operational Credentialing Policy

_________________________End of Consent Agenda________________________ 3. Authorize Maricopa Integrated Health System President & Chief Executive Officer to Contact the

Maricopa County Election Department to Request a Placeholder on the November 2014 General Election Ballot 10 min

Steve Purves, MIHS, President & Chief Executive Officer 4. Discussion and Possible Action on Clinically Integrated Network Plan 10 min Robert E. Fromm, Jr., M.D., M.P.H., MIHS, Chief Medical Officer 5. Discussion on the Treasurer’s Advisory Board; its Membership and Charter 10 min Michael Ayres, MIHS, Chief Financial Officer 6. Discussion and Possible Action on Mercy Maricopa Integrated Care, Bylaw Amendments, Consent in Lieu (Amendment to Bylaws, Appointment of Directors, Appointment of Officers, and Designation of Member Representatives) 10 min Bill Vanaskie, MIHS, Chief Operating Officer 7. INTENTIONALLY LEFT BLANK 8. Discuss, Review and Possible Action on the February 2014 MIHS Key Indicator Dashboards

and Review the Monthly Chief Financial Officer Report 15 min Senior Administration 9. Approve Maricopa Care Advantage Plan Compliance Program 10 min Wilma Acosta, MIHS Chief Compliance Officer

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General Session, Presentation, Discussion and Action (cont.): 10. Reports to the Board of Directors; Discussion and Possible Action: 5 min a. Electronic Health Record – Post Implementation Review District Board 11. iProtean Online Course – Finance: Making Difficult Decisions About Services And Programs: A Portfolio Approach, Part One 30 min District Board 12. Concluding Items

a. Future Agenda Items b. Board Member Requests for Future Agenda Items or Reports c. Comments i. Chairman and Member Closing Comment ii. President & Chief Executive Officer Summary of Current Events

Adjourn

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Maricopa County



March 26, 2014

Item 1. – No Handout

Department Spotlight

Maricopa County



March 26, 2014

Item 2.a.i.

Minutes

Voting Members Present: Bill Post, Chairman Lattie Coor, Ph.D., Vice Chairman

Tony Astorga – arrived at 2:37 p.m. Paul Charlton

Kote Chundu, M.D. Frank Fairbanks

Nita Francis Merwin Grant Doug Hirano

Diane McCarthy Terence McMahon, Ex-officio, Director, District 5 Rick Naimark Brian Spicker – arrived at 2:39 p.m.

Ted Williams – arrived at 2:56 p.m. Absent: Joey Ridenour Others/Guest Presenters: Steve Purves, MIHS, President & CEO - telephonically Recorded by: Melanie Talbot, MIHS, Executive Director of Board Operations Cynthia Cornejo, MIHS, Assistant Clerk of the Board Call to Order Chairman Post called the meeting to order at 2:36 p.m. Roll Call Ms. Talbot called roll. Following roll call, it was noted that ten of the fourteen voting members of the Maricopa County Special Health Care District Bond Advisory Committee were present, which represents a quorum. Mr. Spicker and Mr. Williams arrived after roll call. Mr. Purves participated telephonically. For the benefit of those participating telephonically, Ms. Talbot identified the individuals present at the meeting. Call to the Public Chairman Post called for public comment. Ms. Mary A. Harden, R.N., Chairman of the Board of Directors of the Special Health Care District addressed the Committee. On behalf of the Board of Directors, she thanked the members for their time, effort and commitment.


Board of Directors Bond Advisory Committee Meeting Maricopa Medical Center

Auditoriums 3 and 4 February 12, 2014

2:30 p.m.

Special Health Care District Bond Advisory Committee Meeting Minutes – General Session – February 12, 2014 Call to the Public, cont. Mr. Bil Bruno, a citizen and taxpayer from Chandler, Arizona addressed the committee regarding the report to be recommended to the District Board of Directors. He stated that he could not find the cost of the recommendations and the impact to the taxpayers. He was anticipating a conversation from the Committee prior to a vote on the final report. He understood that the facilities needed to be replaced; however, he suggested separating behavioral health and the other facilities into separate initiatives. The returns on investment from the newer facilities could carryover and help fund other aspects of the recommendations. General Session Presentation, Discussion and Action: 1. Discuss, Review and Approve Final Bond Advisory Committee Report and Recommendations to

the Maricopa County Special Health Care District Board of Directors Chairman Post asked if there were any comments, changes or amendments to the report. Ms. McCarthy suggested creating some consistency when the term ‘medical providers’ was referenced; many may not be familiar with the term ‘providers’ when referring to the medical profession. She suggested all be changed to ‘medical professional’. There was also a typographical error on page 13; the first bullet point under Section 2. The word ‘undeserved’ should be ‘underserved’. She also suggested including a glossary; for those that are not familiar with the terms used throughout the document. Mr. McMahon referred to page 34, paragraph 2 under Recommendation, last sentence. He suggested including ‘cost effective’ after comprehensive; the sentence would read, “…and enhance MIHS’ ability to deliver exceptional outcomes through a comprehensive, cost effective and coordinated services continuum.” Mr. Naimark referred to page 41 and suggesting adding ‘Partnership’ to the title. The title would then read, “Recommendation #7: Create a Community Stakeholder Engagement and Partnership Plan”. This would emphasize the desire to reach out to the community as potential partners. Ms. McCarthy referenced page 35, Recommendation #1, second paragraph; and stated ‘politician’ should be changed to ‘elected official’. On page 36, the last sentence is out of place and should be included in Recommendation #2. She noted that the year should be included after the date. She also referred to page 37, first paragraph, second to last sentence; and proposed striking ‘mid-level’ from the sentence. She stated that medical professionals work as a team and should not be separated. Mr. Purves agreed with the recommendation. The term mid-level is commonly used in the medical industry when describing advanced nurses and other vital healthcare professionals. Chairman Post understood that the term was an industry standard, however, the document is for the public. Mr. Naimark stated that after further reviewing the section, he suggested revising the title on page 41 to “Recommendation #7: Create a Collaborative Community Stakeholder Engagement Plan and Partnerships”. The emphasis needs to be placed on collaborations and partnerships. He also referred to the comment from Mr. Bruno regarding the structure of the bond proposal and the impact to the community and stated that task would be the responsibility of the Maricopa County Special Health Care District Board of Directors (Board). In terms of the impact on the taxpayers, the Committee was tasked to evaluate the need and review the potential capital issues, which the Committee has done. The Board can evaluate the recommendation and determine the next course of action. It is important to question the structure and the impact on taxpayers.

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Special Health Care District Bond Advisory Committee Meeting Minutes – General Session – February 12, 2014 General Session Presentation, Discussion and Action (cont.): 1. Discuss, Review and Approve Final Bond Advisory Committee Report and Recommendations to

the Maricopa County Special Health Care District Board of Directors, cont. Chairman Post agreed and stated that the remarks were consistent with the report. The Committee has reviewed the existing functions of the System, extrapolated those for the future and combined that with the needs of the community. Ms. Francis also agreed that the Committee is not responsible for determining how the proposal will be structured; however, she stated that if the District does not go forward in a big way, it will go forward in a fractured way and the community would not benefit appropriately. Mr. Charlton emphasized that Recommendation #6 states that the proposal for a bond initiative was not to exceed $935 million. Another critical point, the recommendation also states that upon voter approval, the Board of Directors is to complete project-specific due diligence to value engineer the most cost-effective solution for each proposed investment. Mr. Fairbanks said that the final report was a well-written document. He requested a single page document be written to summarize the report. The document would outline the seven recommendations and a brief explanation of each. Mr. Grant concurred and added that the one page summary should be attached to the report itself. Mr. Astorga stated there should be emphasis placed on the improved patient outcomes that would be achieved through the implementation of the recommendations. Dr. Chundu said that it should be noted that the Committee is recommending up to $935 million in a bond initiative for a set of services and has outlined how the community will benefit. He stated it is important for the summary to include all the pertinent information. MOTION: Mr. Astorga moved to approve the final Bond Advisory Committee report and

recommendations with edits to the Maricopa County Special Health Care District Board of Directors. Ms. Francis seconded. Motion passed with a voice vote.

Mr. Post thanked the Committee members for their time. He also thanked the Board for the opportunity to serve on the Committee. He extended gratitude to senior administration, Mr. Purves, and Ms. Doria for her assistance in developing the report. He acknowledged Ms. Bayless for proposing the development of the Committee to the Board. He thanked the consultant team for their guidance and providing the technical components of the report. Mr. Purves, on behalf of the health system, thanked Mr. Post for his leadership and the time he committed. He also recognized the members of the Committee for the caliber of the work completed. The input is valuable to the Board. He also thanked senior administration. He expressed his appreciation on the tremendous team effort and noted that the work is just beginning. 2. Approve Bond Advisory Committee Meeting Minutes dated January 21, 2014 MOTION: Mr. Fairbanks moved to approve the Bond Advisory Committee minutes dated January

21, 2014. Ms. Francis seconded. Motion passed by voice vote.

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Special Health Care District Bond Advisory Committee Meeting Minutes – General Session – February 12, 2014 Adjourn MOTION: Ms. Francis moved to adjourn the February 12, 2014 Bond Advisory Committee meeting.

Dr. Chundu seconded. Motion passed by voice vote. Meeting adjourned at 3:10 p.m. ______________________________ Bill Post, Chair Bond Advisory Committee

4

Maricopa County



March 26, 2014

Item 2.a.ii.

Minutes

Present: Mary A. Harden, R.N. Chairman, District 1 Mark Dewane, Vice Chairman, District 2 – arrived at 1:02 p.m. Susan Gerard, Director District 3 – arrived at 1:04 p.m.

Elbert Bicknell, Director, District 4 Terence McMahon, Director, District 5

Others Present: Steve Purves, MIHS, President & Chief Executive Officer Bill Vanaskie, MIHS, Chief Operating Officer Michael Ayres, MIHS, Chief Financial Officer Louis B. Gorman, MIHS, District Counsel Recorded by: Melanie Talbot, MIHS, Executive Director of Board Operations Cynthia Cornejo, MIHS, Assistant Clerk of the Board Call to Order Chairman Harden called the meeting to order at 1:01 p.m. Roll Call Ms. Talbot called roll. Following roll call, it was noted that three of the five voting members of the Maricopa County Special Health Care District Board of Directors were present, which represents a quorum. Vice Chairman Dewane and Director Gerard arrived shortly after roll call. Call to the Public Chairman Harden called for public comment. There were no comments from the public. General Session, Presentation, Discussion and Action: 1. iProtean Online Course – Governance: Board Effectiveness iProtean is an online resource for hospital board trustee education, and provides online courses in four categories: governance, finance, quality, and mission/strategic. This course reviewed the tools needed for board effectiveness, the proper structure of board meetings, the benefits of board committees, and board education. It also highlighted the value of the board members time and their individual talents and skills. MOTION: Director Bicknell moved to recess general session and convene in executive session at

1:29 p.m. Vice Chairman Dewane seconded. Motion passed by voice vote.

Minutes

Maricopa County Special Health Care District Board of Directors Meeting Maricopa Medical Center

Navajo East and West Rooms February 24, 2014

1:00 p.m.

Special Health Care District Board of Directors Meeting Minutes – General Session – February 24, 2014 General Session Presentation, Discussion and Action: Chairman Harden reconvened the general session at 3:56 p.m. 2. Discuss Holding Board of Directors Informal Meetings Prior to Formal Meetings Chairman Harden said there is a need to review the timeline in which information is received from staff for review prior to Board meetings. The current timeline requires the monthly financial statements to be delivered in a separate mailing, as they are not completed by the time the original packet is delivered. Director McMahon asked if the new system that Board staff proposed would change the time needed to prepare the financial statements. Mr. Purves said that he believes the system will help, in respect to the quality of the reports received. The month end closing process will still require a minimum of 10 business days. Chairman Harden stated that there are cities that have work or study sessions prior to the formal city council meetings to discuss the items. She asked if the Board wanted to hold an additional meeting each month for this purpose. Vice Chairman Dewane questioned the need for this discussion. Chairman Harden stated that she has received feedback that the information is not being received in a timely manner. Vice Chairman Dewane asked Mr. Purves if the current timeline was problematic for staff. Mr. Purves said that preparation for the next board meeting begins as soon as the previous meeting concludes. There are a variety of matters that occur in the organization and he and senior administration are working to ensure that the Board receives the pertinent, strategic and high-level information that is needed to fulfill their fiduciary role. There are also times when the Board requests additional information, and those requests are interwoven with the routine reports that the Board receives. Vice Chairman Dewane said he is interesting in receiving the pertinent high-level information. He also stated that he receives the information with enough time to review. Mr. Purves said that the Board receives and reviews a great deal information on a monthly basis. The more trustful the Board is with the quality of information presented, the less information they will have to receive. He asked how much time would the Board need to review the information prior to the Board meetings. Director Gerard asked if the financial statements were the only item that is difficult to prepare within the established timeline or if all agenda items were difficult. Mr. Purves said that the financials require some time to prepare at the end of the month. Director Gerard stated that she is concerned that regardless of the timeline established, senior administration will find a reason not to meet the deadline. She stated that she reviews the information received the weekend prior to the Board meetings. Mr. Purves said that was a reasonable timeline. Director Gerard questioned the amount of information received in the financial statements. She stated that she reviews the dashboards and should she have any questions, she will review the complete financial information. Chairman Harden suggested that the Board review the information required to be in the Board packet.

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Special Health Care District Board of Directors Meeting Minutes – General Session – February 24, 2014 General Session Presentation, Discussion and Action(cont.): 2. Discuss Holding Board of Directors Informal Meetings Prior to Formal Meetings, cont. Director McMahon stated that he had requested a financial summary be included; which is now the Chief Financial Officer (CFO) report. Mr. Purves said that once the new systems are in place, the Board will receive traditional high-level reports. Vice Chairman Dewane said that having the appropriate staff attend the meeting to answer any possible questions from a Board member will reduce the amount of requests made. Mr. Purves said it is now a requirement for all Vice Presidents and Chief Officers to attend the Board meetings. Director McMahon stated the goal would be for the Board to focus on the strategic plan and results, not to get involved in the operations of the organization. Chairman Harden requested a list of the items included in the Board packets each month. The Board will then review the list and determine what is needed. After some discussion, the current timeline for the Board to receive the information for the Board meetings was modified. This modification will allow senior administration to provide accurate information to the Board in a timely manner. Director Gerard stated that there may be instances when unexpected, urgent items require Board attention. She requested that the Board receive a courtesy call from whoever is responsible for the item. Mr. Purves agreed. He will encourage senior administration to reach out to the Board with any concerns or issues. Adjourn MOTION: Vice Chairman Dewane moved to adjourn the February 24, 2014 Special Health Care

District Board of Directors Executive Session Meeting. Director McMahon seconded. Motion passed by voice vote.

Meeting adjourned at 4:11 p.m. ______________________________ Mary A. Harden, R.N., Chairman Special Health Care District Board of Directors

3

Maricopa County



March 26, 2014

Item 2.a.iii.

Minutes

Present: Mary A. Harden, R.N., Chairman, District 1 Mark Dewane, Vice Chairman, District 2 Susan Gerard, Director District 3 – arrived at 1:05 p.m.

Elbert Bicknell, Director, District 4 Terence McMahon, Director, District 5

Others Present: Steve Purves, MIHS, President & Chief Executive Officer Bill Vanaskie, MIHS, Chief Operating Officer – arrived at 1:55 p.m. Michael Ayres, MIHS, Chief Financial Officer Warren Whitney, MIHS, Chief External Affairs Officer

Louis B. Gorman, MIHS, District Counsel Sherry Stotler, MIHS, Chief Nursing Officer Michael Peck, M.D., MIHS, Chief of Staff – arrived at 1:02 p.m.

Marshall Jones, MIHS, Vice President of Human Resources Susan Doria, MIHS, Vice President of Strategic Planning Guest Presenters: Bill Post, Bond Advisory Committee Chairman

Mary Lee DeCoster, MIHS, Vice President of Revenue Cycle Cheri Tomlinson, MIHS, Vice President of Grants Michael Fronske, MIHS, Legislative and Governmental Affairs Director

Dan Hobohm, M.D., MIHS, Vice President of Quality and Patient Outcomes Brian Maness, MIHS, Director of Contracts/Procurement Paul Dereadt, MIHS, Director of Purchasing and Supply Chain Management Kelly Summers, MIHS, Chief Information Officer Laurie Wood, MIHS, Vice President of Ambulatory and Physician Services Wilma Acosta, MIHS, Interim Chief Compliance Officer

Recorded by: Melanie Talbot, MIHS, Executive Director of Board Operations

Cynthia Cornejo, MIHS, Assistant Clerk of the Board Call to Order Chairman Harden called the meeting to order at 1:00 p.m. Roll Call Ms. Talbot called roll. Following roll call, it was noted that four of the five voting members of the Maricopa County Special Health Care District Board of Directors were present, which represents a quorum. Director Gerard arrived shortly after roll call. Pledge of Allegiance The Pledge of Allegiance was led by staff from the Health Sciences – Library department.

Minutes

Maricopa County Special Health Care District Board of Directors Formal Meeting

Maricopa Medical Center Auditoriums 1 and 2

February 26, 2014 1:00 p.m.

Special Health Care District Board of Directors Meeting Minutes – General Session – February 26, 2014 Call to the Public Chairman Harden called for public comment. There were no comments from the public. General Session, Presentation, Discussion and Action: 1. Department Spotlight Chairman Harden asked the representatives from the featured department, Health Sciences - Library, to introduce themselves, describe what they do and how long they have been at Maricopa Integrated Health System (MIHS). o Rebecca Birr, Manager of the Library and Family Learning Centers, has worked for MIHS for nearly

14 years. o April Aguinaga, Medical Librarian, has worked for MIHS for seven years. o Deborah Richards, Library Assistant, has worked for MIHS for five years. o Shirley Velazquez, Family Learning Center Coordinator, has worked for MIHS for a year and a half. Chairman Harden thanked the staff for their time and dedication to MIHS. 2. Discussion and Possible Action on Recommendations from the Bond Advisory Committee Mr. Post thanked the Board for the opportunity to present the results of the work completed by the Bond Advisory Committee (Committee). The Committee members focused their efforts on the needs of the community from a new perspective. He explained that over the past year, the Committee met in open, public meetings on a monthly basis, shared all the information presented on its website, held five additional public forums and met with numerous community and industry leaders on an individual basis. The conclusion of that effort is contained in the report recommended by the Committee. The report contains seven recommendations for the organization; including the growth of Graduate Medical Education (GME), expansion of the outpatient health clinics, increasing behavioral health capacity, building a right-size modern hospital, conducting an economic impact study, developing a bond proposal and communication plan, and creating collaborative community partnerships. The final recommendation from the Committee is for the Board to pursue bonding authority, not to exceed $935 million. It is also recommended that the Board perform due diligence in respect to specific projects and value engineering to uncover further cost refinements that can be achieved. Chairman Harden thanked Mr. Post for his leadership on the Committee, as well as Dr. Coor and the other members of the Committee. Director Gerard shared her appreciation for the quality of work completed by the Committee; the results exceeded the expectations set. MOTION: Director Bicknell moved to formally acknowledge the receipt of and recognize the work of

the Bond Advisory Committee written report. Vice Chairman Dewane seconded. Director Gerard clarified that the Board was accepting the report. This is the beginning of the process. The Board will review, discuss and make decisions prior to submitting ballot language. VOTE: Motion passed by voice vote.

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Special Health Care District Board of Directors Meeting Minutes – General Session – February 26, 2014 General Session, Presentation, Discussion and Action, cont.: 3. Approval of Consent Agenda:

a. Minutes: Approve Special Health Care District Board of Directors Meeting Minutes dated:

i. January 29, 2014 – Formal ii. February 6, 2014 – Special

b. Contracts: i. Approve a new contract (90-14-145-1) to the Intergovernmental Agreement with Maricopa County by and through the Ryan White Part A Program to continue to receive grant funding to provide the following services to patients eligible under Ryan White Part A: Outpatient Primary Medical Care, Mental Health Services, Substance Abuse Services, Medical Case Management/Early Intervention Services, and Oral Health Services. ii. Approve Amendment #1 to the agreement (90-13-050-1-01) between United Audit Systems, Inc. (UASI) for outpatient medical coding services.

iii. Approve Amendment #6 to the Provider Services Agreement (90-12-084-1-06) between Maricopa County Special Health Cared District and District Medical Group to revise Exhibit B, Sections II, III, V, and VIII of the agreement

c. Board Governance: i. Approve Amended and Restated Sub-operating Agreement between Southwest Center for HIV/AIDS, Inc. and Maricopa County Special Health Care District d. Medical Staff:

i. Approve MIHS Medical Staff Appointments, FPPEs, Reappointments, Change of Privileges/Status, and Resignations for February 2014

ii. Approve MIHS Allied Health Professional Staff Appointments, FPPEs,

Reappointments, and Resignations for February 2014 MOTION: Vice Chairman Dewane moved to approve the consent agenda. Director McMahon

seconded. Motion passed by voice vote. 4. Presentation on the Affordable Care Act (ACA) Project Ms. DeCoster said that because of the Affordable Care Act (ACA), uninsured individuals now have two options available for health insurance. The first option is to apply and be qualified for the expansion of the Medicaid program; the other option is to purchase health insurance through the federal marketplace. There is a particular interest for Arizona to have a successful open enrollment, as it is the only state in Medicare Region 9 with a federal marketplace. She stated MIHS has partnered with various vendors to reach out to the community, including Integrated Health Management Service (IHMS) to assist with the eligibility screening, Integrated Web Strategy (IWS) to create the website CoverMeAz.org, and other vendors to assist with marketing and outreach.

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Special Health Care District Board of Directors Meeting Minutes – General Session – February 26, 2014 General Session, Presentation, Discussion and Action, cont.: 4. Presentation on the Affordable Care Act (ACA) Project, cont. Ms. DeCoster said that MIHS has also contracted with Meritus, a non-profit cooperative health plan, and with the University of Arizona health plan. Meritus has enrolled over 900 new members; compared to number of enrollees in the health plan for Pima, that is a quite an accomplishment. MIHS is proud to be a trendsetter and leader. She noted that Ms. Tomlinson was contacted by the Center for Medicare and Medicaid Services (CMS) and was asked to assist in the creation of a coalition focusing on open enrollment. As a result, Ms. Tomlinson is one of the founders of the Cover Arizona Coalition. She reviewed the governance structure, the in-reach and out-reach efforts, and the goals and objectives. A key objective was to not only capture the uninsured individuals and enroll them in an appropriate health plan, but to maintain the enrollment after the initial year. Ms. Tomlinson stated that there are several committees in place, all of which have a specific focus. The special populations committee focuses on five special populations and has successfully enrolled over 1,200 individuals in an appropriate health plan. The marketing and communication committee has done an outstanding job in getting the information out to the community; including the CoverMeAZ.org website; which was recognized by America’s Essential Hospitals for the innovative and created strategy in reaching out to the community and showing that this service is available. As a result, MIHS is expecting to achieve the goal of enrolling 10,000 individuals by early April 2014. Also, according to the information received from CMS and Arizona Health Care Cost Containment System (AHCCCS), Arizona is ranked 15 out of 36 states that have the federal facilitated market place in the number of enrollments. Arizona is also one of the two states focused on expanding Medicaid and the marketplace simultaneously. She stated the success is due to the support from the Board and senior administration and the community is benefiting. 5. Discussion and Possible Action on Kronos Implementation, Change Order Requests, and Project Expansion Mr. Jones said that the Enterprise Application Suite (EAS) will implement a solution that will integrate financial management, analytics, supply chain, and human resources and payroll. He reviewed the timeline and milestones and noted that there are change orders being proposed. He stated that there is a need to extend the timeline by sixty days due to some challenges causing a delay. Mr. Jones stated that the original budget was $2.4 million; however, the organization change management component for $143,000 was omitted. There are four additional change orders, which require additional resources to continue the implementation, a total of $601,800. He noted that there were funds placed in the contingency budget for the project; however, not enough for the additional expense, so the project will utilize part of the MIHS capital contingency fund. He reviewed the return on investment, which is projected to result in an annual savings of $2.7 to $4.8 million. Director Gerard questioned the challenges encountered that caused the delay. Mr. Jones said that the interface for both Kronos and MIHS was not scaled properly. Vice Chairman Dewane asked if future issues should be anticipated due to the complexity of the project. Mr. Jones said that it was not anticipated. Chairman Harden referred to the projected annual savings and asked when those savings would be realized. Mr. Jones said some savings will be realized in early fiscal year 2015. The real substantive savings will be realized further down the road.

4

Special Health Care District Board of Directors Meeting Minutes – General Session – February 26, 2014 General Session, Presentation, Discussion and Action, cont.: 5. Discussion and Possible Action on Kronos Implementation, Change Order Requests, and Project Expansion, cont. Director McMahon asked if there was a reporting mechanism in place to demonstrate the actual savings and compare with the projected savings. Mr. Ayres said that there is a system in place and the information is provided to the Board upon request or at the completion of a project. Chairman Harden asked if the Board was being asked to approve the additional funds to further implement the EAS project. Mr. Purves said that the totality of the change order is over the approval authority of senior administration. He stated that senior administration is seeking authority to extend the contract and approval for the change orders. Director McMahon said should the Board not approve the extension, would the funds already spent be squandered. Mr. Jones said that would be the case. Mr. Purves directed Mr. Jones and Mr. Gorman to clarify what is requested from the Board and present at the end of the meeting. 6. Discussion and Possible Action on Maricopa Integrated Health System’s 2014 Legislative Agenda

and/or the District’s Position Regarding Current or Proposed State and Federal Legislative Items Mr. Fronske reviewed the current statistics of the legislative session. He stated that with regard to the budget status, the major agency budgets, including the AHCCCS budget, had been heard in committee. There are also small working groups of legislators working on budget issues. He said that MIHS was in the process of exploring options to access additional Disproportionate Share Hospital (DSH) funding while working with AHCCCS to determine if there were funds not being utilized. He reviewed the bills that were being tracked by MIHS; SB 1035; the bill that would remove the mandated $5 million from Maricopa County for service delivery, has been amended since first presented. He noted that HB2234, which would have revoked the funding for the Medicaid expansion, appears to be dead. 7. Fiscal Year 2015 Budget Process Mr. Ayres stated that senior administration is recommending a significant change in the historical budgeting process; which would begin to forecast the projections for the next fifteen months now and create an annual budget. Due to the rate and magnitude of change in the healthcare industry, that becomes long range planning in the best of terms. Senior administration is planning on establishing a budget for the next fiscal year based on the strategic planning conducted with Navvis and amend the budget assumptions for areas that have a high order of magnitude and implications. Following this process, a detailed narrative of the operating plan will be provided and used as the budget for the year. Senior administration is proposing to budget every quarter, to monitor activities and adjust immediately to the changes in the environment, and amend the budget to address those changes. The Board will be presented with quarterly reviews, the variances from original assumptions and an explanation of actual performance over the period. He explained that the proposed process is very different from the process previously used; however, the final product will be the same. This process will provide senior administration better control of the operations. Director Gerard asked if the budget received in June 2014 will include detailed information.

5

Special Health Care District Board of Directors Meeting Minutes – General Session – February 26, 2014 General Session, Presentation, Discussion and Action, cont.: 7. Fiscal Year 2015 Budget Process, cont. Mr. Ayres said the budget for each quarter will be based off the actual performance from the previous quarter. 8. Discuss, Review and Possible Action on the Monthly Chief Financial Officer Report; Discuss and Review January 2014 MIHS Key Indicator Dashboards Dr. Hobohm reviewed the January quality dashboards. He stated that the System achieved the goal for falls with injury with zero harm. He noted there was one medication error with adverse event resulting in a higher level of care needed. The target for pressure ulcer was also missed in January along with the threshold for restraint episodes. He noted that the mortality rate was slightly over the threshold and the data is being analyzed to determine the reason for the increase. The readmission rate continues to run over the established target and there are extensive programs in place to correct and bring within target. He reviewed the process of care measures and noted the acute myocardial infarction (AMI) did not reach the goal of 95% due to missing one stemming within ninety minutes of arrival. The other targets met the thresholds. Chairman Harden questioned the underlying factors for readmissions. Ms. Stotler stated the matter was more psychosocial and there is a new transition clinic at the Comprehensive Health Center (CHC) to address the problem. Director Gerard stated that the number of restraint episodes exceeds the established target on a monthly basis. She asked if the goal was unrealistic. Ms. Stotler said that it is difficult to predict how the patients will react to treatment until they arrive. In lieu of traditional restraints; she noted the implementation of a bed enclosure for patients; however, the patient is confined to their bed and is considered a restraint episode. Director Gerard asked if the cases were reviewed to determine if they were handled correctly. Ms. Stotler said that there are several steps taken prior to restraints, including the utilization of cameras and sitters to monitor the patients. Dr. Hobohm said that it was important to note that there have been no injuries due to the restraints. There is also a new program in place and requires documentation for all restraint episodes and the internal audit program reviews that information. Director McMahon questioned the significance of the thresholds and the impact of the organization if they were not met. Dr. Hobohm said that hospitals that achieve 100% of all of the core measures would be ranked in the top 10% of hospitals nationwide. He said MIHS measures itself with hospitals statewide and nationwide and is better than average, locally and nationally, in most areas. Director McMahon asked if there were financial implications for not meeting the thresholds. Dr. Hobohm said that there are many reasons for tracking the data; however, there are financial reasons as well. Should the thresholds be achieved, there are additional funds; however, funds can be lost if not reached. Vice Chairman Dewane said the core measures are used to measure quality of care.

6

Special Health Care District Board of Directors Meeting Minutes – General Session – February 26, 2014 General Session, Presentation, Discussion and Action, cont.: 8. Discuss, Review and Possible Action on the Monthly Chief Financial Officer Report; Discuss and Review January 2014 MIHS Key Indicator Dashboards, cont. Mr. Vanaskie reviewed the January operational dashboard. Acute admissions continue to fall short of budget; however, the length of stay remained on budget and that resulted in the shortfall in patient days. The admissions in behavioral health remain strong as well as the length of stay. Ambulatory services volumes were better than budget in all areas with the exception of the dental clinics. The utilization in the operating room was on budget, and the number of deliveries was better than budget. The volume in the pediatric emergency room was less than anticipated. The length of stay for psych patients in the adult emergency department was 917 minutes. Chairman Harden questioned the psych length of stay in the emergency room. Mr. Vanaskie explained that the length of stay was for the adult patients in the emergency room (ER) waiting for a psych bed. He noted the time to treatment in the ER was 34 minutes. Mr. Purves stated that psych patients may be in the ER for an extended time; however, they are not receiving ER treatment; just waiting for placement. Mr. Ayres noted the covered lives information that is listed on the operational dashboard. He stated the Maricopa Health Plan (MHP) had the highest percentage of enrollees for the month in the valley and the Maricopa Care Advantage Plan is exceeding projections. He referred to the Chief Financial Officer (CFO) report and noted the challenges faced in January were the various changes effective at the beginning of the 2014 calendar year. He said there was a shift from self-pay into the Medicaid financial class; however, the rates for transition and reimbursement are unknown. Once the information is known, the information will be updated. He stated the MHP had an increase in volume and utilization due to the number of respiratory illnesses in January. He reviewed the cash liquidity and the days of cash on hand, which is being monitored closely. Break from 2:46 p.m. to 2:56 p.m. 9. Update on Savings Achieved from OMSolutions (O&M) Supply Chain Consulting Services; Approve Amendment #1 (90-13-007-1-01) to the Consulting Services Contract between Maricopa Integrated Health System and OMSolutions Mr. Dereadt said that in February 2013, MIHS engaged with Owens & Minor Solutions (O&M) to implement a value analysis program. There were two goals at the time; one was to create a program that would be sustainable and successful upon the termination of the agreement, the second goal was to interject quality and value into the System while allowing for the reduction of expenses, supply chain activities and purchased services. To accomplish the first goal, seven value analysis teams (VAT) were created with representatives throughout the organization. There was also a steering committee established with participation from executives. The teams worked to identify and produce savings through a comprehensive review over the past twelve months. As a result, by January 2014, the organization exceeded the original goal of $12 million in savings over three years. The implemented savings are a culmination of contract negotiations, leveraging volumes to certain vendors, and utilization. Mr. Maness stated that there have been some challenges and competing priorities. With the start of the program, the purchasing and contract staff assumed added responsibility for the VATs over their current responsibilities. Another challenge faced was the concurrent implementation of the EAS system; which placed an additional strain on existing resources. In addition, there was a significant turnover of key staff members, which resulted in additional training for replacement staff and a delay in the project.

7

Special Health Care District Board of Directors Meeting Minutes – General Session – February 26, 2014 General Session, Presentation, Discussion and Action, cont.: 9. Update on Savings Achieved from OMSolutions (O&M) Supply Chain Consulting Services; Approve Amendment #1 (90-13-007-1-01) to the Consulting Services Contract between Maricopa Integrated Health System and OMSolutions, cont. He said that there are more initiatives to be implemented over the next nine months which would result in added savings over the next three years. One option would be to utilize MIHS staff for the implementation, which would result in an additional $1 million in savings over the three-year period. However, should the O&M staff continue its engagement and focus on the implementation; the anticipated savings would be an additional $6 million over the same period. He recommended that the O&M contract be extended through the current fiscal year, with an option to extend on a month-to-month basis until the end of September 2014 to achieve the projected $6 million in savings. The combined savings would result in $18 million over a three-year period. Vice Chairman Dewane asked if the work performed by the consultants was outside the scope of ability for MIHS employees or if it was beyond the scope of the resources available. Mr. Maness stated that the activities performed were initially outside the scope of ability; however, the anticipated knowledge transfer has not been completed as quick due to the staffing challenges. At the conclusion of the contract, staff will be able to perform all activities previously performed by the consultants. Director McMahon asked if additional resources would be needed at the conclusion of the contract. Mr. Maness said that there may be some constrains on the MIHS staff; however, a solution will be needed for MIHS staff to absorb the responsibilities. MOTION: Vice Chairman Dewane moved to approve amendment #1 to the supply chain consulting

contract between MIHS and OMSoultions to extend the contract from February 1, 2014 through June 30, 2014 with the option to extend on a month-to-month basis from July 1, 2014 through September 30, 2014. Director Bicknell seconded. Motion passed by voice vote.

10. Status Update on ICD 10 Implementation Ms. DeCoster stated that the federal government has mandated that all healthcare providers in the United States transition the coding from ICD-9 to ICD-10, with the transition date of October 1, 2014. She noted that the current revision includes the largest increase in the codes to date. The primary use of ICD codes supports the classification of epidemiology, health management and for clinical purposes; with the United States being the only country to use ICD for reimbursement purposes, which will affect the payment stream for healthcare providers. The majority of the employees within the organization will be affected by the implementation. The keys to a successful implementation include training and testing. Mr. Summers said the implementation is interwoven throughout the health system. There are a number of ancillary systems integrated in EPIC and every application component or system component that is going to be affected by ICD-10, will be tested, modified and uploaded with codes. He noted that there has been significant progress. He pointed out that there was originally a computer assisted coding (CAC) tool budgeted for; however, there was some difficulty with the vendor and that item will not be implemented at this time. He anticipated the need to plan for that component in the next fiscal year. Ms. DeCoster stated the CAC tool is expensive and it will shorten the length of time for a coder to code the information by prompting the coder with coding suggestions. The tool will improve productivity, as it is anticipated that productivity will be negatively affected by the implementation of ICD-10. She stated that all participants of the Medicare programs will be transitioning to ICD-10, including payers; which may impact the cash flow. There is currently a testing schematic in place to prepare for this potential issue.

8

Special Health Care District Board of Directors Meeting Minutes – General Session – February 26, 2014 General Session, Presentation, Discussion and Action, cont.: 10. Status Update on ICD 10 Implementation, cont. Chairman Harden asked if the implementation was within budget. Ms. DeCoster said the project was measured every two weeks in respect to budget, scope and target date. The project is on target and on budget. Mr. Purves said over time, the productivity will improve and the specificity of the codes will allow the data to be analyzed and used to facilitate research. If MIHS does not comply with transition, claims to Medicare and Medicaid cannot be submitted. 11. Discussion, Consideration, and Possible Action on the Maricopa Integrated Health System’s

President & Chief Executive Officer’s Performance Goals for Fiscal Year 2014 MOTION: Director Bicknell moved to approve the Maricopa Integrated Health System’s President

and Chief Executive Officer’s performance goals for fiscal year 2014. Vice Chairman Dewane seconded.

Director McMahon asked if the change in the budget format will have an impact on the performance goals that were established. Mr. Purves said that there will still be an annual budget for the Board to approve and the performance goals will be built based off of that budget. Ms. Talbot clarified that the performance goals are for the current fiscal year. The proposed changes to the budget process will take place in the next fiscal year. Motion passed by voice vote. 12. Discuss, Review and Approve the Maricopa Integrated Health System President and Chief Executive Officer Job Description Referring to the items listed under Essential Functions, Director Gerard questioned if the importance of quality should be elaborated. She also asked if there should be a reference to the executive leadership succession plan incorporated in to the description. Mr. Purves stated that the importance of quality is referenced; however, if it pleased the Board, those statements could be strengthened to ensure the focus on quality is highly visible. In terms of leadership development and succession planning, that is what a leader does. Should the Board request that level of detail in the job description, the language can be added. Director Gerard said that was not necessary. MOTION: Director McMahon moved to approve the Maricopa Integrated Health System President

and Chief Executive Officer job description. Director Gerard seconded. Motion passed by voice vote.

9

Special Health Care District Board of Directors Meeting Minutes – General Session – February 26, 2014 General Session, Presentation, Discussion and Action, cont.: 13. Discuss Maricopa County Special Health Care District Procurement Code; Maricopa Integrated Health System Authorization and Responsibility Matrix; and Board Policy Statement 99104, Intergovernmental Agreements: Execution, Amendment and Termination Director Gerard said that after reviewing the legal opinion received, which states that all approvals, amendments, and terminations to an Intergovernmental Agreements (IGA) require Board action; her previous questions have been answered. She requested that the Maricopa County Special Health Care District (MCSHCD) Procurement Code and MIHS Authorization and Responsibility Matrix be reviewed periodically. Chairman Harden stated that the two documents are currently reviewed on an annual basis, or on an as needed basis. Mr. Purves said that there are systems currently being implemented to ensure that all items on the Authority and Responsibility Matrix are being properly monitored. Director McMahon asked what types of systems were being implemented. Mr. Purves stated that new software systems. 14. Discuss, Review and Approve and/or Rescind the Following Board Policy Statements:

a. Financial Assistance – Rescind policy b. Financial Assistance Discount Policy for Uninsured/Underinsured – New policy

Mr. Ayres stated the current Board policy statement directs the organization to evaluate a patient for their ability to pay accounts and creates a system to recognize the write-off. The system wide policy outlined the specific processes, procedures and guidelines for awarding different levels of discounts. In the current form, the existing policies do not meet the requirements established by the Health Resources and Services Administration (HRSA), which governs the operation of the Federally Qualified Health Center (FQHC) look-alike clinics. The three significant areas addressed include; the System cannot require payment prior to seeing a patient in a clinic; there can be no discounts for patients with income above 200% of the federal poverty level (FPL), and the policy must be approved by the Board of Directors and reviewed on an annual basis. He noted that there was one item in contention; the discount sliding fee scale. In particular, the fee schedule in category 3 of dental services. The intent of the guidelines is to avoid charging patients less than HRSA patients would be discounted. He believes the policy meets the intent of the guidelines. Director Gerard asked if the policy was consistent with what has been or will be approved by the Maricopa Health Centers Governing Council (Council). Mr. Ayres said that the policy has been presented to the Council and will be discussed at the next scheduled meeting. The Council may recommend amendments; if so, the policy will be presented to the Board for approval. There is a sense of urgency in that HRSA can survey the organization and there would not be a policy approved by the Board. Director McMahon stated that the term ‘unable to pay’ was not defined in the policy. He asked what that definition would be. Mr. Ayres said that when a patient completes the financial assessment, it would be determined if they are unable to pay. Director McMahon asked how each financial counselor makes the determination.

10

Special Health Care District Board of Directors Meeting Minutes – General Session – February 26, 2014 General Session, Presentation, Discussion and Action, cont.: 14. Discuss, Review and Approve and/or Rescind the Following Board Policy Statements, cont. Ms. DeCoster stated that the organization has a standardized procedure and uses the FPL guidelines. All patients are asked the same questions to determine the category which they would qualify. The policy dictates that the guidelines need to be reviewed and updated every year what the current FPL. For the patients under 200% of the FPL, that is classified as unable to pay. For those patients over 200% of the FPL, they should be able to pay. Director McMahon questioned why it was not defined in the policy. Mr. Ayres said that the phrase can be removed from the policy. The policy is a guideline for the organization to manage the program and to provide guidance to a number of financial counselors to equitably apply the process and meeting HRSA guidelines. Ms. Wood stated that the two primary changes that the policy includes are; requiring a co-payment at the time of the visit and requiring patients to complete the Medicaid eligibility process. The second element is a profound change; the patients can be provided the opportunity to complete the eligibility process. She stated that the Council’s Policy, Services and Compliance Committee will be reviewing the policy at the next scheduled meeting. The only concern is the item previously discussed by Mr. Ayres. Director Gerard asked if ‘unable to pay’ was federal language and a HRSA requirement, therefore, could not be removed from the policy. Ms. Wood stated that to the best of her understanding, that particular phrase is not required by HRSA. Mr. Purves said that his primary concern is having a policy approved by the Board. Should it not meet the specificities of HRSA, the policy can be reviewed and amended. Ms. Wood stated that HRSA has 19 core requirements; one of which states that no discounts may be provided those patients with incomes over 200% FPL. It would appear the sliding fee scale in the policy would provide a discount in dental services for that particular category. Should the organization be surveyed, that would be questioned. Vice Chairman Dewane asked how that could be corrected. Mr. Ayres said the standard applied for those in category 3 is the same standard applied for all patients. The System is not applying a different standard for the discount for non-HRSA patients. Ms. Wood stated that the Council does not agree with the item. Mr. Gorman said that per the Cooperative Agreement between the Board and the Council, the Council is to follow the Board policies. The proposed policy is a Board policy and does follow the law and HRSA guidelines, as written. Mr. Purves said that the Board and the Council need to be comfortable with the language in the policy. Mr. Vanaskie reiterated that the Cooperative Agreement states that the Council will abide by the policies approved by the Board. The policy has not been reviewed by the interim Chief Compliance Officer to confirm that it complies with Center for Medicare and Medicaid Services (CMS). Chairman Harden stated her concerns with the policy as it has not been reviewed by the Chief Compliance Officer. Director Gerard agreed.

11

Special Health Care District Board of Directors Meeting Minutes – General Session – February 26, 2014 General Session, Presentation, Discussion and Action, cont.: 14. Discuss, Review and Approve and/or Rescind the Following Board Policy Statements, cont. Ms. Acosta stated that there would be no reason that the policy could not be approved pending further evaluation. She said it would be more damaging for the System if there were not a policy approved by the Board at the time of a HRSA survey. Hopefully in the future, there can be an organized and methodical process in place to address items such as this. Ms. Wood asked that the Board work collaboratively with the Council. MOTION: Vice Chairman Dewane moved to rescind the Financial Assistance board policy

statement and approve Financial Assistance Discount Policy for Uninsured/Underinsured board policy statement with the intent that the document come back after review by the Maricopa Health Center Governing Council so we are consistent with the language. Director Gerard seconded. Motion passed by voice vote.

15. Reports to the Board of Directors; Discussion and Possible Action:

a. Patient Satisfaction Survey Results Report b. Whole Systems Measure Dashboard (Quality Report) c. Compliance Officer’s Activities d. Internal Auditor’s Activities e. Revenue Integrity Report

f. Maricopa Health Foundation Report g. Semi-Annual Maricopa Health Centers Governing Council Report h. Semi-Annual Special Health Care District Risk Management Report

i. Maricopa Integrated Health System’s Monthly Employee Turnover Reports j. Unbudgeted New Positions/FTEs There were no questions or discussion. 16. iProtean Online Course – Finance: Making Difficult Decisions About Services And Programs: A Portfolio Approach, Part One This item was not watched or discussed. 5. Discussion and Possible Action on Kronos Implementation, Change Order Requests, and Project Expansion MOTION: Vice Chairman Dewane moved to extend the contract timeline and add an additional cost

in the amount of not to exceed $602,000. Director Bicknell seconded. Motion passed by voice vote.

17. Concluding Items

a. Future Agenda Items b. Board Member Requests for Future Agenda Items or Reports c. Comments i. Chairman and Member Closing Comment ii. President & Chief Executive Officer Summary of Current Events

12

Special Health Care District Board of Directors Meeting Minutes – General Session – February 26, 2014 General Session, Presentation, Discussion and Action, cont.: 17. Concluding Items, cont. Director McMahon requested an update on the Treasurer’s Advisory Board, specifically, the charter and membership. Director Gerard requested a review of the Claims Committee charter in April 2014. Mr. Purves reviewed the news coverage over the past month. Of those was the news conference surrounding the unfortunate incident of a child being mauled by a family dog. The child is being treated at Maricopa Medical Center and the dog is receiving an influx of support from pet-lovers from across the country. There was also a feature story on the evening news surrounding the care that is being provided to a prospective pitcher for the Chicago Cubs. The patient was airlifted from a hospital in the Dominican Republic to the Arizona Burn Center for treatment. He is progressing well. NOTE: Director Gerard excused herself at 4:14 p.m. Adjourn MOTION: Director McMahon moved to adjourn the February 26, 2014 Special Health Care District

Board of Directors Formal Meeting. Chairman Harden seconded. Motion passed by voice vote.

Meeting adjourned at 4:20 p.m. ______________________________ Mary A. Harden, R.N., Chairman Special Health Care District Board of Directors

13

Maricopa County



March 26, 2014

Item 2.b.

Contracts

Maricopa County Special Health Care District Summary of Contract Approval Requests

Date: March 26 2014

1 | P a g e

Contract With New or Amendment Contract Provides ROI or Benefit Financial Impact

1. Bridgeway Health

Solutions (90-14-146-1)

New

MIHS will provide facility and professional medical

services to Bridgeway Covered Persons

Provision of these medical services will generate revenue for MIHS

Annual revenue from this contract is

estimated at $625,000.

2. Arizona Department

of Health Services (90-11-102-1-03)

Amendment Provision of free

Gonoccocal & Chlamydia testing for MIHS patients

Extension of this agreement will ensure MIHS patients continue to receive important

medical services related to detection and treatment of these infectious conditions.

No financial impact

3. ITP Consulting (90-13-207-1) New Correction to contracting

entity

Board originally approved agreement with IT Partners. This corrects approval to recognize

the appropriate vendor, ITP Consulting No financial impact

4. Choices Network of

Arizona (90-12-162-1-01)

New Lease of 540 sq. ft. of space in the Choices Network of

Arizona offices.

Allows for MIHS to provide health care services to Choices Network patients. $21,000 annually

5. Ernst & Young, LLP (90-12-152-1-02) Amendment External Auditing Services Compliance with governmental and

contractual obligations Estimated at

$280,000 annually.

6. District Medical Group (90-12-084-1-07) Amendment

Eliminate Medical Director of Informatics position; add

Managed Care Medical Director

Adds position of Medical Director of Managed Care to promote comprehensive,

cost effective patient focused care. Eliminates the position of Medical Director of

Informatics from the contract.

Expense reduction of $202,568.00

7. Navigant Consulting New

Review and validation of deliverables and

methodologies employed in Bond Advisory

Committee recommendations

Independent review and confirmation of the soundness of the approach used by the

consultant to the Bond Advisory to arrive at the recommendations

$70,000

Maricopa County



March 26, 2014

Item 2.b.i.

Contracts

Maricopa County



March 26, 2014

Item 2.b.ii.

Contracts

From: Compliance 360To: Brian ManessSubject: Contract Approval Request: Gonoccocal & Chlamydia Testing Maricopa County Department of Public HealthDate: Friday, March 07, 2014 2:00:57 PM

Message InformationFrom Purves, Stephen

To Maness, Brian;

Subject Contract Approval Request: Gonoccocal & ChlamydiaTesting Maricopa County Department of Public Health

Additional Information

Indicate whether you approve or reject by clicking theApprove or Reject button.

Add comments as necessary.

Approve/Reject ContractClick here to approve or reject the Contract.

Contract Information

Status Pending ApprovalTitle Gonoccocal & Chlamydia Testing

Contract Identifier(Travel Type

Dropdown)Board - Amendment

MIHS ContractNumber 90-11-102-1-03

Primary ResponsibleParty Melton, Christopher C.

DepartmentsProduct/Service

Description Free Gonoccocal & Chlamydia Testing.

Action/Background

Approve Amendment #3 to the Grant with ArizonaDepartment of Health Services (“ADHS”) to extend theIGA Letter of Agreement (LOA) for one additional year.

Arizona Department of Public Health provides freeGonoccocal & Chlamydia Testing for MIHS patients. Thisamendment#3 will extend the Letter of Agreement termfor one additional year from January 7, 2014 to January6, 2015 for an aggregate term of January 7, 2011 toJanuary 6, 2015.

This is a non-financial amendment regarding an IGALetter of Agreement.

Evaluation Process

The requesting department has determined that theContractor is performing satisfactorily and is meetingthe goals and objectives of the organization. Therequesting department has elected that the contractshould be continued and extended.

Notes This is a non-financial amendment regarding an IGALetter of Agreement.

Category IGA

mailto:[email protected]




https://secure3.compliance360.com/DMZ/DmzCustomViewLoader.aspx?CD=mAOsRMNUVTZe7Pt0MR4zRwfUMFWXQEHf%252bu0jxqWo0Th2QtKIUzjvcQ%253d%253d&PD=gewc47sikRiVwm37td5kSVukoo27wnj0J9MrNTBE7GZgPDPYnV2fnsouqZEZ%2b99EEnSUgelnB%2fHSi80YDj9tELk4R5IiTXZNzdXwqghsW3YPJFjwXeBJ9dLnwOfoe4oJbAD1fDGWFABINjINeETIEKerfDsq3%2bgBTiinE67vxznLIkC2I%2fX%2fxaRiW9qElASp9M%2bMOsFxWYgpyqxG7FaWsbvSjptvKSQq2jtAWRmk4F1kipr8ztwPreeNFDvYD6%2feGF3udCvqSsLm0D6ZyU2actrxyFCSAuaEnT1M%2bfPXwZ6zHqNu8Id3zQ%3d%3d

Effective Date 1/7/2014Expiration Date 1/6/2015

Annual Value $0.00Expense/Revenue

Budgeted (Budget BalDropdown Travel) N/A

Procurement NumberPrimary Vendor Maricopa County Department of Public Health

Responses

Member Name Status CommentsManess, Brian D. Approved Ok to route for approvals.

Stotler, Sherry A. Approved

Gorman, Louis B. Approved

Vanaskie, William F. Approved

Ayres, Michael D. Approved

Purves, Stephen A. Approved

Maness, Brian D. Current

Maricopa County



March 26, 2014

Item 2.b.iii.

Contracts

From: Compliance 360To: Brian ManessSubject: Contract Approval Request: Financial Statement & A-133 Audits Ernst & Young, LLPDate: Friday, March 14, 2014 1:08:57 PM


To Maness, Brian;

Subject Contract Approval Request: Financial Statement & A-133 Audits Ernst & Young, LLP






Status Pending ApprovalTitle Financial Statement & A-133 Audits




Primary ResponsibleParty Miyazaki, Annie S.


Description Financial Statement & A-133 Audits

Action/Background

Approve Amendment #2 with Ernst & Young, LLP(Contractor) for external auditing services includingfinancial statement and program audit required underOMB Circular A-133.

MIHS is required to undergo an annual financial audit inorder to comply with various governmental andcontractual obligations.

Amendment #2 extends the contract for 1 additionalyear from 6/1/2014 to 5/31/2015. The aggregate termof this Agreement from inception will be from 6/1/2012to 5/31/2015.

Evaluation Process

The Finance department has determined that theContractor is performing satisfactorily and is meetingthe goals and objectives of MIHS. Finance recommendsthat the contract should be continued and extended.

MIHS budgeted $280K per year for the auditing services.Total annual spent in 2013 was approximately $280K.Actual cost will be determined by auditing requirements.





https://secure3.compliance360.com/DMZ/DmzCustomViewLoader.aspx?CD=mAOsRMNUVTbH%252f%252fJLBEFIRt425leCnLZAOWYPHS9K2XUQ%252blgYVFitew%253d%253d&PD=gewc47sikRiZbT4bKWdkLtyz7J8EyWQekhgGxc5CgPd4OOWxOiFgvey5K9%2bBZHtc%2f%2fj6DAtC%2brISY%2bE5AJDzUzKx9kezBnOHScKV1Gn7CTuiYEkLDSppraMXlOxNxk%2bov44NmB%2fN2sqF6etrAQjrTO8%2bLQFUFYWDKyuh9xhZq85HiXKIq%2bkZm3Adoot98jmUz4sqMohJs4wKZaL185cenYG5syKW2eHlrIzI1cP2slaKWlV19Miaw7VBcSdisa95BBR0dMpC%2b94fKv2EfdrgeM92zlgh8o%2fqg9wBqvKU9E62sihYJnsRwQ%3d%3d

NotesCategory 0

Effective Date 6/1/2014Expiration Date 5/31/2015

Annual Value $280,000.00Expense/Revenue Expense

Budgeted (Budget BalDropdown Travel) Yes

Procurement NumberPrimary Vendor Ernst & Young, LLP

Responses


Benaquista, Kathleen F. Approved





Maricopa County



March 26, 2014

Item 2.b.iv.

Contracts

From: Compliance 360To: Brian ManessSubject: Contract Approval Request: Lease & Collaborative Co-Location Agreement Choices Network of ArizonaDate: Thursday, March 13, 2014 2:51:36 PM


To Maness, Brian;

Subject Contract Approval Request: Lease & Collaborative Co-Location Agreement Choices Network of Arizona






Status Pending ApprovalTitle Lease & Collaborative Co-Location Agreement


Dropdown)Board - New Contract

MIHS ContractNumber 90-12-162-01

Primary ResponsibleParty Ferrin, Peggy A.

Departments Hospital AdministrationProduct/Service

DescriptionLease of approximately 540 sq. ft of space at 1616 E.Roeser Rd., Phoenix, AZ 85040

Action/BackgroundEvaluation Process

Notes

This is a Lease agreement with Choices Network ofArizona in which MIHS leases approximately 540 sq. ft.of space at the Roeser Rd. location of the ChoicesProvider Network Organization.

The Co-Location Agreement between MIHS and Choicesprovides for MIHS employees to be on-site at the RoeserRd site which is the location of the PNO's Direct CareClinics. MIHS employees will provide behavioral healthservices to enrolled persons with serious mental illness.

Category 0Effective Date 3/1/2014

Expiration Date 12/31/2017Annual Value $21,000.00

Expense/Revenue ExpenseBudgeted (Budget Bal

Dropdown Travel) Yes

Procurement Number





https://secure3.compliance360.com/DMZ/DmzCustomViewLoader.aspx?CD=mAOsRMNUVTaUeWPL4dLGxG8AfzHV1oO8csgNwfKBR2B2Sasj47I%252fXg%253d%253d&PD=gewc47sikRjEATr3v0sjdUw6aC3q1%2fjisfUB676fFTQratpI48I37nyZIGnYcA24mn43hlzUVaroRcpTSFffje3n8CcK1OWiNs8guXnuxx39YjbDgw1bN3WNOqLhmETlMgR5US1N0yR6LO8ij9KmfqTV%2fELhcotH%2b07VroRU0FNghH6us8a%2f2sxZX6SSjwuI2k9MEUrzGoUTe3Ktd79FwM92p8V9CgTCy6SlWrYpcFimySg1R60NM%2fUDGAzGLCKDnLGOCCVmZrUVFH0z5muxVxRKN%2fzmfPbdLy9RZO7Zb8PzP%2fq6FTBe%2bg%3d%3d

Primary Vendor Choices Network of ArizonaResponses



Vanaskie, William F. Approved




Maricopa County



March 26, 2014

Item 2.b.v.

Contracts

From: Compliance 360To: Brian ManessSubject: Contract Approval Request: HP Mini Computers, Servers & Related Products/Services ITP Consulting d.b.a. IT

PartnersDate: Thursday, March 13, 2014 3:27:49 PM


To Maness, Brian;

SubjectContract Approval Request: HP Mini Computers, Servers& Related Products/Services ITP Consulting d.b.a. ITPartners






Status Pending Approval

Title HP Mini Computers, Servers & RelatedProducts/Services




Primary ResponsibleParty Miyazaki, Annie S.


DescriptionHP Mini Computers, Servers & RelatedProducts/Services

Action/Background

The Cooperative contract with IT Partners, approved bythe Board on May 22, 2013, referenced the incorrectvendor, IT Partners, Inc. and General ServicesAdministration (“GSA”) contract # GS-35F-0585X. Thisrequest is to obtain Board approval to change thevendor name to ITP Consulting, Inc. and recognize thecorrect Cooperative contract, City of Tempe contract #IT10-132-01, that MIHS will be accessing forinformation technology equipment and services.

The term of this Cooperative contract will be consistentwith the City of Tempe contract which will be May 20,2010 through May 19, 2015.

Evaluation ProcessNotes

Category Co-opEffective Date 5/20/2010

Expiration Date 5/19/2015





https://secure3.compliance360.com/DMZ/DmzCustomViewLoader.aspx?CD=mAOsRMNUVTaUeWPL4dLGxLwdx0V0z9%252fomOIBcY%252bjF1wEDHTkPzMPXA%253d%253d&PD=gewc47sikRiQO3f71NAPLhGm7VAqUnNdWvWTkpmzYnujT6be1bz0dgRgN7ccKOyRstv2iYLQfszhT84u5SJ%2bZExrFRHPo9%2fAu0eDvNHF7Q1%2b24Gwm5Rizax8bJinYWQw0q9sD%2bwTvKrH6WRqzHsWX7oyvPqiZ7jHsoXE4VtYf8l2%2bAuf06xbSNO%2bI8PjB6rgRh2Nx1JG1DHGBnehJ7QVD%2fTFOQKa19IWKbaxqQUrpGbexUhx9W142WiVP4f3JdRCYinvWHo%2bmO9z3H3kr1qanPLFDyJOE81YOY9MOEq6iewy6ogqdAGSqw%3d%3d

Annual Value $0.00Expense/Revenue Expense

Budgeted (Budget BalDropdown Travel) Yes

Procurement NumberPrimary Vendor ITP Consulting d.b.a. IT Partners

Responses


Summers, Kelly R. Approved





Maricopa County



March 26, 2014

Item 2.b.vi.

Contracts

From: Compliance 360To: Brian ManessSubject: Contract has been Approved: Amendment #7Date: Friday, March 14, 2014 1:07:38 PM


To Maness, Brian; Subject Contract has been Approved: Amendment #7


Status Pending ApprovalTitle Amendment #7




Primary ResponsibleParty Maness, Brian D.

Departments Hospital AdministrationProduct/Service

Description Amendment #7

Action/BackgroundApprove Amendment #7 to Special Health Care District –District Medical Group Contract for ProfessionalServices.

Evaluation Process

Notes

Amendment #7 will remove the position of MedicalDirector of Informatics (.8 FTE); Add a Managed CareMedical Director (.2 FTE) and add supportingdocumentation to the contract related to thesepositions. Net impact is a reduction of .6 FTE.

CategoryEffective Date 4/1/2014

Expiration Date 6/30/2017Annual Value ($202,568.00)



Procurement NumberPrimary Vendor District Medical Group (DMG)

Comments

Type Classification Date Employee Comments Approval 3/14/2014 Gorman, Louis B.

Approval 3/14/2014 Vanaskie, WilliamF.

Approval 3/14/2014 Fromm, Robert E.

Approval 3/14/2014 Ayres, Michael D.

Approval 3/14/2014 Purves, Stephen A.





Maricopa County



March 26, 2014

Item 2.b.vii.

Contracts

From: Compliance 360To: Brian ManessSubject: Contract has been Approved: Health Care Consulting ServicesDate: Wednesday, March 19, 2014 3:36:22 PM


To Maness, Brian;

Subject Contract has been Approved: Health Care ConsultingServices


Status Pending ApprovalTitle Health Care Consulting Services




Primary ResponsibleParty Maness, Brian D.

Departments Hospital Administration

Product/ServiceDescription

Healthcare consulting contract for review of BondAdvisory Committee deliverables and consultantmethodologies employed to arrive at recommendations.

Action/Background

Approve a Cooperative Purchasing agreement withNavigant Consulting, Inc. Navigant is being accessed viathe contract between Navigant Consulting and the Stateof Arizona. The initial term of the contract is October 31,2013 through November 1, 2014. The State may extendthis contract for additional periods.

Evaluation ProcessNotes

Category Co-opEffective Date 10/31/2013

Expiration Date 11/1/2014Annual Value $70,000.00



Procurement NumberPrimary Vendor Navigant Consulting Inc

Comments

Type Classification Date Employee Comments Approval 3/19/2014 Purves, Stephen A.





Maricopa County



March 26, 2014

Item 2.c.i.

Governance

WILMA ACOSTA, RN, BS, CHC, CPQH

PROFESSIONAL SUMMARY

Senior heathcare executive with over 25 years experienced in corporate governance, regulatory compliance with special expertise developing or restructuring compliance programs, including board and audit committees, and fraud and investigations.

- Leads compliance by building collaborative, trust based relationships and credibility with diverse groups, including executives, board members, regulatory agencies and line staff.

- Deep knowledge and understanding of fraud, abuse and anti-kickback law/regulation/rules – adept at integrating those regulations in to real time operations for long term sustainability/effectiveness

PROFESSIONAL EXPERIENCE

Protiviti, Inc. – Division of Robert Half International 1/2013 to present Associate Director, Tampa, Florida Health & Life Sciences – Government and Regulatory Provider Selected Achievements – Engagements

Medical Integrated Health System – assisted with restructure of compliance program and audit processes and developed audit plan, managed Meaningful Use CMS audit of Stage 1 – Part 1 attestation, managed all aspects of compliance program and HIPAA/Privacy and Security activities. Chair Compliance Committees, member of Audit and Compliance, Finance and Board Committees.

Developed compliance support services for American Indian Health Services entity – first internal audit /risk firm to develop this level of service and relationship with a sovereign Tribal Nation

Participate as Subjected Matter Expert in areas such as; compliance for senior management/leadership and board and committee development, monitoring business and clinical practices for acute and post-acute systems, inpatient rehabilitation, psyche services- inpatient/outpatient mental health, clinical systems implementations that impact coding and billing, physician-hospital contractual relationships, fraud and abuse investigations as related to CMS claims submission and patient rights as related to Conditions of Participation.

Served as primary Subject Matter Expert for Internal Audit projects nationally for compliance matters related to Hospital and Post-Acute entities.

Deloitte & Touché LLP Manager, Tampa, Florida 9/ 2011 to 1/2013 Health & Life Sciences – Government and Regulatory Provider Selected Achievements – Engagements

Mitigated major Hospice/Home Health potential disclosure and repayment at a Northeastern University Medical Center – assisted with restructure of hospice program and audit processes and developed education and training materials for new employees and annual updates

Participate as Subjected Matter Expert in areas such as; senior management/leadership and board and committee development, monitoring business and clinical practices for acute and post-acute systems, inpatient rehabilitation, psyche services- inpatient/outpatient mental health, clinical systems implementations that impact coding and billing, physician-hospital contractual relationships, fraud and abuse investigations as related to CMS claims submission and patient rights as related to Conditions of Participation.

Served as primary Subject Matter Expert for Internal Audit projects nationally for compliance matters related to Hospital and Post-Acute entities.

Sutter Health System, Sacramento, CA 6/2009 to 4/ 2011 Compliance Officer - Selected Achievements:

Operationalized a new compliance program at the facility level at 3 hospitals, a Nursing Home, Inpatient Psyche Facility and outpatient psyche hospitalization programs and Ambulatory Surgery Services. Compliance program management also included a full Research program that included animal and human studies. Manage

WILMA ACOSTA RN, BS, CHC, CPUM, CHA PAGE 2 OF 5

search compliance aspects of a Research program; included IRB, Conflicts of Interest, managing regulatory issues with FDA, NIH, CDC and CMS.

Mitigated Stark issues for physician arrangements of 600 plus physician related agreements valued at over $500 million.

Redesigned/implemented a contract management process, standardizing the processes, including the use of the software product Track Manager. Developed position for a dedicated contract specialist to administer the procedures and processes to ensure proper and timely information in Track Manager. Outcome: Decreased administrative time by .8 FTE and mitigated contract STARK issues and financial impacts.

Internal Audit identified $121K (CMS repayment) in error billing in Interventional Radiology: Drove change in System/Software interfaces, correcting CDM charging, appropriate documentation and coding. Outcome: denials decreased by 30%, increased improvement in net reimbursement, mitigating future CMS repayments.

Hospital programs included transplants (bone marrow, heart, lungs, pancreas and kidneys) largest NICU in county over 65 beds. Maternal – Pediatric Programs, Pediatric Hematology/Oncology Cancer Center & Clinical Research - Adult Cancer, Spine and Cardiovascular programs, Rural Health Clinics, Sleep Centers, Outpatient Surgical Centers

WPA Independent Consulting, Tampa, FL 3/2008 – 09/2011 Principle Launched personal consulting firm providing interim full time roles, and consulting services to diverse set of healthcare organizations, each with unique challenges to resolve as related to compliance. Children’s Hospital and Research Center, Oakland, CA – Interim Chief Compliance Officer – 4 months

Selected Achievements: Restructured compliance program, policy; including reorganizing the compliance committee charge and

mission; developed a Risk Assessment tool for hospital and research center; updated compliance communication posters, educational materials, and education to physicians and executive team regarding STARK & Antikick as related to physician arrangements.

Worked with Research Arm of Children’s Hospital on matters related to IRB, Human Study Subjects, Grants and Sponsorships and ensuring compliance with CMS, FDA, NIH and other applicable regulatory agencies.

Legal Firms – Subject Matter and Expert Witness Services 2008 to present Foley & Lardner LLP, Broad and Cassel, Attorneys at Law,

Selected Engagements: Hospice Investigations, Fraud and Abuse Billing Assessments, Physician Arrangements, CMS Condition of Participation Evaluations, Clinical Assessments of Nursing/Physician Documentation & Medical Necessity

Eastern New Mexico, Roswell, NM – Interim Quality Director – 4 months

Selected Achievements: Raised core measures from an overall mean of 75% to 96%. Chaired Quality Committee and restructured the

Quality dept. and Peer Review Processes.

Group Health Cooperative, Seattle, WA Developed Charge Audit and Staffing Model for Revenue Cycle, Coding/Billing and Reimbursement controls for

Internal Audit Division

Providence Centralia Hospital, Centralia, WA - Regulatory Compliance Director – Interim Position Prepared hospital for JCAHO re-accreditation implementing the new “threat to life” survey requirements Successfully met timely corrective action requirements for several Dept. of Health (CMS) surveys

Lifepath Hospice and Palliative Care, Inc., Tampa, FL 2007 to 2008 Vice President Corporate Compliance / Quality Selected Achievement:


Mitigated more than $1.2M in repayment to the Federal government by executing an organized and directed Medicare Focus review concurrently with a Medicaid Focus review.

Led process to become the 1st Hospice in Florida to achieve (and was designated) JCAHO “Deemed Status” Innovated and implemented a “Back to Basics” task force to address emergent risk management issues –

decreasing patient flights and improving patient safety. Achieved a 50% reduction in loss time through redesigned of Workers Comp Claim management and return to

work processes. Protiviti, Inc., Seattle, WA 2005 to 2007 Associate Director - Lead for Health Provider & Governmental Regulatory Selected achievement:

Served as compliance Subject Matter Expert for Protiviti consultants and management nationally Turned around client relationships to win back strategic client, gained confidence of other clients, closed three

new clients in 1 year, increasing sales by $1.2 million Developed an Enterprise Compliance Risk Tool – utilized today by Seattle Cancer Alliance, Integrity First

Consulting and Children’s Hospital and Research Center of Oakland,

University of Washington, Seattle, WA 2004 to 2005 Physicians and Children’s University Medical Group Regulatory Director of Compliance Achievement:

Developed and implemented a Corporate Integrity Agreement (CIA) for Physicians and Children’s University Medical Group. Coordinated Internal Review Organization (IRO) activities. Led the first year’s CIA implementation and successfully filed the first report with no sanctions or penalties.

Academic Medical University - 2,000+ faculty/physicians, 1,700+ employees (included residents, administrative and support staff) across 3 hospital systems , 90+ clinics Catholic Health Initiatives (CHI) – Denver, CO, 10-2000 to 4-2004 Franciscan Health System (FHS), Tacoma, WA 2000 to 2004 Regional Director of Corporate Responsibility (Compliance officer) – Achievement:

Implemented the first compliance program for one of the primer Catholic Initiative Health systems- spanned 3 hospitals, nursing home, hospice and hospitalist

Managed all aspects of a compliance program, developed the initial Gap assessment for HIPAA, reported to 3 boards, and System Finance committee, conducted investigations, education, audits/monitoring, policies & procedures

Mitigated an OIG investigation of Wound Care inappropriate coding and billing of over $125,000, with final resolution of no wrong doing and a small repayment of $25 and investigation was dismissed.

Managed the Chargemaster Dept. – in the process of restructuring and addressing non-compliant issues in the CDM, increased billable revenue by $3.2M (net) first year and $1.9 M the second year as a result of repairing CDM . Became a model for other CHI systems.

Initiated development and implementation of the Revenue Integrity Team Developed and coordinated in conjunction with CHAN (internal audit team) initial annual compliance audit

plans and risk assessments – model for Oregon and Idaho hospitals Led implementation of compliance and revenue integrity program for the FHS, a multi-health system consisting of 3 hospitals (600+ beds), trauma 2, nursing home, hospice and medical clinics; 30+ inpatient hospitalists and 100+ employed health care providers.

Catholic Health Audit Network (CHAN) Division of CHI, St. Louis, MO 2-1999 to 10-2000 Compliance Clinical Audit Manager – Achievement:


Mitigated millions of dollars in repayment and potential loss of CMS participating provider status. Developed and implemented the first nationwide clinical/coding compliance audit programs for CHAN. Developed and participated on APC and CDM Task Forces in 8 different hospital systems in 3 states. Developed new processes for managing hospital CDM for revenue generation and coding compliance.

Compliance Clinical Audit Manager, served as internal consultant to 5 CFOs and senior management teams in 8 hospital systems across 3 states, Support/Resource to 150 auditors nationwide. Reported to Board and Finance Committees of hospital systems in 3 states.

INDEPENDENT CONSULTING EXPERIENCE High Sierra Medical Group, (Affiliated with CHI) Reno, NV – 1998 Consultant / Manager, Business Services

Consolidated 3 billing centers into a central business-billing center; 8 sites, 170+ staff. Led completion of systems conversion, merging three AR systems with approximately $19M in revenue.

Reduced AR from 128 days to 68 days within 3 months of new system implementation. Developed Evaluation and Management Coding education, audit methodology and established coding

proficiencies of 85% or better Created the first compliance program for physician practices in state of Nevada and nationally.

Pediatric Health Alliance, LLC, Tampa, FL 1997 Consultant / Manager, Billing and Reimbursement

Consolidated 5 billing centers into 1 central business office. 40+ Pediatricians – 60+ staff – 5 sites Successfully appealed $500K claims due from Humana. Developed and implemented a Revenue Integrity Team to review all procedures, other services for accuracy of

CPT and Diagnosis Coding -

GENERAL NURSING & HEALTH CARE EXPERIENCE

Nations Healthcare Home Health Agency, Tampa, FL 1996 to 1998 Case Manager and Nurse Auditor

Responsible for management, and utilization review. Per Diem and weekend on-call coverage, and staffing supervision. Spanish bilingual, and certified HIV nurse.

Planned Parenthood, Lakeland and Winter Haven, FL 1993 to 1996 Clinical Services Manager

Clinical operations and financial billing oversight of 3 locations, 20+ staff and 4-6 ARNPs.

Various Hospitals and Healthcare Systems, Polk County, FL 1989 to 1995 Nursing Positions

Staffing and Per Diem nursing positions/ assignments in PICU/Med, Med Surg, Peds, Day Surg, ICU, ER, behavioral health and occupational health, hospice, home health and private duty nursing.

EDUCATION Executive JD Graduate Program, Concord Law University – Concord, CA (completed 1st year studies) BS/ASN - University of the State of New York at Albany – Excelsior College USNY, Albany, NY Respiratory Therapy Certificate, Hudson Community College, Jersey City Medical Center, NJ

WILMA ACOSTA, RN, BS, CHC, CPQH

LICENSES AND CERTIFICATION

Licensed RN (active) – State Board of Nursing for Florida, California, and Washington State. Nursing, California

Certified Healthcare Compliance Professional (CHC), Certified Professional Healthcare Quality (CPQH)

Certified Hospice Administrator (CHA)

PROFESSIONAL LEADERSHIP Health Care Compliance Association (HCCA) – Member, Speaker, Contributor since 1999 to present

• Presenter/Speaker/Advanced sessions at National Conference since 2004 Program Chair for Pacific NW Region HCCA Conference, 2003 – 2007 Program Chair and Speaker for Orlando Regional HCCA Conference, Jan. 2008, 2009

Healthcare Financial Management Association (HFMA) – Member, Speaker, Compliance Forum JCAHO – Immediate Past Advisory member of Home Health and Hospice Board

PUBLICATIONS AND PRESENTATIONS

PRIM&R – Public Responsibility in Medicine and Research –National Conference - “Human Subjects Protection Programs in Smaller Institutions”, Presenters: Offer Amit, Maria J. Arnold, Cheryl Golden, and Wilma Acosta. Dec 3, 2011

HCCA – Southeast Regional Conference, Orlando, FL – “Quality and Peer Review – What is the Role of Compliance”, Presenters: Wilma Acosta, Compliance Officer and Greg Cohen, MD, CEO of PRN – Jan 2011

HCCA Annual Compliance Institute, Dallas, TX - “Connecting the Dots – Quality & Compliance Partnership”, advance presentation session, Presenters: Wilma Acosta, Compliance Officer, and Robert Nolan, VP Compliance – April 2010

HCCA Annual Compliance Institute, Las Vegas, NV - “Medicare Focus Review, Now What”, advance presentation session, Presenters: Wilma Acosta and Robert Nolan – April 2009

GCHIMA 2008 Symposium, Pepin Heart Hosp, and Tampa, FL – “The World of Coding With Integrity” Presenter: Wilma Acosta, HCCA Regional SW Conf Chair – May 2008

HCCA National Compliance Institute, New Orleans, LA — Roundtable Discussion on “Performing a Risk Assessment for a Hospice Organization, or for the Hospice Component as Part of a Health System Risk Assessment.” Presenters: Wilma Acosta, VP Corp Compliance, Lifepath and Vickie Patterson, Associate Director, Protiviti Inc., April 2008

HCCA Physician Practice Compliance Conference, San Francisco, CA — “Pay for Performance — Will It Impact Physician Services?” Presenters: Wilma Acosta, Associate Director, Protiviti, Inc. and Richard Prebil, Foley & Lardner, October 2006

Protiviti - Health & Life Sciences Workshop — Protiviti Inc., Seattle, WA — “Health Care Audit Basics – From Admissions to Discharge.” Presenters: Wilma Acosta, Associate Director, Protiviti Inc. and HLS Team, December 2006

MGMA Reno, NV — “Key Tactics for Compliance If You Are Audited = an Ounce of Prevention,” Health Care Practice Consultants: Lori Laubach CPA, Moss Adams and Wilma Acosta, RN, BS Protiviti, Inc., July 2005

Wilma Acosta, “Spiritual Care Givers and HIPAA Compliance: Is it Possible to have both?” Journal of Health Care Compliance, Volume 5, Number 6, November – December 2003

HAN Conference, Orlando, FL “Basic Coding Terminology – What Every Auditor Needs to Know.” Presenter: Wilma Acosta, RN, FHS Corporate Compliance Director, CPUM, and Georgette Gustin, PWC, May 2000, May 1999

Maricopa County



March 26, 2014

Item 2.c.ii.

Governance

Section 10. Executive Session The Board of Directors, may call an Executive Session to discuss such matters as permitted under the applicable provisions of Arizona law, including but not limited to the Arizona Open Meeting Law A.R.S. § 38-431 et. seq. as amended from time to time.

ARTICLE VIII SPECIAL OR ADVISORY COMMITTEES

Section 1. Special or Advisory Committees By a majority vote of the Board of Directors at any meeting, open to the public, where a quorum is present, the Board may appoint special or advisory committees for such purposes as the Board directs. Such special or advisory committees shall limit their activities to the purposes for which they are impaneled and be limited in time to the task for which they are appointed. Special or advisory committees shall have only those powers as specifically conferred in writing upon them by the Board of Directors and shall report to the Board of Directors. The continuation of any special or advisory committee shall be reviewed annually if it has not been disbanded because of completion of its work. Section 2. Special or Advisory Committee Membership Unless otherwise expressly provided herein, members of a special or advisory committee shall be appointed by the Board of Directors. The chair and vice chair of a special or advisory committee, may be members of the Board of Directors. When the chair of the special or advisory committee is not a member of the Board of Directors, the Board may appoint the chair of the special or advisory committee. The Board of Directors may involve citizens of Maricopa County as members to serve on a special committee. Such citizens shall serve without compensation. In addition, the Board may take reasonable steps to involve citizens at large, from the community, who can contribute their expertise or value for the benefit of the District. Other members of a special or advisory committee, unless otherwise expressly provided herein, need not be members of the Board of Directors. In the event the chair of a special or advisory committee shall be absent from a scheduled meeting, the vice chair shall act as chair for that meeting. Section 3. Term of Office Members of a special or advisory committee shall serve for the term of the committee or at the will of the Board of Directors.

Page 11 11/28/2012

mtalbot

Highlight

MARICOPA INTEGRATED HEALTH SYSTEM BOND ADVISORY COMMITTEE

CHARTER Purpose 1. Review, prioritize and make recommendations to the Maricopa County Special Health

Care District Board of Directors (“District”) on proposed bond projects in support of the Maricopa Integrated Health System mission, vision and community needs.

2. Develop a bond proposal comprised of prioritized projects and make a recommendation to the District Board regarding the issuance of bonds or any other viable financing vehicle to fund the prioritized capital projects, including the consideration of a bond election.

3. Obtain public comment, community and stakeholder input, and expert opinion into bond

project and proposal deliberations.

Creation of Advisory Committee 1. The Maricopa County Special Health Care District Board of Directors (“Board”) will

create the Bond Committee as an Advisory Committee of the Board of Directors, as authorized by A.R.S. 38-431.

2. By Board Resolution, the Board will a. Identify the powers of the Advisory Committee. b. Establish a budget and funding source for the Advisory Committee. c. Require annual review of need for continuation of the Advisory Committee. d. Identify and contract with a consultant with project management and meeting

facilitation experience to staff the Advisory Committee. e. Establish, in conjunction with the Chief Executive Officer, criteria by which

to evaluate projects and prioritize them. f. Develop a timeline for delivery of the bond proposal and a companion ballot

proposal.

Membership of Advisory Committee 1. Advisory Committee members are to be appointed by the District Board.

2. The District Board will select members of the Advisory Committee, representing each

District and reflecting the community at large, as well as representatives from different stakeholder groups.

Approved: October 24, 2012 Revised: September 25, 2013 Revised: December 11, 2013

1

3. By the majority vote of the Board of Directors, one member of the District’s Board of Directors shall be selected to serve as a non-voting member of the Advisory Committee.

4. The Chair and Vice Chair of the Advisory Committee are to be appointed by the District Board. Powers of Advisory Committee 1. Make recommendations to the District Board regarding the creation of a bond proposal

and consideration of a bond election for the voters of Maricopa County whose goal is consistent with the Purpose of the Advisory Committee as stated above.

2. As directed by the Board of Directors and in conjunction with the consultant:

a. Develop a working knowledge of MIHS’s mission, vision, strategies, services, programs, operations and finances as a foundation from which to evaluate future needs and projects, while taking into consideration recent economic challenges, future health care delivery trends and models, and healthcare workforce training education.

b. Tour all current MIHS facilities to understand their ability to deliver services to

meet community needs today and into the future and to secure MIHS’s role as a 21st century academic medical center.

c. Review each proposed project in terms of its overall purpose, strategy, goals,

resource requirements, performance expectations and cost. Challenge underlying project assumptions regarding demand and utilization expectations as well as changes in healthcare delivery. Any recommendations for new programs or service lines need to include business plans with a five-year return on investment pro forma.

d. Recommend a proposed capital investment proposal that:

i. identifies the capital needs, and priorities of the District based on goals

and objectives;

ii. analyze the operational cost impact of each plan component; and

iii. includes a recommendation regarding capital financing.

3. The Advisory Committee may at its discretion appoint subcommittees to assist the Advisory Committee.

4. Conduct hearings to review bond projects, present the bond proposal and seek input from

the community.


2


3

5. Request additional Powers from the District Board, via Bond Advisory Committee

charter amendments, in order to carry out its duties as defined in the Purpose of said charter.

6. Limitations on power:

a. The Advisory Committee may not expend District funds without the District

Board prior approval.

b. The Advisory Committee may not make District policy.

Administrative Requirements 1. Advisory Committee and its members, and any subcommittee and its members, are

subject to the Arizona Open Meeting Law and Public Records Act and Arizona and District conflict of interest laws, regulations, and policies; and therefore:

a. Must record and maintain minutes of all meetings.

b. Conduct all meetings as open to the public and noticed as required by the Arizona

Open Meeting Law.

2. Make bimonthly reports of the activities of the Advisory Committee and any subcommittee to the District Board. The Advisory Committee shall meet not less than once a month.

3. The Advisory Committee’s final report is due by February 28, 2014.

4. All funds held by Advisory Committee are public funds and must be held in accounts

permitted for public funds and are subject to audit as public funds. Funds can only be spent in accordance with District procurement procedures.

Maricopa County



March 26, 2014

Item 2.c.iii.

Governance

Date: March 18, 2014

To: Mary A. Harden, R.N., Chairman, Board of Directors, District 1 Mark Dewane, Vice Chairman, Board of Directors, District 2 Susan Gerard, Board of Directors, District 3 Elbert Bicknell, Board of Directors, District 4 Terence McMahon, Board of Directors, District 5

From: Wilma Acosta, Interim Chief Compliance Officer

Cc: Steve Purves, President & Chief Executive Officer Louis B. Gorman, District Counsel

Re: Maricopa Integrated Health System: Code of Conduct and Ethics

Maricopa County Special Health Care District: Corporate Compliance Program Maricopa Care Advantage Plan and Education: Compliance Program

The Maricopa County Special Health Care District (“District”) was awarded a contract by the federal government to operate a Medicare Advantage Plan that operates under the name Maricopa Care Advantage Plan. The day to day operations of the District’s Maricopa Care Advantage Plan is conducted by the University of Arizona Health Network (“UAHN”).

The District and UAHN Compliance Officers reviewed and revised the above listed three compliance related documents (Attached hereto in both Redlined and Clean copy format). In addition, federal regulations require that each of these documents are reviewed annually and presented to the Governing Body of the awarded entity.

The Code of Conduct and Ethics: the District’s Code of Conduct and Ethics was last revised in December of 2012. The edits reflected in this March 2014 draft do not change the substantive provisions of the Code of Ethics but do reflect grammatical revisions, the removal of redundant provisions and the editing of various provisions to make them more easily understood.

The Maricopa County Special Health Care District: Corporate Compliance Program: this District Compliance Program has not been reviewed or revised since 2008; consequently, the Interim Chief Compliance Officer took the opportunity to bring the document current. Substantively, the provisions within the District’s Corporate Compliance Program have by and large remained unaltered; however, there have been revisions to the composition of the District’s Compliance Committee.

Maricopa Care Advantage Plan and Education: Compliance Program: attached for your review and understanding is the Maricopa Care Advantage (Medicare Advantage) Compliance Program and Education that was prepared by UAHN. Since this is the first award to the District of a Medicare Advantage Plan, this is the first opportunity that the District has had to design, approve, and implement a compliance program for this Medicare awarded contract.

Federal regulatory authorities require that the District, as the Medicare Advantage Plan awardee, and its Board of Directors, be presented with the Compliance Program and Education. This presentation is being accomplished via the attached Plan as well as the attached PowerPoint presentation entitled “Compliance Program & Fraud, Waste & Abuse Plan”.

Should you have any questions concerning the above or the attached documents, as the Interim Compliance Officer, I will be available to assist in addressing the questions.

Page 2

THE MARICOPA COUNTY SPECIAL HEALTH CARE DISTRICT

d/b/a MARICOPA INTEGRATED HEALTH SYSTEM

2008 2014 CORPORATE COMPLIANCE PROGRAM

MARICOPA INTEGRATED HEALTH SYSTEM CORPORATE COMPLIANCE PROGRAM

DESCRIPTION OF THE 2008 2014 COMPLIANCE PROGRAM Purpose - The Maricopa County Special Health Care District d/b/a Maricopa Integrated Health System (“MIHS”) has adopted the 2008 2014 Corporate Compliance Program (“Compliance Program”) to reaffirm MIHS’ commitment to conducting its business in full compliance with applicable statutes, regulations, and other Federal and State health care program requirements. The enhanced program provides a solid framework for structuring a comprehensive range of compliance activities that are designed to avoid legal and compliance problems in the first instance, to effectively address compliance allegations as they arise, and to remedy the effects of noncompliance.

Legal Basis – MIHS’ Compliance Program has been developed in accordance with applicable law, with guidance from Federal and state authorities, including the United States Federal Sentencing Guidelines, adapted to providers of health care services by the Department of Health and Human Services’ Office of Inspector General in its various Compliance Program Guidance documents1. The scope of the Compliance Program may be expanded in the future to cover additional areas of regulatory compliance to which MIHS is subject.

Core Elements - The Compliance Program reflects MIHS’ good faith commitment to identify and reduce risk, improve internal controls, and establish standards to which the entire organization shall adhere. As such, MIHS adopts the following principles of compliance:

1. Developing and distributing a written Code of Conduct and Ethics (“Code of

Conduct and Ethics”), as well as written policies and procedures that promote MIHS’ commitment to compliance, provide general and specific operational guidance, and identify specific areas of risk.

2. Designating a Chief Compliance Officer (“CCO”) and Compliance

Committees charged with the responsibility of operating and monitoring the Compliance Program.

3. Developing and implementing regular, effective compliance education and

training programs for all MIHS employees, corporate officers, members of the Board of Directors of the Maricopa County Special Health Care District (“Board”) and medical staff members.

1 See 63 FR 8987 (Feb. 23, 1998) for the compliance program guidance for hospitals; 69 FR 32012 for the supplemental compliance program guidance for hospitals (June 8, 2004). These documents, along with the other OIG compliance program guidance documents, are available at http://www.hhs.gov/oig/. 7/11/20083/14/2008 Page 2

http://www.hhs.gov/oig/

http://www.hhs.gov/oig/

4. Maintaining an effective and well-publicized disclosure program to provide guidance and receive complaints about potential Compliance Program violations without fear of retaliation.

5. Developing disciplinary standards and appropriate hiring criteria to respond to

allegations of improper or illegal activities, and carrying out the equitable enforcement of these standards on employees who have violated laws, regulations, other State or Federal health care program requirements or the Compliance Program standards.

6. Maintaining effective auditing and monitoring systems and protocols to

evaluate MIHS’ compliance with laws, regulations, other State or Federal health care program requirements and the Compliance Program standards; to assist in the prevention of Compliance Program violations; and to maintain the efficacy of the Compliance Program.

7. Investigating, responding to and preventing identified compliance problems,

including establishing appropriate and coordinated corrective action measures.

Scope - These Compliance Program standards shall apply to all MIHS’ board members, officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and agents affiliated with MIHS throughout MIHS’ diverse operations. It is the responsibility of all employees, officers, administrators, managers, supervisors, board members, medical staff members and agents to be familiar and comply with all requirements of the Compliance Program that pertain to their respective areas of responsibility, recognize and avoid actions and relationships that might violate those requirements, and seek guidance from the Office of Compliance in situations raising legal or ethical concerns.

Limitations – The Compliance Program is not intended to summarize all laws and regulations applicable to MIHS. This Compliance Program is a living document that will be updated periodically to assure that MIHS’ board members, officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and agents are kept informed of the most current legal and compliance developments in the health care industry.

GLOSSARY OF IMPORTANT TERMS

These terms will have the following meanings throughout the MIHS Corporate Compliance Program:

“Agents” or “agents” with respect to MIHS shall mean all persons and entities that have contracted with or volunteer at MIHS to provide services, equipment or other items that impact MIHS’ provision of services to patients, and MIHS’ relationship with Federal Health Care Programs. Agents shall include, but not be limited to, residents, medical students, independent contractors, consultants, volunteers and vendors.

“Audit” or “audit” shall mean a formal review of compliance with internal (e.g., policies and procedures) and external (e.g., laws and regulations) standards. 3/14/20087/11/2008 Page 3

“Board” shall mean the Board of Directors of the Maricopa County Special Health Care District.

“CCO” shall mean MIHS’ Chief Compliance Officer.

“CEO” shall mean MIHS’ Chief Executive Officer.

“DC” shall mean MIHS’ District Counsel.

“Complainant” or “complainant” shall mean a person who reports suspect conduct that is alleged to be inconsistent with the requirements of the Compliance Program.

“MIHS” shall mean the Maricopa County Special Health Care District d/b/a Maricopa Integrated Health System, its subsidiaries and other affiliates.

. “Employees” or “employees” shall mean those persons employed by MIHS, including, but not

limited to, officers, administrators, managers, supervisors, employed medical staff, and other health care professionals.

“Excluded Individuals and Entities” refers to an individual or entity who: (a) is currently excluded, debarred, suspended, or otherwise ineligible to participate in the Federal Health Care Programs or in Federal procurement or non-procurement programs; or (b) has been convicted of a criminal offense that falls within the ambit of 42 U.S.C. § 1320a-7(a), but has not yet been excluded, debarred, suspended, or otherwise declared ineligible.

“Exclusion Lists” refers to the electronic lists of excluded individuals or entities maintained by the OIG and General Services Administration (“GSA”).

“Compliance Committee” shall mean those MIHS employees appointed to the MIHS Compliance Committee and who are responsible for providing direct support to the CCO in the creation, implementation and operation of the Compliance Program.

“Federal Health Care Programs” as defined in 42 U.S.C. Section 1320a-7b(f), include any plan or program that provides health care benefits to any individual, whether directly, through insurance, or otherwise, which is funded directly, in whole or in part, by a United States Government or state health care program, including, but not limited to, Medicare, AHCCCS, the Military Health System (TRICARE), Department of Veterans Affairs (“VA”), Federal Bureau of Prisons, and Indian Health Services, but excluding the Federal Employees Health Benefit Program (“FEHBP”).

“Medical Staff”, “medical staff”, or “medical staff member” shall mean those physicians and other health professionals who have been granted membership or clinical privileges to admit, treat or practice medicine within the facilities owned or operated by MIHS, according to the terms of the Bylaws of the Medical Staff.

“Monitoring” or “monitoring” refers to reviews that are repeated on a regular basis during the normal course of MIHS’ operations.

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“Officers” or “officers” shall mean MIHS employees who hold an office of trust, authority, or command.

“OIG” is the Office of Inspector General of the United States Department of Health and Human Services.

“Board Members” or “board members” shall mean the members of the Board of Directors of the Maricopa County Special Health Care District.

I. Written Standards

A core principle of this Compliance Program is the development, distribution and implementation of written standards that address principal risk areas and reflect MIHS’ commitment to promote compliance with all applicable legal duties and to foster and assure ethical conduct. These written standards shall consist of the Code of Conduct and Ethics and policies and procedures that reflect MIHS’ values and expectations regarding the behavior of MIHS’ board members, officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and agents, explain the operation of the Compliance Program, clarify and establish internal standards for compliance with laws and regulations, and help MIHS’ board members, officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and agents understand the consequences of noncompliance to both MIHS and the individual.

A. Code of Conduct and Ethics

MIHS has adopted a Code of Conduct and Ethics. The Code of Conduct and Ethics is intended to serve as a guide to provide standards by which MIHS’ board members, officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and agents will conduct themselves to protect and promote organization-wide integrity and to enhance MIHS’ ability to achieve its organizational mission. The Code of Conduct and Ethics is designed to assist all MIHS’ board members, officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and agents in carrying out daily activities within the appropriate ethical and legal standards. The Code of Conduct and Ethics, however, is not a substitute for each employee, board member, medical staff member or agent’s own internal sense of fairness, honesty, and integrity. Instead, each employee, board member, medical staff member and agent must utilize their own good judgment, along with the principles announced in the Code of Conduct and Ethics, to maintain MIHS’ value of integrity.

The Code of Conduct and Ethics is intended to be easily understood. In some instances, the Code of Conduct and Ethics deals fully with the subject-matter covered. In many cases, however, the subject discussed is sufficiently complex that additional guidance is necessary to provide adequate direction. Consequently, the Code of Conduct and Ethics is designed to be supplemented by this Compliance Program and a comprehensive set of compliance policies and procedures that may be accessed through MIHS’ Intranet and through review of copies placed in each MIHS department, as warranted. Those policies

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shall expand upon and supplement many of the principles articulated in the Code of Conduct and Ethics.

The Code of Conduct and Ethics defines how MIHS operates and conducts business with respect to the following:

(i) Commitment to patients and customers;

(ii) Commitment to legal and regulatory compliance endeavors;

(iii) Expectation that MIHS’ board members, officers, administrators,

managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and agents remain free of conflicts of interest in the performance of their responsibilities and services to MIHS ;

(iv) Commitment to satisfy the payment conditions required by the payers with

which MIHS transacts business, including Federal Health Care Programs;

(v) Commitment to monitor and structure its relationships with physicians and other providers in ways that satisfy the community;

(vi) Commitment to a diverse workforce; and

(vii) Commitment to ensure that health information is used and safeguarded

effectively and appropriately. B. Policies and Procedures

This Compliance Program demands the establishment, distribution and maintenance of sound policies and procedures that not only govern the operation of the Compliance Program, but that also address MIHS’ principal legal risk areas.

Policies directly relating to the operation of the Compliance Program shall address critical issues, such as the following:

• The duties of the CCO, the duties and the constitution of the Compliance

Committee and the duties of any subcommittees or task forces created by the Compliance Committee;

• Compliance education and training program requirements;

• The specific operation of the Disclosure Program;

• Disciplinary standards and action to be pursued against those found to have

violated the Compliance Program standards;

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• Screening mechanisms for new employees, including protocol for querying the lists of Excluded Persons and Entities to identify persons and entities who have been sanctioned by Federal Health Care Programs;

• Effective auditing and monitoring procedures;

• Investigating and responding to complaints and potential compliance

problems; and

• Implementing corrective action plans in instances of noncompliance.

There are certain areas of heightened risk that have been identified throughout the health care industry, including the investigative and audit functions of the OIG; therefore, to ensure that the Compliance Program remains effective, it is important for MIHS’ policies and procedures to adequately address the following risk areas:

• The integrity and accuracy of claims submitted to the Federal and State Health

Care Programs and commercial payors for reimbursement, including policies that address:

(i) Billing separately for outpatient services within 72 hours prior to

an inpatient admission;

(ii)

Billing for a patient discharge that accurately should be billed as a patient transfer;

(iii)

Claiming reimbursement for services that have not been rendered;

(iv)

Filing duplicate claims for the same service;

(v)

“Upcoding” to more complex procedures than were actually performed to obtain greater payment than that which is applicable to the items or service actually provided;

(vi)

“Unbundling” or splitting a code for combined services into individual component codes to maximize reimbursement;

(vii)

Including inappropriate or inaccurate costs on hospital cost reports;

(viii)

Falsely indicating that a particular health care professional attended a procedure, or that services were otherwise rendered in a manner they were not;

(ix)

Billing for a length of stay beyond what is medically necessary;

(x)

Billing for services or items that are not reasonable and necessary for the diagnosis or treatment of illness or injury or to improve certain functions; and

3/14/20087/11/2008 P 7

(xi) Billing excessive charges.

• Guidance regarding gifts, gratuities and discounts to Federal Health Care Program beneficiaries.

• Patient referrals to and by MIHS and its Medical Staff to promote the best

interests of every patient and to comply with applicable anti-kickback and patient self-referral laws.

• Appropriate methods for recruiting physicians to MIHS.

• The manner in which MIHS is authorized to acquire physician practices.

• The manner in which MIHS contracts with physicians for professional,

academic and administrative services.

• MIHS’ obligations and rights when dealing with patients in emergency situations.

• The protection of confidential and other sensitive health information.

• The law surrounding conflicts of interest and best strategies for avoiding and

identifying potential conflicts.

• Compliance standards to govern MIHS’ relationship with independent contractors, vendors, and other agents.

Policies and procedures should be easily available to all employees, medical staff and agents, and revised on a regular basis.

II. Chief Compliance Officer and Committee

MIHS’ CCO, provides management and oversight for the ongoing development and implementation of the Compliance Program. MIHS shall also establish a compliance committee to advise and provide support to the CCO in the implementation and maintenance of the Compliance Program.

A. Chief Compliance Officer

While compliance is everyone’s responsibility, the CCO is the focal point of the Compliance Program and shall be accountable for all compliance responsibilities at MIHS. The CCO may delegate authority and responsibility for compliance activities to an appropriate delegatee in the Office of Compliance, or as the CCO otherwise determines, in a manner consistent with the structure and provisions of the Compliance Program.

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The presence of the CCO does not diminish or alter an employee, board member, medical staff member or agent’s independent duty to abide by the Compliance Program. For example, managers and supervisors should be responsible for monitoring and promoting compliant behavior among those he or she supervises.

In addition to the general accountability for MIHS’ Compliance Program, the CCO’s responsibilities include:

• Periodically assessing MIHS’ compliance risk exposure and the development

of action plans to assure that the Compliance Program responds to identified risk areas.

• Formulating and ensuring the distribution of the Code of Conduct and Ethics.

• Overseeing the establishment, distribution and maintenance of the policies and

procedures necessary to support the Compliance Program.

• Ensuring that effective systems are established to prevent employment of individuals or contracting with Agents or vendors who are Excluded Individuals or Entities or who are otherwise determined to have engaged in illegal activities.

• Ensuring that compliance education and training programs are effective to

familiarize all MIHS employees, board members, medical staff and agents with the components of the Compliance Program, the Code of Conduct and Ethics, and other compliance policies.

• Updating and refreshing education and training information through

mandatory periodic training that addresses compliance issues related to specific departments, groups of employees or medical staff.

• Coordinating internal audit endeavors to assess the effectiveness of MIHS’

internal controls and to detect significant violations of legal and ethical standards.

• Maintaining a well-publicized disclosure program for reporting of potential

Compliance Program violations without fear of retaliation and promoting effective lines of communication for employees, board members, medical staff and agents to pose informal compliance questions.

• Maintaining a record of compliance-related complaints and allegations and the

disposition of each case, including any associated disciplinary actions and remedial action pursued by MIHS.

• Conducting investigations, or authorizing outside investigations, in

consultation with the DC, of potential violations of laws, regulations, other State or Federal Health Care Program requirements, or instances of unethical behavior, which jeopardize MIHS.

3/14/20087/11/2008 Page 9

• Evaluating, determining and implementing the most appropriate remedy to correct an incident of noncompliance, once detected, and develop and implement strategies for identifying and preventing future incidents.

• Reporting, in consultation with the DC, any compliance matter requiring external reporting or disclosure.

• Making regular reports on compliance developments to the CEO and to the

Board, after consulting with the DC. Additional reports may be made to the CEO and the Board as determined by the CCO and the DC, with input from the CEO and the Board.

• Serving as Chairperson of the Compliance Committee.

• Maintaining a good working relationship with key operational areas relevant

to the effective implementation of the Compliance Program, including Internal Audit Services, Patient Financial Services, Human Resources and Health Information Management.

• Providing guidance and interpretation to the Board, CEO and other officers, in

consultation with the DC, on matters related to the Compliance Program.

• Preparing, at least annually a report describing the compliance activities and actions undertaken during the preceding year, the compliance priorities for the next year, and any recommendations for changes to the Compliance Program. This report should include input from the DC and the Internal Audit Services Department.

• Reviewing and updating this Compliance Program at least annually, and as

required by events, such as changes in the law, or discovered flaws in the Program.

To carry out the responsibilities of his or her role, the CCO has complete authority to review all documents or other information related to compliance activities, including, but not limited to:

• Patient records

• Billing records

• Records concerning marketing activities

• Records concerning MIHS’ arrangements with MIHS’ board members,

officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, agents and payors

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• Contracts and obligations that may implicate applicable laws, such as anti- kickback, physician self-referral or other statutory or regulatory requirements.

B. Compliance Committee

The Compliance Committee shall be responsible for providing support to the CCO in the creation, implementation and operation of the Compliance Program. This committee is critically important to establishing accountability, credibility, and the structure of the Compliance Program. The purpose of the Compliance Committee is to allow MIHS and the CCO to benefit from the combined perspectives of individuals with diverse responsibilities and experiences.

Members of the Compliance Committee should include the Chief Compliance Officer, the Chief Executive Officer, the Chief Operating Officer, the Chief Financial Officer, the Chief Information Officer, the Chief Nursing Officer, the Chief Medical Officer, Vice President of Ambulatory and Physician Services, Executive Director of AZ Children’s Services, VP Hospital Operations, Executive Director of Trauma, Endoscopy, Perioperative Service Lines, the Vice President Behavioral Health, and the District Council. Members of the Compliance Committee include the Chief Compliance Officer, the Chief Executive Officer, the Chief Operating Officer, the Chief Financial Officer, the Chief Information Officer, the Chief Nursing Officer, the Chief Medical Officer, the Vice President of Administrative Services, the Vice President of Cardiac and Ancillary Services, the Director of Internal Audit, the Director of Health Information Management and the District Counsel.

The District Counsel monitors compliance activity with consideration for MIHS’ interests and concerns and ensures the preservation of attorney-client and work- product privileges due certain information. The Director of Internal Audit provides audit interpretation and procedural/processing advice from an audit perspective and ensures that prospective compliance reviews are appropriately designed.

The Compliance Committee’s responsibilities include:

• Preliminary review of all compliance concerns and proposed

recommendations as identified. • Identification of compliance concerns which warrant Executive Compliance

Committee monitoring due to their potential for becoming significant issues for MIHS.

• Authorization of investigative/research activities on potentially significant issues.

• Ensuring the development of acceptable resolution and prevention action plans for potentially significant issues.

• Developing a corporate structure to promote compliance of organizational

functions.

• Analyzing the requirements with which MIHS must comply, and the specific risk areas.

Comment [WU1]: This explains the disconnect from MMC Peds, MMC Inpatient, and Behavioral Health Departments. I have not added, but we should consider VP of Finance, VP of Revenue Cycle, VP of Laboratory Services, and VP of Pharmacy. It does not make sense to include on VP and not the other. Perhaps it all rolled up under one VP; but now it is separated.

• Updating and providing revisions to the Code of Conduct and Ethics

• Developing effective training programs. 3/14/20087/11/2008 Page 11

• Recommending and supervising, in consultation with the relevant departments and facilities, the development of internal systems and controls to achieve the standards set forth in the Code of Conduct and Ethics and MIHS’ policies and procedures.

• Determining the appropriate strategy to promote adherence to the Compliance

Program standards.

• Developing a system to solicit, evaluate and respond to complaints and problems.

• Creating and implementing effective methods for the proactive identification

of potential compliance issues throughout MIHS.

• Assessing the effectiveness of the Compliance Program.

• Furnishing recommendations to the CCO regarding reports to be furnished to the CEO, the Board, or external third parties.

• Reviewing and providing comments on the annual audit plan.

• Provide guidance and support to the CCO in furtherance of his/her duties and

responsibilities. The Compliance Committee may also address other compliance functions as the Compliance Program develops.

The Compliance Committee shall create ad hoc committees and task forces as necessary to perform specialized functions, such as conducting an investigation into reported noncompliance, in an efficient and effective manner.

The Compliance Committee is authorized to invite other MIHS employees to meetings to draw from other relevant expertise related to the matter under discussion.

C. Outside Consultants

The CCO is authorized to rely on outside consultants to provide legal, financial, billing, clinical and other assistance as needed. The CCO shall consult with either the DC or the CEO before engaging outside consultants.

III. Education and Training

To promote compliance with applicable legal requirements and to assure that the standards set forth in this Compliance Program are maintained, MIHS is committed to conducting education and training programs for MIHS’ board members, officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and, as applicable, agents at least annually, but more often if there is a change in law, regulation or policy that affects the Compliance

3/14/20087/11/2008 Page 12

Program, or if specific issues arise and the CCO feels there is a need for additional training.

The CCO, working with the MIHS education and development staff and MIHS management, shall be responsible for the proper coordination and supervision of the education and training process. The CCO shall develop and maintain a general compliance training program that is designed to provide an overview of Compliance Program activities and requirements and emphasizes the areas that generate the greatest compliance risks for MIHS.

In addition to a general compliance training program, MIHS will also sponsor more detailed, job-specific compliance training programs designed for MIHS’ board members, certain officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and, as applicable, agents, to help them effectively perform their job duties, and comply with the various specific legal and ethical issues that general training may not cover.

The combined general and specific compliance training programs are intended to provide each MIHS board member, officer, administrator, manager, supervisor, employee, medical staff, resident, other health care professional, medical student, and agent with an appropriate level of information and instruction regarding the Compliance Program, applicable legal requirements, ethical standards, and appropriate procedures to fulfill the objectives of the Compliance Program. Both general and specific compliance training programs shall include distribution of the Code of Conduct and Ethics and policies and procedures relevant to the various departments, facilities and committees.

Each new employee orientation will, at a minimum, include general compliance training. New employees may also receive specific training based on their job-function.

Compliance education and training sessions shall be conducted by qualified personnel, which may include the CCO, the DC, or other trained MIHS personnel. Seminars may also be conducted by consultants or vendors competent to provide educational programs. The CCO is authorized to require that MIHS officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and, as applicable, agents attend, at MIHS’ expense, publicly available seminars covering relevant areas of law.

Education and training programs should be updated to consider results from audits and investigations, feedback from previous training and education programs, trends in hotline reports, and changes in Federal Health Care Program requirements. As new developments or concerns arise, the CCO may require additional training for some or all employees.

Attendance at and completion of the education and training programs should be mandatory for all employees (including officers), board members and medical staff with regard to general training, and selected employees and agents with regard to specific training. Attendance shall also be a factor in each employee’s performance evaluation. Failure to attend and complete compliance training will be grounds for disciplinary action, which may include termination of employment. 3/14/20087/11/2008 Page 13

The CCO shall be responsible for seeking feedback from employees, medical staff and agents attending training and education sessions, and developing and implementing a system for retaining records of employee training, including attendance logs, certifications, and material distributed at training sessions.

IV. Disclosure Program

The successful implementation of the Compliance Program requires an open line of communication between MIHS’ board members, officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and agents and the compliance office. All MIHS board members, officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and agents are encouraged to communicate their compliance concerns to, as applicable, their direct supervisors, the CCO or the DC to enable MIHS to identify possible Compliance Program violations early, and more immediately initiate investigations, determine the materiality of violations, and, if necessary, implement the appropriate corrective action. Once an MIHS board member, officer, administrator, manager, supervisor, employee, medical staff, resident, other health care professional, medical student, or agent has made a report, the complainant has a continuing obligation to update the report as new information becomes known to the complainant.

To ensure a viable disclosure program, the following steps shall be incorporated:

• Creation of an environment within which MIHS board members, officers,

administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and agents feel comfortable reporting concerns, questions and instances of improper conduct without fear of retaliation.

Provision of a mechanism for confidential or anonymous reporting for employees, board members, medical staff and agents who are uncomfortable reporting concerns to a supervisor, manager, or the CCO. This reporting may be accomplished through the use of the MIHS Compliance Hotline which can be accessed 24 hours a day, 7 days a week, by dialing 1-866-333-MIHS.

• Publicizing the MIHS Compliance Hotline in a manner in which all

employees, board members, medical staff and agents may know of its existence.

• Tracking, documentation and oversight mechanisms to ensure that reports of

suspected noncompliance are fully and promptly investigated and addressed. In the case of the MIHS Compliance Hotline, a log of the calls received should be maintained by the CCO.

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• Mechanisms to ensure that the CEO, the Board, and relevant senior management are properly and regularly apprised of, and can take appropriate action on, compliance issues identified in investigations that result from reports of noncompliance. Such action may include the development or updating of related policies and procedures and training content.

Although MIHS shall always strive to maintain the confidentiality of a complainant’s identity, regardless of whether the complaint is reported through the Hotline of the complainant’s supervisor, the complainant should be made aware that his or her identity may have to be revealed in certain circumstances, such as scenarios involving governmental enforcement authorities, or when it is necessary to further the internal investigation or where required by law or regulatory authority. Nevertheless, no complainant may be retaliated against unless the complainant is responsible for the noncompliance.

V. Disciplinary Standards and Hiring Criteria

Compliance with Compliance Program standards and all applicable laws and regulations is a condition of employment or association with MIHS and MIHS will pursue appropriate disciplinary action to enforce compliance.

A. Disciplinary Standards

MIHS shall develop, implement and maintain a mechanism of accountability and discipline for individuals who violate any law or regulation, or any of the Compliance Program standards, in the course of their employment or association with MIHS. Examples of actions or omissions that will subject an officer, administrator, manager, supervisor, employee, medical staff, resident, other health care professional, medical student, and certain agents to disciplinary action include, but are not limited to:

• A violation of law or any of the Compliance Program standards;

• Failure to report a suspected or actual violation of law or the Compliance

Program, or failure to cooperate fully in an internal investigation of alleged noncompliance;

• Lack of attention or diligence on the part of supervisory personnel that

directly or indirectly leads to a violation of law or the Compliance Program;

• Direct or indirect retaliation against anyone who reports through any means a violation or possible violation of law or the Compliance Program; or

3/14/20087/11/2008 Page 15

• Deliberately making a false report of a violation of law or any of the Compliance Program standards.

Possible disciplinary action may include, but shall not be limited to, counseling, warning, suspension, demotion, reduction in pay, revocation of privileges, termination of employment, and termination of contracts or failure to renew agreements, depending on the degree of severity of noncompliance. Disciplinary action will be pursued on a fair and equitable basis, and employees at all levels of MIHS shall be subject to disciplinary action for the commission of offenses, including officers. The Human Resources Department will serve as the appropriate body to ensure that the imposed discipline is proportionate and administered fairly and consistently in compliance with MIHS policies and procedures.

Disciplinary standards shall be well-publicized and shall be disseminated and available to all levels of MIHS officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and agents, where applicable. Enforcement of disciplinary standards will require an effective working relationship between the Office of Compliance, Human Resources Department and other areas of MIHS maintaining primary responsibility for administering discipline.

B. Hiring Criteria

No individual who has engaged in illegal or unethical behavior and/or has been convicted of health care-related crimes shall occupy positions within MIHS that involve the exercise of discretionary authority.

Accordingly, any applicant for an employment position with MIHS , and any agent seeking to provide services to or for MIHS , will be required to disclose whether the individual, or entity, has ever been convicted of a crime, including crimes related to health care or has ever been sanctioned by a Federal Health Care Program. In addition, MIHS will reasonably inquire into the status of each prospective employee and agent by, at a minimum, pursuing the following steps:

• Conducting background checks of employees and agents with discretionary

authority in the delivery of health care services or items, or billing functions to ensure that no history of engaging in illegal or unethical behavior exists;

• Conducting periodic reviews of the GSA’s List of Parties Excluded from

Federal Programs available at www.arnet.gov and the OIG’s List of Excluded Individuals and Entities at http://www.oig.hhs.gov/fraud/exclusions.html; and

• Conducting periodic reviews of the National Practitioner Data Bank for

physicians and other health care practitioners.

MIHS shall not knowingly employ or contract with Excluded Individuals and Entities. Accordingly, MIHS has implemented procedures to terminate employees, or its

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http://www.arnet.gov/

http://www.oig.hhs.gov/fraud/exclusions.html%3B

relationship with Contractors or Agents, who have been convicted or excluded from participation in Federal Health Programs. In no instance will MIHS allow a clinician, physician or billing representative to perform in those capacities if such person or entity has been excluded from participation in any Federal Health Care Program.

In carrying out these functions, MIHS supports the principles of the Equal Employment Opportunity Commission and will not discriminate with respect to race, color, religion, sex, national origin, age, sexual orientation, disability, or any other basis prohibited by Federal, state, or local laws in any aspect of its employment or hiring practices. In addition, MIHS is committed to providing employees with assistance when a violation of these non-discrimination practices is suspected. MIHS will not tolerate harassment of its employees or agents by other employees or agents. Examples of harassment that are explicitly prohibited include words or actions that are sexual in nature, as well as words or actions based on, race, color, religion, national origin, age, sexual orientation, presence of a disability or other basis protected by Federal, state, and local laws.

VI. Auditing and Monitoring

MIHS will facilitate organizational compliance by conducting a variety of active auditing and monitoring functions designed to test and confirm compliance with legal requirements and with the Compliance Program standards. Auditing and monitoring functions are critical in identifying areas in which Compliance Program standards have not been fully understood, followed or properly implemented. MIHS will utilize the auditing and monitoring functions to measure the Compliance Program’s effectiveness with regard to the functions instrumental to its operation, such as the education and training programs, employee screening, and the appropriateness of disciplinary actions.

Regular audits shall be set forth in an audit plan to be reviewed by the Compliance Committee and conducted by the Internal Audit Department or other appropriate persons with input from the CCO as necessary. The audit plan shall be re-evaluated annually to ensure that it addresses the proper areas of concern, which may be based on the prior years’ audit findings, or risk areas identified as part of an annual risk assessment. In addition, the audit plan shall include an assessment of billings systems, in addition to claims accuracy, in an effort to identify the origin of billing errors.

Individuals who conduct the compliance audits will be independent from the area audited. Persons conducting compliance audits will have a general awareness of applicable federal and state health care laws and Federal Health Care Program requirements, and will confer with the CCO and/or DC for specific guidance concerning legal requirements as needed. Audits will target diverse levels of MIHS operations, including external relationships with third-party contractors, specifically those with substantive exposure to government enforcement actions, potential kickback arrangements, physician self-referrals, billing, coding, claim development and submission, cost reporting, and marketing endeavors. Further, and as warranted, audits will be repeated on a periodic basis to measure MIHS’ current level of compliance, as well as its progress in attaining increased levels of compliance as the Compliance Program matures.

Compliance audits may take one or more of the following forms: 3/14/20087/11/2008 Page 17

• A baseline audit is an initial audit in a series of identical audits, and provides a basis against which the progress of future audits is compared. Assessment of organizational risk levels can be determined through baseline audits.

• Prospective audits occur before billing, and will allow MIHS to correct

discovered errors before submitting a bill.

• Retrospective audits occur after billing, and may require MIHS to correct discovered errors by re-billing or self-disclosing to a Federal, state or private health care program.

• Special audits are performed at the direction of the CCO, with input from the

DC, in response to events such as internal or external investigations.

• Post-compliance reviews are audits performed following the correction of a compliance issue to determine the effectiveness of the remedial effort.

• A risk assessment is a broad based audit that may be used to identify the

effectiveness of and opportunities for improvement in the Compliance Program. This type of audit should occur at least annually.

The CCO, with input from MIHS’ Internal Audit Services Department as necessary, will establish procedures to supplement such audits, which may include:

• Interviews conducted with personnel involved in management, operations and

other related activities, to be conducted by the CCO, a designee of the CCO, the DC, or a designee of the DC;

• Reviews, at least annually, to determine the efficacy of the Compliance

Program (e.g. the effectiveness of education and training programs); and

• Reviews of billing documentation, including clinical documentation, in support of a claim.

MIHS’ compliance monitoring activities will be carried out by and within each department or product line. The CCO will communicate to each department and product line the level of monitoring activities necessary to detect and prevent violations of Compliance Program requirements. Monitoring activities should provide MIHS with the opportunity to correct any noncompliance before it creates significant risk to MIHS. Monitoring activities may also be initiated by departments and product lines when no specific problems have been identified to confirm and document ongoing compliance.

Compliance reports created by an auditing or ongoing monitoring process, including reports of noncompliance, should be reported to, and maintained by, the CCO and shared with the DC, the Compliance Committee, the CEO and the Board as dictated by MIHS policy. The CCO will report compliance matters to the Board on a quarterly basis and as the CCO, in consultation with the DC, determines is necessary.

3/14/20087/11/2008 Page 18

VII. Investigation, Response and Prevention

Detected but uncorrected violations of law or the Compliance Program standards can seriously endanger the mission, reputation and legal status of MIHS. Consequently, MIHS will establish mechanisms that make possible prompt responses to situations where conduct inconsistent with legal requirements or Compliance Program standards is reported, suspected or confirmed.

When an instance of potential noncompliance is reported, suspected or confirmed, the CCO should consult with the DC and coordinate with representatives from the relevant functional areas, which may include the Audit Services Department or Patient Financial Services, to pursue the following steps:

• Promptly halt the underlying activity and halt or mitigate, where possible, any

ongoing harm caused by the suspected noncompliance.

• Fairly and expediently investigate, according to MIHS policy and procedure, to determine the existence, scope and seriousness of the noncompliance, and to identify the conduct or process that caused the noncompliance.

• Respond with appropriate action to correct the confirmed noncompliance.

• Implement preventative measures to avoid similar instances of noncompliance

in the future.

• Perform periodic reviews of the identified problem areas to ensure that the implemented preventative measures have effectively eliminated the cause of the noncompliance.

If an investigation uncovers credible evidence of noncompliance, and, after a reasonable inquiry, the CCO has reason to believe that the noncompliance may violate any criminal, statute or regulation, the matter will be immediately reported to the DC for advice regarding MIHS’ reporting obligations. After consulting with the DC, the CCO will report such matters to the CEO and the Board; these reports will be made within 48 hours of each other. The CCO will maintain appropriate protocol to ensure that steps are pursued to secure or prevent the destruction of documents or other evidence relevant to the investigation. The CCO shall be responsible for directing appropriate corrective action to be taken, which may include re-billing for services improperly billed and disclosure to applicable payers, including federal and state health programs.

ACKNOWLEDGEMENT and CERTIFICATION

Employee, Board member, Medical Staff and Agent Acknowledgement Process All MIHS board members, officers, administrators, managers, supervisors, employees, medical staff, residents, other health care professionals, medical students, and agents will

3/14/20087/11/2008 Page 19

receive these Compliance Program standards and other information necessary to assure compliance with these standards. All new employees, medical staff and agents will receive a copy of the Compliance Program standards within 2 weeks after beginning employment or association with MIHS. Within 4 weeks after receiving the Compliance Program Manual, each employee, board member, medical staff member and agent must sign and return the Acknowledgement Form reprinted at the end of this Manual, which states that the employee, board member, medical staff member and agent has read and understands the provisions of this Manual. If any employee or agent is unable to read this document, it will be explained to such person verbally. Each employee, board member, medical staff member and agent will be required to review these Compliance Program standards and sign and return a new “Acknowledgement Form” periodically and as updates occur. All employees, board members, medical staff and agents are encouraged to ask questions or comment on the components of the standards. All Acknowledgement and Certification Forms must be submitted to the Office of Compliance, and the Office of Compliance will be responsible for tracking appropriate completion of all Acknowledgements and Certifications.-

3/14/20087/11/2008 Page 20

EMPLOYEE ACKNOWLEDGEMENT AND CERTIFICATION

I hereby certify that I have received and read the Maricopa Integrated Health System Compliance Program Standards and I understand that compliance with the requirements set forth in the Compliance Program is a condition of my continued employment. I understand that it is my responsibility to read, understand and seek guidance, should I require clarification, with regard to these standards. I also understand that I may be subject to disciplinary action, up to and including termination, for violating these standards or failing to report violations of these standards.

Print Name:

Signed:

Department:

Date:

Please retain a copy for your records and return your original signed acknowledgement form to:

The Office of the Chief Compliance Officer

Maricopa Integrated Health System 2601 E. Roosevelt Street

Phoenix, AZ 85008

3/14/20087/11/2008 Page 21

BOARD MEMBER ACKNOWLEDGEMENT AND CERTIFICATION I hereby certify that I have received and read the Maricopa Integrated Health System Compliance Program standards. I understand that it is my responsibility to read, understand and seek guidance, should I require clarification, with regard to these standards, and to act in accordance with these standards at all times in my service as board member.

Print Name:

Signed:

Date:


The Office of the Chief Compliance Officer Maricopa Integrated Health System

2601 E. Roosevelt Street Phoenix, AZ 85008

3/14/20087/11/2008 Page 22

MEDICAL STAFF ACKNOWLEDGEMENT AND CERTIFICATION

I hereby certify that I have received and read the Maricopa Integrated Health System Compliance Program standards. I understand that it is my responsibility to read, understand and seek guidance, should I require clarification, with regard to these standards, and to act in accordance with these standards at all times.

Print Name:

Signed:

Date:




Phoenix, AZ 85008 3/14/20087/11/2008 Page 23

AGENT ACKNOWLEDGEMENT AND CERTIFICATION

I hereby certify that I am the independent contractor referenced below (the “Contractor”), or am a duly authorized officer of the Contractor. On behalf of the Contractor and its employees, officers, board members, and agents, I certify that I have received and read the Maricopa Integrated Health System Compliance Program Standards, and that the employees and agents of the Contractor providing services to or for MIHS will receive and read these standards. I understand that it is our responsibility to read, understand and seek guidance, should we require clarification, with regard to these standards, and to act in accordance with these standards at all times in performing services for MIHS .

Print Name of Contractor:

Signature of Contractor:

By:

Title:

Date:




Phoenix, AZ 85008 3/14/20087/11/2008 Page 24

Maricopa County



March 26, 2014

Item 2.c.iv.

Governance

Maricopa Integrated Health System

CODE OF CONDUCT AND ETHICS

March 2014 December, 2012

March 2014 December, 2012

Dear Member of the Maricopa Integrated Health System Team: Personal and corporate integrity has been one of the Maricopa County Special Health Care District d/b/a Maricopa Integrated Health System’s (MIHS) guiding principles since the day our health system hospital was founded. It affects everything we do and is a central part of our daily lives.

What makes MIHS exceptional is that our roots go deep into the community. Community is an essential part of our mission. MIHS was founded on the ethical imperative to care for the less fortunate among those we serve. This commitment to sound values and best business practices has guided us through many difficult times.

All of us need to be comfortable talking about integrity openly and in detail. This updated Code of Conduct and Ethics (Code) is the cornerstone of our Corporate Integrity Program as well as the basis for that conversation. As you read through our Code, we are sure much of it will impress you as common sense. We believe that what is written here shouldis already second nature to you. However, as we grow and expand our operations in an increasingly regulated environment, it is more important than ever that we have a single definition of corporate integrity and a common understanding of what is expected we expect of every member of the MIHS team.

What makes MIHS exceptional is that our roots go deep into the community. Community is an essential part of our mission. MIHS was founded on the ethical imperative to care for the less fortunate among those we serveMaricopa C ount y’s residents. This commitment to sound values and best business practices has guided us through many difficult times.

Consider the ethical ideals on the following pages. Renew your personal commitment to the shared values that unite us as an organization and guide our decisions and actions.

Thank you for your continuing efforts.

Sincerely,

Steve Purves, Betsey Bayless, President and Chief Executive Officer

William Vanaskie Chief Operating Officer

Wilma Acosta, John J. Middleton Interim, Vice President and Chief Compliance/Privacy Officer

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Code of Conduct and Ethics Revised and Effective March 2014December, 2012

I. PURPOSE This Code of Conduct and Ethics (Code) has been adopted by the Maricopa County Special Health Care District d/b/a Maricopa Integrated Health System (MIHS) to provide standards by which the MIHS Board of Directors, employees, officers, medical staff and agents will conduct themselves to protect and promote organization-wide integrity and to enhance MIHS’ ability to achieve its organizational mission. The Code is intended to serve as a guide to assist MIHS’ Board of Directors, employees, officers, medical staff and agents to make sound decisions in carrying out their day to day responsibilities.

II. RESPONSIBILITIES UNDER THE CODE OF CONDUCT and ETHICS

Who must comply with MIHS’ Code of Conduct and Ethics?

This The Code applies to all members of the Board of Directors, employees, officers, medical staff, and agents of MIHS and or affiliated with MIHS’ Busi ness P art ners throughout M IHS’ diverse operations and any other facilities or services which shall become a part of MIHS (Affiliates).. MIHS recognizes the different missions and services that each Business Partner Affiliate provides and that the Code is designed to allow flexibility for each Affiliate in developing policies and procedures to achieve the standards and goals set forth in the Code while maintaining each Business PartnerAffiliate’s unique mission and services.

What are your the responsibilities as an of each MIHS employee with regard to the Code of Conduct and Ethics?

Foster and support an atmosphere of compliance by:

• Reading the Sstandards of Conduct and Ethics contained in the Code and think

about their application to your work. You should have a basic understanding of issues covered by each Sstandard and the supplemental compliance policies that apply to your job function.

• Seeking assistance from your supervisor(s), the Administration, the Chief Compliance Officer, the District Counsel or other MIHS resources when you have questions about the application of the standards and other MIHS policies to your work.

• Understanding the numerous options that MIHS makes available to you for

raising conduct or ethical concerns and promptly raise such concerns. You should raise such concerns with your immediate supervisor or MIHS’ Chief Compliance Officer or its District Counsel. If you prefer to raise your concerns anonymously, the MIHS Compliance Hotline Line 1-866-333-MIHS is another resource upon which you can rely. You can also submit a concern anonymously by logging onto the CopaNnet and click the tab titled “Rreport a Ccompliance Cconcern.”

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• Cooperating in MIHS’ investigations concerning potential violations of law, g o v e r n m e n t p a y o r r e g u l a t i o n s a n d r u l e s , the Code, the MIHS Compliance Program and MIHS’ policies and procedures.

• Completing all required compliance training.

What are your the responsibilities as of MIHS’ officers, managers and other supervisors?

Build and maintain a culture of compliance by:

• Leading by example, using your own behavior as a model for all employees.

• Knowing, understanding and following the statutes, rules and regulations that

govern your area(s) of responsibility.

• Encouraging employees to raise conduct and ethical questions and concerns.

• Using employee actions and judgments in promoting and complying with MIHS’ Code and other policies as considerations when evaluating and rewarding employees.

• Providing the Office of Compliance with the resources it needs to be successful.

• Ensuring that all employees, volunteers and contractors subordinates complete all required compliance training.

• Completing all required compliance training.

• Maintaining t h e c o n f i d e n t i a l i t y o f information p r o v i d e d to y o u

r e l a t i n g t o compliance and privacyactivities.

Prevent compliance problems by:

• Identifying potential compliance risks and proposing appropriate policies, and

procedures and actions to address such risks.

• Identifying employees whose activities involve issues covered by MIHS’ policies and procedures.

• Providing education and counseling to assist employees to understand the Code, MIHS policies and procedures and applicable law, and government payor regulations and rules.

Detect compliance problems by:

• Implementing and maintaining appropriate controls to monitor compliance and

mechanisms that foster the effective reporting of potential compliance issues.

• Promoting an environment that permits employees to raise concerns without fear 4

of retaliation. • Arranging periodic compliance reviews that are conducted with the assistance of

the MIHS’ Chief Compliance Officer to assess the effectiveness of MIHS’ compliance measures and to identify methods of improving them.

Respond to compliance problems by:

• Pursuing prompt corrective action to address weaknesses in compliance

mattersmeasures.

• Applying appropriate disciplinary action when necessary.

• Consulting with MIHS’ Chief Compliance Officer so that compliance issues are promptly and effectively addressed.

What are your the responsibilities as of MIHS’ Board of Directors?

Build and maintain a culture of compliance by:

• Reading the Standards of Conduct and Ethics contained in the Code, thinking

about them and thinking about their application to your work.

• Leading by example, using your own behavior as a model for others.

• Making decisions that are in the best interest of MIHS and that are not affected by

conflicts of interest.

• Being knowledgeable about the MIHS Compliance Program and exercise governance and oversight over it.

• Requiring Receiving appropriate reports from management concerning the status of the MIHS Compliance Program, the resources required to maintain its vitality and MIHS’ response to identified compliance deficiencies.

• Receiving and acting o n c o m p l i a n c e m a t t e r s , upon advice from

management, including MIHS’ Chief Executive Officer, District Counsel, and Chief Compliance Officer.

• Assuring that the Compliance Program is free from undue restraints and

influences through direct reporting by the Chief Compliance Officer to the Board of Directors r e g a r d i n g of compliance matters that promote the integrity of the Compliance Program and raising any concerns with the Chief Compliance Officer or the District Counsel.

• Maintaining the confidentiality of all compliance-related information provided to

them, subject to the requirements of applicable law.

• Complete required compliance training.

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What are your the responsibilities as of a member of the medical staff?

Assist MIHS to foster an atmosphere of compliance by:

• Reading the Standards of Conduct and Ethics contained in the Code and think

about their application to your work. You should have an basic understanding of issues covered by each Sstandard and the supplemental compliance policies that apply to the services you furnish to MIHS and our patients.

• Actively participating in compliance activities as requested by MIHS’

administration.

• Maintaining the confidentiality of information provided to you relating to compliance mattersactivities.

• Assisting MIHS in identifying possible compliance issues and in developing possible solutions to address those issues.

• Understanding the various options that MIHS makes available for raising conduct

or ethical concerns and promptly raise such concerns. You should raise such concerns with MIHS’ Chief Compliance Officer or District Counsel. If you prefer to raise your concerns anonymously, the MIHS Compliance Hotline 1-866- 333-MIHS is another resource upon which you can rely.

• Cooperating in MIHS investigations concerning potential violations of law,

MIHS’ Code of Conduct and Ethics, the MIHS Compliance Program and MIHS’ policies and procedures.

• Completing required compliance training.

What are your the responsibilities as of agents?

Agents are responsible to participate in the MIHS compliance program by:

• Reading the Standards of Conduct and Ethics contained in the Code and think

about their application to the services you furnish to MIHS. You should have an basic understanding of issues covered by each standard and the supplemental compliance policies that apply to the services you furnish to MIHS.

• Actively participating in compliance activities, such as education and training, as

requested by MIHS.

• Understanding the various options that MIHS makes available for raising conduct or ethical concerns and promptly raise such concerns. You should raise such concerns with MIHS’ Compliance Officer or D i s t r i c t General Counsel. If you prefer to raise your concerns anonymously, the MIHS Compliance Hotline 1- 866-333- MIHS is another resource upon which you can rely.

• Cooperating in MIHS investigations concerning potential violations of law, the MIHS Code of Conduct and Ethics, the MIHS Compliance Program and MIHS

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policies and procedures.

• Completing required compliance training. How May the Code of Conduct and Ethics Be Revised?

This Code may be amended, modified or waived only after a review by the Chief Executive Officer and the approval of the Board of Directors.

How Frequently will the Compliance Program Be Reviewed?

The Compliance Program (including the Code of Conduct and Ethics) will be reviewed annually by the Compliance Committee to foster its effectiveness and at such times when changes to it are necessitated by changes in laws and regulations applicable to MIHS. Suggested changes to the Compliance Program will be presented to the Board of Directors for approval.

III. STANDARDS OF CONDUCT AND ETHICS

1. Patient Relationships: We are committed to providing a high quality of

healthcare and services to our patients, their families, visitors and the community. We treat all patients with respect and dignity and provide care that is necessary and appropriate.

Principles:

* We will recognize the right of our patients to receive hi gh quali t y and appropriate services provided by competent individuals in an efficient, cost effective and safe manner.

* We will continually monitor the clinical quality of the services we provide

and will endeavor to improve the quality of the services provided.

* We will support every patient’s right to be free from all types of abuse, and will not tolerate patient abuse in any form.

* We will apply our admission, treatment, transfer and discharge policies

equally to all patients based upon identified patient needs and regardless of a patient’s ability to pay.

* We will listen to our patients, families and visitors to understand any

concerns or complaints and will involve patients in the decision-making process about their care.

* We will demonstrate our commitment to patient safety by continuously

reviewing systems, processes and policies to detect and prevent medical errors.

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* We will provide treatment and medical services without discrimination based on race, age, religion, national origin, sex, sexual orientation or disability.

* We will remain sensitive to our position as a regional leader in tertiary and

specialty care and research, and to our consequent obligation as a health care leader to all segments of our community.

- We will implement policies and procedures to complete emergency

assessments as required for all who request our emergency, trauma, or burn services.

- We will fully and fairly evaluate requests to transfer patients to our care from our colleagues and providers in outlying areas, and will accept such transfers as clinically appropriate.

* We will maintain licensure and credentialing standards to further the

provision of clinical services by properly trained and experienced practitioners.

* We will perform background checks of potential employees, medical staff

members, contractors and consultants to verify credentials and to assess whether such individuals and entities have ever been excluded from participation in any of the federal or state health care programs, including the Medicare, and Medicaid, and AHCCCS programs.

* We will respect the privacy of our patients, and we will treat all patient information with confidentiality, in accordance with all applicable laws, regulations and professional standards.

2. General Legal and Regulatory Compliance: MIHS will continuously and

vigorously promote full compliance with applicable laws.

Principles

* We will continuously study our legal obligations and create policies and procedures that facilitate compliance by our Board of Directors, employees, officers, medical staff and agents with such legal obligations.

* We will recognize the critical role of research in improving the health

status of our community, and we are committed to conducting all research activities in compliance with the highest ethical, moral, and legal standards.

* We will engage in open and fair competition and marketing practices,

based on the needs of our community and consistent with the furtherance of our mission.

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* We will treat our employees with respect, and will engage in human relations practices that promote the personal and professional

advancement of each employee.

*

We will recognize that our employees work in a variety of situations and with a variety of materials, some of which may pose a risk of injury. We are committed to providing a safe work environment, and will implement and monitor policies and procedures for workplace safety that are designed to comply with federal and state safety laws, regulations, and workplace safety directives.

*

We will recognize that the provision of health care may in some instances produce hazardous waste products or other risks involving environmental impact. We are committed to compliance with applicable environmental laws and regulations, and will follow proper procedures with respect to handling and disposing of hazardous and bio-hazardous waste.

*

We will expect our Board of Directors, employees, officers, medical staff and agents to understand the basic legal obligations that pertain to their individual job functions or services they furnish to MIHS and our patients, and will require that they strive to make certain that their decisions and actions are conducted in conformity with such laws, regulations, policies and procedures.

*

We will support educational and other training sessions to teach MIHS’ Board of Directors, employees, officers, and as warranted medical staff and agents, about the impact of the law on their duties and to promote compliance with our collective legal obligations.

*

We will support and maintain multiple resources for MIHS’ Board of Directors, employees, officers, medical staff and agents to voice any questions about the proper interpretation of a particular law, regulation, policy or procedure.

3.

Avoidance of Conflicts of Interest: MIHS’ Board of Directors, employees, officers, medical staff, and agents maintain a duty of loyalty to MIHS and to all of the citizens of Maricopa County and, as a result, must avoid any activities that may involve (or may appear to involve) a conflict of interest or that may influence or appear to influence the ability of the Board of Director’s member, employee, officer, medical staff member or agent to render objective decisions in the course of their his or her job responsibilities, or other services they he or she furnishes to MIHS.

Principles.

* We will maintain policies and procedures that make clear when an individual’s private interests may inappropriately interfere with MIHS’ interests; and will provide support through which MIHS’ Board of

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Directors, employees, officers, medical staff and agents may pose questions about whether a particular outside activity or relationship could be construed as a conflict of interest or otherwise improper.

* We will articulate expectations of the conduct that must be demonstrated

by MIHS’ Board of Directors, employees, officers, medical staff and agents in the performance of services for MIHS, and will require that such individuals remain free of conflicts of interest in the performance of their responsibilities and services to MIHS.

* The MIHS Conflicts of Interest and Gift Policy, Policy Number 01291 S,

establishes the policy and procedure for MIHS’, employees, officers, medical staff and agents to evaluate, analyze, and properly remediate potential and apparent conflicts of interest.

* We will require MIHS’ Board of Directors, employees, officers, medical

staff and agents to inform MIHS of personal business ventures and other arrangements scenarios that could be perceived as conflicts of interest and will provide for policies and procedures for doing so.

* We will ll not permit MIHS’ Board of Directors, employees, officers,

medical staff or agents to use any proprietary or non-public information acquired as a result of a relationship with MIHS for person gain or for the benefit of another business opportunity.

* We will render decisions about the purchase of outside services and goods

based on the supplier’s ability to best satisfy MIHS’ needs and not based on personal relationships.

* MIHS Board of Directors, officers and employees shall not use

their official position for personal gain. Public influence and confidential or “inside” information must never be used for personal advantage. Conflict of interest laws, A.R.S. § 38-501 et. seq. must be scrupulously observed. The conflict of interest laws prohibit participation by public officers, elected officials, or employees in a decision or contract in which they public officer or employee has have a direct or indirect pecuniary or proprietary interest.

4. Relationship with Payers: MIHS will consistently strive to satisfy the conditions

of payment required by the payers with which MIHS transacts business.

* We will promote compliance with laws governing the submission and review of bills for our services and will deal with billing inquiries in an honest and forthright manner.

* We will implement reasonable measures to prevent the submission or

filing of inaccurate, false or fraudulent claims to payers.

* We will utilize systematic methods for analyzing the payments we receive

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and will reconcile inaccurate payments in a timely manner after discovery and review.

* When warranted, we will investigate p o t e n t i a l o r r e p o r t e d inaccurate

billings and payments to determine whether changes to current protocol or other remedial steps are necessary.

* We will implement documentation systems sufficient to create and

maintain complete and accurate documentation of services provided.

* We will review cost reports to be filed with the federal and state health care programs to determine whether such reports accurately and completely reflect the operations and services provided to beneficiaries and to confirm that such reports are completed in accordance with applicable federal and state regulations and MIHS’ policies and procedures.

* We will, as necessary, rely on internal and external sources to help

improve MIHS’ billing and coding protocol and to identify potential areas of noncompliance.

* We will compensate billing and coding staff and consultants for services

rendered, in a manner that is permitted under law and will not compensate such persons in any way related to collections or maximization of revenues.

5. Relationship with Physicians and Other Providers: MIHS will monitor its

business dealings to structure relationships in ways that satisfy the needs of the community.

* We will maintain relationships with physicians and other referral sources

based onl y on the needs of our community and consistent with the furtherance of our mission.

* We will treat referral sources fairly and consistently, and will not provide remuneration that could be considered payment for referrals, including:

• free or below-market rents;

• administrative or staff services at no- or below-cost;

• grants in excess of amounts for bona fide research or other services

rendered;

• interest-free loans; or

• gifts, “perks” or other payments intended to induce referrals.

*We will implement policies, procedures and other protocol which require fair market value determinations for services rendered by referral sources and for services rendered by MIHS.

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* * We will implement procedures to require all agreements with referral

sources to be reduced to writing and reviewed and approved as appropriate under law and MIHS’ policies and procedures.

* We will train the appropriate personnel on the primary laws and

regulations governing the referral of patients and other legal restrictions on the manner in which MIHS transacts business, including the penalties that may result for violations of such laws.

6. Respect for Our Culture: We recognize that a diverse workforce enriches the life experience of all employees and our community, and will promote diversity consistent with the MIHS Diversity Plan.

* We will provide equal employment opportunities to employees and

applicants for employment without regard to race, color, religion, sex, national origin, marital status, political belief, age (over 40), veteran status, or disability, in accordance with applicable law.

* We will implement policies and procedures that promote compliance with

laws governing nondiscrimination in personnel actions, including recruiting, hiring, training, evaluation, transfer, workforce reduction, termination, compensation, counseling, discipline, and promotion of employees.

* We will promote diversity with respect to individuals with disabilities, and

will make reasonable accommodations to any individual as required by law.

* We will recognize the right of our employees to a workplace free of

violence and harassment, and will not tolerate any form of harassment or violence toward our employees.

* We will implement policies and procedures that promote appropriate

conduct in the workplace and prohibit unwanted or hostile interaction, including degrading or humiliating jokes, physical or verbal intimidation, slurs, or other harassing conduct.

* We will not tolerate any form of sexual harassment, either overt, such as request for sexual favors in return for promotions, or less obvious forms of harassment, such as sexual comments.

*We will maintain policies and procedures prohibiting workplace violence,

including robbery, stalking, assault, terrorism, hate crimes, or violence directed at supervisors.

* We will maintain policies, and procedures, and practices prohibiting intimidation and retaliation in any form for reporting.

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7. Information and Information Systems: We recognize that the provision of health care services generates business, financial, and patient-related information that requires special protection. We will establish systems that ensure such information is used appropriately and safeguarded zealously.

* We are committed to the security and integrit y accuracy of documents and records in our possession, and will develop systems, policies and procedures sufficient to safeguard the s e c u r i t y a n d integrity of our documents and records, including systems, policies and procedures to:

- Establish retention periods and protocols for business, financial,

and patient records in the MIHS system.

- Prevent the altering, removal, or d e s t r u c t i o n o f r e c o r d s o r documents except according to our records retention policy and applicable ethical and legal standards.

- Promote the accurate, thorough, detailed, and complete

documentation of all business, financial, and patient transactions.

- Control and monitor access to MIHS’ communications systems, electronic mail, internet access, and voicemail to ensure that such systems are accessed appropriately and used in accordance with MIHS’ policies and procedures.

- Protect the privacy and security of patient medical, billing, and

claims information by implementing sufficient physical, systemic, and administrative measures to prevent unauthorized access to or use of patient information, and to track disclosures of such information as required by law.

- Provide access to medical, billing, and claims information for our

patients and their legal representatives as required by law.

- Safeguard the personal and human resources information of our employees, including salary, benefits, medical, and other information retained within the human resources system as required by law.

1.8. Applicable laws, regulations and other program requirements.

We realize that changes may occur to laws, regulations and other program requirements. Should changes occur, MIHS will update this Code to incorporate changes. This includes changes to the following laws:

*Title XVIII of the Social Security Act *Medicare Regulations Governing Parts C and D found at 42 CFR § § 422 and

423 respectively

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*Patient Protection and Affordable Care Act (Pub. L. No 111-148, 124 Stat. 119) *Health Insurance Portability and Accountability Act (HIPAA) (public Law 104-

191) * False Claims Acts (31 USC § § 3729-3733) *Federal Criminal False Claims Statutes (18 USC § § 287.1001) *Anti-Kickback Statute (42 USC § 1320a-7b(b)) *The Beneficiary Inducement Statute (42 USC § 1320a-7a(a)(5)) *Civil Monetary Penalties of the Social Security Act (42 USC § 1395w-27(g)) *Physician Self-Referral (Stark) Statute (42 USC § 1395nn) *Fraud and Abuse, Privacy and Security Provisions of the Health Insurance

Portability and Accountability Act, as modified by HITECH Act *Prohibitions against employing or contracting with persons or entities that have

been excluded from doing business with the Federal Government (42 USC § 1395w-27(g)(1))(G)

*Fraud Enforcement and Recovery Act of 2009 *All sub-regulatory guidance produced by CMS and HHS such as manuals,

training materials, HPMS memos and guides 9.

8. IV. VIOLATIONS OF THE CODE OF CONDUCT AND

ETHICS

MIHS is committed to providing all Board of Directors’ members, employees, officers, medical staff and agents with a means of raising questions and concerns, and reporting any conduct that the Board member, employee, officer, trustee, medical staff member or agent suspects is in violation of this Code. Board members, employees, officers, medical staff and agents are expected and required to communicate any suspected, det ect ed or report ed violations of the Code to a direct supervisor, the Chief Compliance Officer or the District Counsel, as applicable. If you prefer, you can anonymously call the MIHS Compliance Hotline which is available 24 hours a day, 7 days a week: 1-866-333- MIHS or you can also submit a complaint anonymously via the CopaNnet by clicking the tab titled “Rreport a Ccompliance Cconcern.” The Chief Compliance Officer will maintain primary responsibility for investigating reports received on this hotline.

The following list, while not exhaustive, describes the type of concerns and questions that you should raise with your supervisor, the Chief Compliance Officer, the District Counsel or through the MIHS Compliance Hotline:

(i) the possible submission of false, inaccurate, or questionable claims to

Medicare, Medicaid, AHCCCS, or any other payer;

(ii) the provision or acceptance of payments, discounts or gifts in exchange for referrals of patients;

(iii) the utilization of improper physician recruitment techniques under

applicable law;

(iv) allegations of discrimination;

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(v) potential breaches of confidentiality or privacy;

(vi) situations that could raise conflicts of interest concerns; and

(vii) harassment; and

(vii)(viii) retaliation.

15

Personal Commitment and Certification I acknowledge and certify that I have received and read the M a r i c o p a C o u nt y S p e c i a l H e a l t h C a r e D i s t r i c t ’ s Maricopa Integrated Health System Code of Conduct and Ethics and I understand my obligations to comply with the Code.

I agree to comply with the M a r i c o p a C o u n t y S p e c i a l H e a l t h C a r e D i s t r i c t ’ s Maricopa County Integrated Health System Code of Conduct and Ethics.

Board of Directors: I understand that compliance with this Code is essential to my service on the Board of Directors of the Maricopa County Special Health Care District.

Initials:

Employees and Officers: I understand that compliance with this Code is a condition of my continued employment. I further understand that violation of the Code of Conduct and Ethics may result in corrective disciplinary action up to and including termination.

Initials:

Medical Staff: I understand that compliance with this Code is a condition to my ability to practice my profession at MIHS. I further understand that violation of the Code of Conduct and Ethics may result in disciplinary action as provided in the Bylaws of the Medical Staff.

Initials:

Agents: I understand that compliance with this Code is a condition of my continued ability to furnish services to MIHS. I further understand that violation of the Code of Conduct and Ethics may result in a termination by MIHS of any relationship I have with MIHS.

Initials:

Please sign here: Date:

Please print your name: Dept.

16

Maricopa County



March 26, 2014

Item 2.d.i.

Medical Staff

Recommended by Credentials Committee: March 4, 2014 Recommended by Medical Executive Committee: March 11, 2014 Submitted to MSHCDB: March 26, 2014

1 of 3

MARICOPA INTEGRATED HEALTH SYSTEM CREDENTIALS AND ACTION ITEMS REPORT

MEDICAL STAFF

The credentials of the following individuals including, current licensure, relevant training and experience, malpractice insurance, current competence and the ability to perform the requested privileges have been verified.

INITIAL MEDICAL STAFF APPOINTMENT NAME CATEGORY DEPARTMENT/SPECIALTY APPOINTMENT DATES COMMENTS

Emily Signe Mika, M.D. Courtesy Family and Community Medicine and Emergency Medicine (Urgent Care)

04/01/2014 to 03/31/2016 Interim Privileges granted as of 3/11/2014

James L. Reingold, M.D. Courtesy Pediatrics (Emergency Medicine) 04/01/2014 to 03/31/2016 Interim Privileges granted as of 3/01/2014 Ronald J. Smith, M.D. Active Surgery (Ophthalmology) 04/01/2014 to 03/31/2016 Interim Privileges granted as of 2/20/2014 Soheil Taghavi Zargar, M.D. Active Emergency Medicine (Urgent Care) 04/01/2014 to 03/31/2016 Interim Privileges granted as of 2/25/2014 Alexander Toledo, D.O. Active Pediatrics (Emergency Medicine) 04/01/2014 to 03/31/2016 Nachman Ullman, D.O. Courtesy Pediatrics (Emergency Medicine) 04/01/2014 to 03/31/2016 Interim Privileges granted as of 3/01/2014

INITIAL/FOCUSED PROFESSIONAL PRACTICE EVALUATION NAME DEPARTMENT/SPECIALTY RECOMMENDATION

EXTEND or PROPOSED STATUS COMMENTS*

Laura M. Barth, M.D. Emergency Medicine FPPE Successfully Completed Chair has submitted documentation demonstrating practitioner has successfully completed FPPE requirement for Emergency Medicine Core Cognitive/Procedural Privileges.

Adrian Timothy Harvey, D.O. Surgery (Neurosurgery) FPPE Successfully Completee Chair has submitted documentation demonstrating practitioner has successfully completed FPPE requirement for Neurosurgery Core Privileges.

Adam L. Prawzinsky, M.D. Surgery (Otolaryngology) FPPE Successfully Completed Chair has submitted documentation demonstrating practitioner has successfully completed FPPE requirement for Endoscopy Privileges.

Aaron B. Skolnik, M.D. Emergency Medicine FPPE Successfully Completed Chair has submitted documentation demonstrating practitioner has successfully completed FPPE requirement for Emergency Medicine Core Cognitive/Procedural Privileges.

Mariel Stroschein, M.D. Surgery (Otolaryngology) Maintain Ongoing Monitoring/Partial Completion

Chair has submitted documentation demonstrating practitioner has successfully completed two out of the five required Concurrently Reviewed Esophageal/Esophagoscopy Procedures.

REAPPOINTMENTS NAME CATEGORY DEPARTMENT/SPECIALTY APPOINTMENT DATES COMMENTS

Thomas Ardiles, M.D. Active Internal Medicine (Critical Care/Pulmonology) 04/01/2014 to 03/31/2016 R. Michael Brady, M.D. Courtesy Obstetrics and Gynecology 04/01/2014 to 03/31/2016 Robert E. Fromm, Jr., M.D. Active Internal Medicine (Critical Care) 04/01/2014 to 03/31/2016 Neil K. Goldstein, M.D. Courtesy Radiology 04/01/2014 to 03/31/2016


2 of 3

REAPPOINTMENTS Leslie A. Kanda, M.D. Courtesy Surgery (Ophthalmology) 04/01/2014 to 03/31/2016 Kim T. Long, M.D. Active Pediatrics 04/01/2014 to 03/31/2016 Zia Mansoor, M.D. Courtesy Anesthesiology 04/01/2014 to 03/31/2016 Guneet K. Mumick, M.D. Courtesy Internal Medicine (Nephrology) 04/01/2014 to 03/31/2016 Andrew L. Papez, M.D. Courtesy Pediatrics (Cardiology) 04/01/2014 to 03/31/2016 Norma L. Perales, M.D. Courtesy Family and Community Medicine 04/01/2014 to 03/31/2016 John C. Porter, M.D. Active Surgery (Physical Medicine & Rehabilitation) 04/01/2014 to 03/31/2016 Anthony A. Smith, M.D. Courtesy Surgery (Plastics/Hand) 04/01/2014 to 03/31/2016 Joseph S. Stapczynski, M.D. Active Emergency Medicine 04/01/2014 to 03/31/2016

CHANGE IN PRIVILEGES

NAME DEPARTMENT/SPECIALTY ADDITION / REVISION/ REDUCTION / WITHDRAWAL

COMMENTS

Thomas Ardiles, M.D. Internal Medicine (Pulmonology) Addition: Endobronchial/Intra-Thoracic Ultrasound (EBUS-TBNA) Concurrent Review/Direct Supervision of first two cases

David L. August, M.D. Radiology Addition: Cardiac CT Angiography Unsupervised Ahmad Nazih Chebbo, M.D. Internal Medicine (Pulmonology) Addition: Endobronchial/Intra-Thoracic Ultrasound (EBUS-TBNA) Unsupervised Pedro F. Quiroga, M.D. Internal Medicine (Critical Care and

Pulmonology) Addition: Dialysis: Continuous Renal Replacement Therapy (CRRT) Addition: Endobronchial/Intra-Thoracic Ultrasound (EBUS-TBNA)

Unsupervised Unsupervised

Mehrdad Saririan, M.D. Internal Medicine (Cardiology) Addition: Cardiac CT Angiography Unsupervised

STAFF STATUS CHANGE NAME DEPARTMENT CHANGE FROM/TO COMMENTS*

Bertram D. Hurowitz, M.D. Internal Medicine (Rheumatology) Courtesy to Emeritus Retired Timothy T. Kuberski, M.D. Internal Medicine Active to Courtesy Reduction in hours

CHANGE IN STATUS Information Only

NAME DEPARTMENT STATUS REASON John A. Sarko, M.D. Emergency Medicine Active to Medical Leave of Absence Medical Leave of Absence (effective 03/01/2014 through

08/31/2014)

RESIGNATIONS Information Only

NAME DEPARTMENT/SPECIALTY STATUS REASON Patricia A. Eckholdt, M.D. Emergency Medicine Courtesy to Inactive Resigned (Effective 2/18/2014) Amy Michelle Guzek, M.D. Pediatrics Courtesy to Inactive No longer contracted with contracting agency


3 of 3

RESIGNATIONS Information Only

Stephanie Hsieh, M.D. Pediatrics (Nephrology) Courtesy to Inactive Resigned (Effective 2/1/2014) Richard I. Peterson, M.D. Obstetrics & Gynecology Active to Inactive Resigned Charles Alan Richardson, M.D. Family & Community Medicine Courtesy to Inactive No longer contracted with contracting agency

CORRECTION TO THE FEBRUARY 26, 2014 MARICOPA SPECIAL HEALTH CARE DISTRICT BOARD MEETING NAME SPECIALTY/PRIVILEGES CATEGORY COMMENTS

Risa Michelle Cohen, M.D. Internal Medicine (Cardiology) Active Physician inadvertently was listed as resigned/inactive status and should remain on the medical staff.

C. Dale Collins, M.D. OB/GYN and Women’s Health Courtesy Physician inadvertently was listed as “Active” staff and should be listed as “Courtesy” staff.

Jeffrey Packer, D.O. Internal Medicine (Nephrology) Courtesy to Inactive Physician Bruce P. Packer, M.D. was inadvertently listed as a resignation. Jeffrey Packer, D.O. is the correct name that should be listed for the resignation.

Definitions: Active > 1,000 hours/year – Active members of the medical staff have voting rights and can serve on medical staff committees Courtesy < 1,000 hours/year – Courtesy members do not have voting rights and do not serve on medical staff committees Reappointments Renewal of appointment and privileges is for a period of two years unless otherwise specified for a shorter period of time. FPPE Focused professional practice evaluation is a process by which the organization validates current clinical competence. This process may also be used when a question arises in practice patterns.

Maricopa County



March 26, 2014

Item 2.d.ii.

Medical Staff


1 of 1

MARICOPA INTEGRATED HEALTH SYSTEM CREDENTIALS AND ACTION ITEMS REPORT

ALLIED HEALTH PROFESSIONAL STAFF The credentials of the following individuals including, current licensure, relevant training and experience, malpractice insurance, current competence and the ability to perform the requested privileges have been verified.

ALLIED HEALTH PROFESSIONALS - INITIAL APPOINTMENTS

NAME DEPARTMENT PRACTICE PRIVILEGES/ SCOPE OF SERVICE

APPOINTMENT DATES

COMMENTS/SPONSORING PHYSICIAN (if applicable)

Maria Emilaine Varon De Castro, F.N.P. Family and Community Medicine Practice Prerogatives on file 04/01/2014 to 03/31/2016 Interim Privileges granted as of 2/24/2014 Larissa Christine Franchuk, P.A.-C Internal Medicine (Dermatology) Practice Prerogatives on file 04/01/2014 to 03/31/2016 Interim Privileges granted as of 3/03/2014 Freddy L. Montenegro, F.N.P. Family and Community Medicine Practice Prerogatives on file 04/01/2014 to 03/31/2016 Interim Privileges granted as of 3/06/2014

INITIAL/FOCUSED PROFESSIONAL PRACTICE EVALUATION NAME DEPARTMENT RECOMMENDATION

EXTEND or PROPOSED STATUS COMMENTS*

Britni Laine Ferguson, P.A.-C Surgery (Trauma/Burn) FPPE successfully completed Chairman has submitted documentation demonstrating practitioner has successfully completed FPPE requirement for Physician Assistant Core and Trauma/Burn Privileges.

ALLIED HEALTH PROFESSIONALS – REAPPOINTMENTS

NAME DEPARTMENT PRACTICE PRIVILEGES/ SCOPE OF SERVICE

APPOINTMENT DATES

COMMENTS/SPONSORING PHYSICIAN (if applicable)

Marcia E. Bouton, P.A.-C Surgery (Breast/Oncology) Practice Prerogatives on file 04/01/2014 to 03/31/2016 Supervising Physician: Ian K. Komenaka, M.D. Tracey Lee Gillispie, N.N.P. Pediatrics (Neonatal) Practice Prerogatives on file 04/01/2014 to 03/31/2016 LouAnne Jones, F.N.P. Surgery (Burn/Trauma) Practice Prerogatives on file 04/01/2014 to 03/31/2016 Harry W. Schechner, C.C.P. Surgery (Perfusionist) Practice Prerogatives on file 04/01/2014 to 03/31/2016 James Gene Soler, C.R.N.A. Anesthesiology Practice Prerogatives on file 04/01/2014 to 03/31/2016 Lizabeth A. Starkey, P.A.-C Surgery (Urology) Practice Prerogatives on file 04/01/2014 to 03/31/2016 Supervising Physician: Jose Q. de Guzman, M.D.

CHANGE IN PRIVILEGES

NAME DEPARTMENT ADDITION / REDUCTION / WITHDRAWAL/CHANGES COMMENTS Shiloh J. Danley, F.N.P. Emergency Med (Urgent Care) Addition: Urgent Care Nurse Practitioner Privileges With General Supervision

General Definitions: Allied Health Professional Staff

An Allied Health Professional (AHP) means a health care practitioner other than a Medical Staff member who is authorized by the Governing Body to provide patient care services at a MIHS facility, and who is permitted to initiate, modify, or terminate therapy according to their scope of practice or other applicable law or regulation. Governing Body authorized AHPs are: Certified Registered Nurse Anesthetists; Certified Registered Nurse Midwife; Naturopathic Physician; Optometrists; Physician Assistant; Psychologists (Clinical Doctorate Degree Level); Registered Nurse Practitioners.

Practice Prerogatives Scopes of practice summarizing qualifications for the respective category, developed with input from the physician director of the clinical service and the observer/sponsor/responsible party of the AHP, Department Chair, and other representatives of the Medical Staff, Hospital management, and other professionals.

Supervision Definitions: (1) General Supervision The procedure is furnished under the physician’s overall direction and control, but the physician’s presence is not required during the performance of the procedure or provision of the services.(2) Direct Supervision The physician must be present in the office suite or on the premises of the location and immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that

the physician must be present in the room when the procedure is performed. (3) Personal Supervision A physician must be in the room during the performance of the procedure.

Maricopa County



March 26, 2014

Item 2.d.iii.

Medical Staff

Maricopa Integrated Health System PROPOSED RADIOLOGY REVISIONS

Approved 07/98, REV: 12/05, 01/06, 05/06, 03/07, 12/07, 04/08, 10/09, 11/09, 5/11, 06/12, 11/12, 10/13 3/2014 / Sedation Rev: 11/12, 5/13, 11/13 Page 1 of 3

Criteria-Based Core Privileges: GENERAL AND INVASIVE RADIOLOGY

To be eligible to apply for core privileges in radiology, the applicant must meet Maricopa Integrated Health System membership requirements outlined in the Medical Staff Bylaws and the following privileging criteria. Additional non-core special privileges may be requested in this specialty by those practitioners who qualify for core privileges and meet the respective criteria of the non-core privilege requested.

INITIAL APPLICANTS

Education Successful completion of an Accreditation Council for Graduate Medical Education (ACGME) or American Osteopathic Association (AOA) accredited residency in radiology.

Board Certification Current certification or active participation in the examination process [with achievement of certification within five years] leading to certification by the American Board of Radiology or the American Osteopathic Board of Radiology.

Clinical Activity Applicants for initial appointment must be able to demonstrate provision of services, reflective of the scope of privileges requested, during the past 12 months in an accredited hospital or healthcare facility similar in scope and complexity to MIHS or demonstrate successful completion of an ACGME or AOA accredited residency, clinical fellowship within the past 12 months.

FOCUSED PROFESSIONAL PRACTICE EVALUATION

Guidelines for Initial Appointment

Retrospective review of 10 cases reflective of the scope of privileges requested, with satisfactory performance and to be completed in accordance with the MIHS Focused Professional Practice Evaluation to Confirm Practitioner Competence Policy. NOTE: See additional requirements for Mammography and MRI privileges.

REAPPOINTMENT Performance or supervision of 2,500 procedures reflective of the scope of privileges requested for the past 24 months as a results of ongoing professional practice evaluation activities and outcomes.

Requested GENERAL RADIOLOGY CORE PRIVILEGES Perform and interpret medical images for outpatients and inpatients within the Maricopa Integrated Health System. The core privileges in this specialty include those procedures listed and such other procedures that are extensions of the same techniques and skills. If you wish to exclude any procedures, please strike through those procedures which you do not wish to request, initial, and date. Image guided drainage from internal body locations; Medical images:

o Diagnostic Radiology o Ultrasound (total body) o Computerized Tomography (Neuro and Total Body)

Perform Minor Invasive privileges: o Needle Breast Localization, o Venography, o Arthrography and Myelography

Radiology Ultrasound (Total Body) Diagnostic Nuclear Medicine including Scans and/or Interpretations (excluding therapeutic nuclear radiology and PET/CT) Computerized Tomography (Neuro and Total Body) Ultrasound guided biopsies



Requested INVASIVE RADIOLOGY CORE PROCEDURES (DIAGNOSTIC AND THERAPEUTIC) Admit patients following invasive radiologic procedures and for treatment of complications or reactions from the diagnostic or therapeutic procedures, perform history and physical examinations, and act as a consultant to others. Core Procedures: Invasive Radiology core privileges include the following: Angiography (including cerebral) Arthrography Percutaneous Needle Biopsy Percutaneous Drainages

1. Angiography (including cerebral), abdominal, extremities to include venography

2. Body or extremity angioplasty or atherectomy 3. Central venous and dialysis access line insertion and

maintenance 4. Cerebral arteriography 5. Coil occlusions of aneurysms 6. Endovenous laser therapy 7. Head, neck and spine arteriography and venography 8. Intra-arterial thrombolytic therapy 9. Intravenous thrombolytic therapy 1.10. Cisternography 2.11. Neuro interventional procedures for pain including

epidural steroid injection, nerve blocks and discography

12. Non vascular interventional procedure, including soft tissue biopsy, abscess and fluid drainage, nephrostomy, biliary procedures, and tumor ablation

3.13. Non-invasive diagnostic vascular radiology to include vascular ultrasonography, pulse volume recordings, CT and MRI

4.14. Percutaneous Needle Biopsy 5.15. Percutaneous Drainages 16. Placement of catheter for tumor treatment 17. Placement of vena cava filter 18. Pulmonary angiography 19. Therapeutic infusion of vasoactive agents 20. Therapeutic vascular radiology including balloon

angiography, stent placement, atherectomy, thrombolic therapy, and embolization/ablation excludes carotid and intracranial intervention (includes transarterial chemoembolization)

21. Transjugular intrahepatic portosystemic shunt (tips)

6.22. Vascular ultrasonography 23. 25. Venography and venous sampling

Initial Appointment Criteria: Requesting physician will be required to submit documentation to support one of the following options: A letter from the Director of the physician’s Residency/Fellowship Program documenting adequate training in the above invasive radiology

procedures, including fifty (50) angiograms performed in the past twenty-four (24) months; OR A certificate documenting completion of a short-term fellowship training program in the above invasive radiology procedures; OR If applicant is more than five (5) years out of residency/fellowship training, documentation of experience during other affiliations that meet

reappointment criteria delineated below; AND provide a letter from Director of Cath Lab or Chief of Radiology from previous affiliation attesting to physician competency and satisfactory performance.

Focus Professional Practice Evaluation: Retrospective review of 4 cases reflective of the scope of privileges requested with satisfactory performance. Reappointment Criteria: Performance of 100 cases reflective of the scope of privileges requested within the past 24 months as a results of ongoing professional practice evaluation activities and outcomes.



NON-CORE SPECIAL PROCEDURE Requested Percutaneous Ultrasound Guided Fasciotomy & Tenotomy Initial Appointment Criteria:

Documentation in performing Ultrasound Guided Injections; AND Completion of an approved residency/fellowship training program that included training in the performance of

Percutaneous Ultrasound Guided Tenotomy & Fasciotomy; OR Documentation of an approved training course that provided training in the performance of Percutaneous Ultrasound

Guided Tenotomy & Fasciotomy that includes at least five (5) procedures performed on a cadaver in the past twenty-four (24) months.

Focus Professional Practice Evaluation: Concurrent proctoring of the first two (2) cases with successful outcomes. Reappointment Criteria: Performance of five (5) Percutaneous Ultrasound Guided Fasciotomy & Tenotomy cases during the past twenty-four (24) months with acceptable results based on results of ongoing professional practice evaluation and outcomes.

Maricopa County



March 26, 2014

Item 2.d.iv.

Medical Staff

Once Printed This Document May No Longer Be Current

Policy # Title: Page 1 of 7 00/00 Supersedes 00/00


Maricopa Integrated Health System Administrative Policy & Procedure Effective Date: 04//2010

Reviewed Dates: 00/00

Revision Dates: 09/2011, 04/2012, 04/13, 03/14

Policy #: 39026 T Policy Title: Clinical Services/Medical Affairs: Operational Credentialing Policy and Procedure Scope: [ ] District Governance (G) [ ] System-Wide (S) [ ] Division (D) [ ] Multi-Division (MD) [ ] Department (T) [ X ] Multi-Department (MT)

Purpose: In accordance with Medical Staff Bylaws and Medical Staff Credentials Policy and Allied Health Professional Credentials PoliciesPolicy, to further define the process for credentialing members of the Medical Staff and Allied Health Professional staff in compliance with NCQA standards, DNV, CMS, and health plan delegation agreements.

Definitions: Allied Health Professional: A health care practitioner other than a Medical Staff member who is authorized to provide patient care services in the Hospital who have been granted clinical privileges. AMA: American Medical Association AOA: American Osteopathic Association CMS: Centers for Medicare and Medicaid Services Delegation Agreement – An agreement between MIHS and a health plan that allows the health plan to accept the credentialing process of MIHS, provided MIHS meets the health plan’s credentialing standards and successfully demonstrates compliance upon audit by the respective health plan. DNV: Det Norske Veritas – A hospital accreditation program approved by the US Centers for Medicare and Medicaid Services (CMS). DNV performs annual deemed status surveys. Medical Staff: All physicians, dentists, oral surgeons and podiatrists who have been appointed to the Medical Staff by the Board. NCQA: National Committee for Quality Assurance Certifacts: An official Display Agent for the American Board of Medical Specialties (ABMS) to serve as one of the providers of primary source equivalent ABMS Participating Practitioners: Medical Staff and Allied Health Professional Staff as defined in the Credentialing Policy.




Policy:

The credentialing process is performed in accordance with the Medical Staff Credentials Policy and Allied Health Professional Staff Credentials Policy and is operationalized as set forth in this policy. A health care plan may delegate its credentialing function for practitioners who provide services at Maricopa Integrated Health System (MIHS). Health care plans, through a contractual agreement, may delegate the credentialing, re-credentialing and monitoring for adverse actions of all participating practitioners. The Delegation Agreement shall detail the delegated activities, responsibilities of the health plan and of MIHS, and the process by which evaluation of the process shall occur.

MIHS performs primary source verification and does not sub-delegate this function. The applications for initial appointment and reappointment existing now and as may be revised are incorporated by reference and made a part of this Policy.

Procedure: SECTION 1 – INITIAL APPOINTMENT PROCEDURES

1.1 Verification of Information The information that shall be collected and verified by representatives of the Medical Staff Services (MSS) Department working with the Credentials Committee shall include, but not be limited to:

1.1.1 Education and training are verified through the AMA/AOA profile or directly with the training program by written letter. The Educational Commission for Foreign Medical Graduates (ECFMG) may be used for verification of a physician’s graduation from a foreign medical school.

1.1.2 All currently unrestricted professional licensures or certifications verified directly with the appropriate state agencies, by a letter, telephone verification, or secure electronic communication obtained from the appropriate state licensing board. Telephone and electronic communication shall be appropriately documented with the date, time, and initials of the individual performing the verification.

1.1.3 A current copy of the Drug Enforcement Administration (DEA) registration when applicable, with the date and number of each shall also be obtained.

1.1.4 Specialty or sub-specialty board certification, recertification, or active candidate status verified by Certifacts, or directly with the Specialty Board.

1.1.5 Continuous professional liability insurance coverage as required in the Credentialing Policy. The applicant must include names of present and past insurance carriers and complete information on malpractice claims history and experience including past and pending claims, final judgments, or settlements. The National Practitioners Data Bank (NPDB) is queried for verification of any professional liability claims.

1.1.6 Any pending or completed action involving the withdrawal of an application for or the denial, revocation, suspension, reduction, limitation, probation, non-renewal, or voluntary relinquishment (by expiration or resignation while under investigation or to avoid investigation) of: license or certificate to practice in any state or country; DEA or other controlled substances registration; specialty or sub-specialty board certification or eligibility; staff membership status, prerogatives, or clinical privileges at any hospital, clinic or health care institution; professional liability insurance coverage. The entities that shall verify this information shall include, but not be limited to: the applicable state agency; health care affiliations; NPDB; and professional peer references.

1.1.7 Health status information provided in response to pertinent questions about practitioner’s physical and mental health status or chemical/substance dependency/abuse that may impair his/her ability to provide professional services.




1.1.8 Charge, indictment, conviction, or a plea of guilty or no contest pertaining to any felony, or to any misdemeanor involving (i) controlled substances; (ii) illegal drugs; (iii) Medicare, Medicaid, or insurance or health care fraud or abuse; or (iv) violence against another shall be elicited on the application.

1.1.9 All hospitals or health care organizations (medical groups, hospitals, corporations and government agencies) where the applicant had or has any association, employment, privileges or practice during the previous ten (10) years, to include start and end dates of each affiliation. Gaps in practice greater than three (3) months All time intervals greater than three (3) months since graduation must be accounted for and gaps in practice shall be verified by an individual who can attest to the validity of the activity as specified by the applicant, or re-applicant.

1.1.10 Medicare sanctions are verified directly with the OIG (Office of the Inspector General) website or the NPDB.

1.1.11 The Medicare Opt-Out Report will be reviewed on at initial appointment. If a practitioner is identified they shall be deemed to not meet the qualifications for appointment as outlined in the credentialing policies.

1.1.12 The NPDB is queried at the time of initial appointment/reappointment and for new privilege requests

SECTION TWO - REAPPOINTMENT PROCEDURES

2.1 All terms, conditions, requirements, and procedures relating to initial appointment shall apply to continued appointment and reappointment. Each staff member shall be sent an application for reappointment and notice of the date on the appointment will expire (not to exceed two years from the last appointment/reappointment) in accordance with Medical Staff Credentials Policy and Allied Health Professional Staff Credentialing PoliciesPolicy.

2.2 The sources used will be the same as in the initial credentialing process

SECTION THREE - NOTIFICATION AND STATUS OF APPLICATION

3.1 During the initial credentialing or recredentialing process, the practitioner will be given notice by the MIHS credentialing staff of any conflicting information and be given an opportunity to reconcile such information. The following process will be followed: 3.1.1 Practitioner shall be notified of the variation via telephone, USPS, fax, or e-mail

on a case-by-case basis to correct erroneous information. The notice shall detail what information needs clarification, where the corrected information shall be submitted.

3.1.2 The information may be submitted by letter, fax, telephone, or email. 3.1.3 The practitioner shall be contacted by phone, fax, or email, once the corrected

information is received. 3.1.4 Upon such notification, it is the applicant's obligation to obtain or correct the

required information. 3.1.5 Any application that continues to be incomplete 30 days after the individual has

been notified of the additional information required shall be deemed to be withdrawn.

3.2 The applicant has the right to inquire into the status of an application by contacting the MSS Department.

3.3 Practitioners are notified in writing within 30 days of final Board action. If the application is denied the reason will be stated in the letter along with the notification for right to appeal as outlined in the Medical Staff and Allied Health Credentialing Policies.




3.4 Practitioners receive a copy of the Medical Staff Bylaws, Medical Staff Credentialings Policy, or Allied Health Professional Credentialing Policy (if applicable) outlining their rights.

3.5 Practitioners have the right to review information submitted to support their credentialing application. All such requests to review information shall be in writing, addressed to the Chief Medical Officer, or Chief of Staff. The access may include review of the materials that have been submitted by the practitioner, malpractice carriers, and state licensing board, and shall explicitly exclude peer references, recommendations, or other peer protected information. The practitioner shall be required to sign a specific confidentiality statement based on the scope of the inquiry, and the review shall be conducted in the presence of the Chief Medical Officer, Chief of Staff, or their designee.

SECTION FOUR - ONGOING VERIFICATION OF INFORMATION

4.1 Medicare/Medicaid Exclusions shall be verified on a monthly basis. Verification shall be accomplished through a sweep of the credentialing database matched against the OIG (Office of Inspector General) website.

4.2 Medicare/Medicaid Opt-Out Report - The Medicare Opt-Out Report will be reviewed on a quarterly basis; if a practitioner is identified the health plan will be notified immediately.

4.3 Licensure - The applicant’s current professional licensure shall also be verified at the time of license renewal and revision of privileges. During the interim period between reappointment cycles, the Credentials Committee shall review disciplinary actions identified, or other issues deemed to be significant. The Credentials Committee shall make recommendations on these matters, when deemed necessary. Any licensure revocation, suspension, restriction, or probation shall result in a like limitation of clinical privileges, as of the date such action becomes effective and throughout its term. Contracted health plans shall be notified immediately of any such actions.

4.4 Patient Complaints, Adverse Events, and Medical Record Review- The collection of and review of information obtained from complaints, adverse events, and medical record review is performed on a concurrent basis. Appropriate interventions are identified from adverse events through the confidential peer review mechanism.

SECTION FIVE - REPORTING TO THE NATIONAL PRACTITIONER DATA BANK (NPDB) AND STATE LICENSING BOARD

5.1 It is the policy of MIHS to comply with the required reporting of adverse actions taken against a Participating Practitioner to all regulatory agencies, including the National Practitioner Data Bank (NPDB) and the appropriate State of Arizona Licensing Board.

5.2 Following a formal peer review process, and at the time that MIHS denies, reduces, revokes, terminates, or suspends the privileges of a practitioner for a period of longer than thirty (30) calendar days, or accepts the Participating Practitioner’s surrender of privileges while under investigation by MIHS, MIHS will notify the NPDB and the appropriate State of Arizona Licensing Board.

5.3 NPDB Reporting:

5.3.1 MIHS will submit a report to the NPDB of the adverse action consistent with the NPDB timeliness requirements.




5.3.2 The NPDB report will be submitted electronically, in accordance with NPDB requirements via the NPDB website at www.npdb-hipdb.hrsa.gov www.npdb-hipdb.com

5.4 State of Arizona Licensing Board Reporting: The Report Verification Document that MIHS received from the NPDB will be submitted to the appropriate State licensing board.

SECTION SIX – PROTECTION AGAINST DISCRIMINATION

6.1 In accordance with the Medical Staff Credentials Policy and Allied Health Professional Credentialing PoliciesPolicy, Practitioners shall not be discriminated against solely on the basis of race, ethnic/national identity, gender, age, sexual orientation or the types of procedures or types of patients in which the practitioner specializes. Means used to prevent discrimination in the decision making process includes: 6.1.1 The Credentials Committee will be comprised of a multi-disciplinary, heterogeneous group

of practitioners to the degree feasible. 6.1.2 All members of the medical staff are required to attest to their willingness to abide

by the Medical Staff Bylaws and associated documents. Discrimination is prohibited in the Medical Staff Credentialings Policy (section 2.A.5) and Allied Health Professional Credentialing Policy (Section 3.A.5).

6.1.3 Adverse recommendations must be supported by qualitative and quantitative data that is presented to the Credentials Committee blindly (i.e., using a numeric identifier in lieu of name, discipline, specialty, etc.).

6.2.4 All denial decisions will be handled in accordance with the Medical Staff Credentials Policy (Article 3.A.6-3.A.7) and Allied Health Professional Policy (Article 4.A.5-4.5.6) and potentials for discrimination shall be assessed through the respective (medical staff or allied health professional staff) Hearing and Appeal Process.

6.2 The Credentials Committee will conduct an annual review of credentialing decisions to ensure that practitioners are not discriminated against.

SECTION SEVEN – GENERAL PROVISIONS

7.1 MIHS shall seek to verify all the data elements as set forth in this policy and the Medical Staff Credentials Policy and Allied Health Professional Staff Credentialing PoliciesPolicy.

7.2 MIHS will verify all information provided on the physician application within 180 days of the Credentials Committee decision. Each applicant is required to sign and attest to the accuracy of the information provided in the application and reapplication. If the signature attestation exceeds 180 calendar days before the credentialing decision, MSS shall update it with an attestation that the information on the application remains correct and complete.

7.3 All members of the Medical Staff and Allied Health Professional Staff acknowledge that they agree to respect and maintain the confidentiality of all discussions, deliberations, proceedings, and activities of Medical Staff Committees and Departments which have the responsibility of evaluating and improving the quality of care in the Hospital. Members of the Credentials Committee and other Peer Review Committees may be required to sign a confidentiality statement.

7.4 Provisionally credentialed (clean file review) and approval is permitted in accordance with the criteria and process set forth in the Medical Staff Credentialings Policy (Section 4.B) and Allied Health Professional Staff Credentialing Policy (Section 4.C).




7.5 The health care plan and MIHS will identify the providers who will participate in this agreement in a written list updated monthly. Any published directories are based on the information provided from the Credentials Office.

7.6 MIHS will conform to the current requirements established by the NCQA. 7.7 For purpose of the “Federal Quality Health Care (FQHC) Look Alike” delegated

credentialing arrangements, a completed application is defined as the fully verified application that has been acted on favorably by the MIHS Credentials Committee.

References: MIHS Medical Staff Bylaws, Medical Staff Credentialings Policy, Allied Health Professional Staff Policy, NCQA Standards CR 1- 12, Health Care Quality Improvement Act of 1986.




MIHS Policy & Procedure - Approval Sheet (Before submitting, fill out COMPLETELY.)

POLICY RESPONSIBLE PARTY:

DEVELOPMENT TEAM(S):

Policy #:

Policy Title:

E-Signers: ___________________________________________________ [Michael D. Peck, M.D, Chief of Staff MIHS]

____________________________________________________

[Dr. Robert E. Fromm, Jr. MD-CMO]

Place an X on the right side of applicable description:

New -

Retire - Reviewed -

Revised with Minor Changes - Minor revisions throughout document. No substantive changes.

Revised with Major Changes -

Please list revisions made below: (Other than grammatical changes or name and date changes)

Reviewed and Approved by in Addition to Responsible Party and E-Signer(s):

Committee: Credentials Committee 03/14

Committee: Medical Executive Committee 03/14

Committee: Maricopa Special Health Care District Board 03/14

Committee: 00/00

Other: 00/00

Other: 00/00

Other: 00/00

Maricopa County



March 26, 2014


Maricopa County Election

Maricopa County



March 26, 2014

Item 4.

Clinically Integrated Network

Clinically Integrated Organization

1

In August of 20131 the Board of Directors approved a strategic plan for the District focusing on 6 key strategies. Included was a network of

academic care sites convenient to where people live and work and that would contribute to the sustainability of the System. The strategic plan

recognized the continuing transition of healthcare from the inpatient to the outpatient arena and underscored the importance of our

ambulatory care network.

The proposed Clinically Integrated Organization is foundational to at least 2 of the key strategies that the Board adopted in their strategic

plan:

Strategy 1: Enhance the patient experience by growing the number of covered lives under MIHS care and management.

1. Organize a physician-led clinically integrated care network that brings physicians, hospitals and others together to redesign care systems and

improve outcomes, better manage cost, and enhance the patient care experience by January 2014.

2. Manage at least a total of 100,000 lives through arrangements with payers and employers by December 2015

3. Increase total system revenue earned from managing lives enrolled in the MIHS health plans and under contract with insurers and employers

by December 2015

Strategy 2: Build and upgrade a network of ambulatory care facilities in key markets outside the Maricopa Medical center primary service

area.

1. … extend the MIHS brand, grow office-based and outpatient volumes, and meet emerging community need by December 2016

2. … meet emerging care needs among AHCCCS patients in an underserved market by July 2016.

To effectuate this plan, MIHS and DMG will work together in the planning, operationalizing, and funding of the integrated organization. Both

entities see a new paradigm in healthcare delivery with a transition from the traditional fee for service model to compensation for value. This

1 MIHS 2013 Strategic Plan August 27, 2013

Clinically Integrated Organization

2

new paradigm will undoubtedly include capitated and bundled payment arrangements as well as gain-sharing models. These models will require

an organization to contract with payors.

MIHS and DMG have identified Navvis as the most appropriate consulting entity to assist with the development of our Clinically Integrated

Organization. The following attributes underscore some of the reasons why Navvis was identified:

1) Long standing relationship with the institution

2) Understanding of MIHS operations and history

3) Familiarity with the current MIHS strategic plan

4) Ongoing relationship with DMG

5) Previous experience with multiple successful CIO implementation

Navvis will be engaged to:

1) Structure and create governing body and appropriate committees to direct the operations of the CIO and nuture a culture that will

facilitate a successful enterprise

2) Help design a compensation structure that aligns physician incentives with the underlying purpose of the CIO

3) Assist with the development of a strategic contracting plan with market payors .

4) Assist with a detailed financial assessment and budgeting process

5) Help develop the care model and care management resources and metrics

6) Consult with the parties on the most appropriate business structures with careful regard for anti-trust and kick-back issues

7) Assess the enterprise’s competencies and assist with the selection and procurement of any addition tools, technology, and

personnel.

MIHS and DMG will each contribute ½ of the $320,000 engagement fee in the furtherance of this initiative. It should be noted that the ultimate

implementation of the CIO will require addition expenditures by both parties.

Maricopa County



March 26, 2014


Treasurer’s Advisory Board

Maricopa County



March 26, 2014

Item 6.

Mercy Maricopa Integrated Care

Maricopa County



March 26, 2014

Item 7. INTENTIONALLY LEFT

BLANK

Maricopa County



March 26, 2014

Item 8. Key Indicator Dashboards &

CFO Report


Key Indicator Dashboard

February 28, 2014

Key Indicator Dashboard - Quality 1

Key Indicator Dashboard - SCIP Detail (Surgical Care Improvement Project) 2

Key Indicator Dashboard - Operational 3

Key Indicator Dashboard - Financial 4

Appendix A Definition of Financial Indicators 5


Key Indicator Dashboard

Dashboard


Key Indicator Dashboard - Quality

February 28, 2014Prior

Target Month Month

Per 1000 Patient Days

Fall with Injuries Rate < 0.00 0.00 0.00

Medication Error with Adverse Event Rate < 0.00 0.00 0.08

Pressure Ulcer Stage III & IV NPOA Rate < 0.00 0.00 0.59

Restraint Episode Rate < 21.1 25.50 23.80

Restraint Episodes - Psych < 30.0 31.50 36.40

Outcome of Care Measures

Overall Mortality Rate < 0.81 1.02 0.88

% Readmissions < 30 Days < 9.27 9.87 11.94

Process of Care Measures

AMI > 95% 100% 83%

Heart Failure > 95% 100% 100%

Pneumonia > 95% 97% 96%

SCIP > 95% 98% 99%

Patient Satisfaction

Inpatient 85.6% 84.0%

Emergency Room (Adult) 75.0% 80.5%

Emergency Room (Pediatric) 87.7% 91.8%

Behavioral Health 0.0% 0.0%

Outpatient 87.4% 88.1%

Medical Practice (CHC & FHCs) 84.2% 84.0%

Greater than 100% of Target

Within 95% to 100% of Target

Less than 95% of Target

Current Month

Legend

Page 1


Key Indicator Dashboard - Quality

February 28, 2014

Current

Month

SCIP Inf-1aProphylactic Antibiotic Received Within One Hour

Prior to Surgical Incision100.0%

Numerator 18

Denominator 18

SCIP Inf-2a Prophylactic Antibiotic Selection for Surgical Patients 94.7%

Numerator 18

Denominator 19

SCIP Inf-3aProphylactic Antibiotics Discontinued Within 24 Hours

After Surgery End Time94.7%

Numerator 18

Denominator 19

SCIP Inf-6 Surgery Patients with Appropriate Hair Removal 100.0%

Numerator 27

Denominator 27

SCIP Inf-9

Urinary catheter removed on Postoperative Day 1

(POD 1) or Postoperative Day 2 (POD 2) with day of

surgery being day zero

100.0%

Numerator 3

Denominator 3

SCIP Inf-10Surgery Patients with Perioperative Temperature

Management

Numerator 0

Denominator 0

SCIP Card-2

Surgery Patients on Beta-Blocker Therapy Prior to

Arrival Who Received a Beta-Blocker During the

Perioperative Period

100.0%

Numerator 3

Denominator 3

SCIP VTE-2

Surgery Patients Who Received Appropriate Venous

Thromboembolism Prophylaxis Within 24 Hours Prior

to Surgery to 24 Hours After Surgery

100.0%

Numerator 25

Denominator 25

Total Surgical Care Improvement Project Measures 98.2%

Numerator 112

Denominator 114

Page 2


Key Indicator Dashboard - Operational

February 28, 2014

Actual Budget Variance Actual Budget Variance Actual Variance

Acute

Admissions 1,088 1,112 (24) 8,946 9,837 (891) 9,283 (337)

Length of Stay (LOS) 5.00 4.90 (0.09) 4.93 4.91 (0.02) 4.82 (0.11)

Patient Days 5,435 5,450 (15) 44,120 48,300 (4,180) 44,756 (636)

Acute - Observation Days and Admits

Observation Days 524 542 (18) 4,191 4,411 (220) 3,039 1,153

Admits to OBS 483 351 132 3,624 2,873 751 2,809 815

Behavioral Health

Admissions 264 256 8 2,449 2,401 48 2,389 60

Length of Stay (LOS) 18.3 18.7 0.4 16.8 17.4 0.7 17.5 0.7

Patient Days 4,841 4,800 41 41,037 41,872 (835) 41,818 (781)

Ambulatory

Family Health Centers (FHC) Visits 15,562 14,407 1,155 123,929 124,913 (984) 120,706 3,223

Integrated Health Home (IHH) Visits 807 559 248 6,318 4,669 1,649 2,393 3,925

Comprehensive Health Center (CHC) Visits 12,965 11,893 1,072 102,826 100,190 2,636 99,898 2,928

Subtotal : 29,334 26,859 2,475 233,073 229,772 3,301 222,997 10,076

Dental Clinics Visits 2,693 1,818 875 16,746 15,876 870 14,684 2,062

7th Ave Walk-In Clinic Visits 2,303 1,960 343 17,727 17,127 600 16,901 826

Total Ambulatory Visits : 34,330 30,637 3,693 267,546 262,775 4,771 254,582 12,964

Hospital

Operating Room Utilization 72% 70% 2.0%

Surgical Center (SURG) - Total IP & OP Surgeries 579 642 (63) 5,014 5,241 (227) 5,190 (176)

Surgical Center (SURG) - Total Surgical Minutes 70,005 75,512 (5,507) 587,970 613,335 (25,365) 599,475 (11,505)

Surgical Center (SURG) - Minutes per Case 121 118 3 117 117 0 116 2

Deliveries 204 222 (18) 1,867 1,841 26 1,746 121

Emergency Department (ED) 5,626 5,495 131 44,618 45,601 (983) 44,006 612

Adult ED 3,803 3,781 22 32,209 32,497 (288) 31,508 701

Peds ED 1,823 1,713 110 12,409 13,104 (695) 12,498 (89)

% of Total ED Visits Resulting in Admission Adult 15.6% 16.1% (0.6%)

% of Total ED Visits Resulting in Admission Peds 7.5% 11.2% (3.8%)

Left Without Treatment (LWOT) ADULT 4.1% <3% (1.1%)

Left Without Treatment (LWOT) PEDIATRICS 0.0% <3% 3.0%

Overall ED Median Length of Stay (M-LOS) (minutes) ADULT 341 <180 (161)

Overall ED Median Length of Stay (M-LOS) (minutes) PEDS 146 <180 34

PSYCH ED Median LOS (minutes) 906 <0 (906)

Median Time to Treatment (MTT) (minutes) ADULT 35 30 (5)

Median Time to Treatment (MTT) (minutes) PEDS 23 30 7

% of Acute Patients Admitted Through the ED 66.9% 72.1% (5.2%)

Labor

FTE/AOB WO Residents 5.85 6.19 0.35 6.01 6.13 0.12 5.68 (0.33)

Turnover Rate - Voluntary 1.01% 13.54%

Turnover Rate - Involuntary 0.45% 7.27%

Turnover Rate - Total 1.46% 20.81%

Membership Disenrollment Rate CY 12 CYE 11 CYE 10 CYE 09 CYE 08

Maricopa Health Plan (MHP) 5% 4% 5% 3% 6%

AHCCCS Average 2% 2% 2% 2% 2%

December January February February Budget

Member Months

Maricopa Health Plan (MHP) 51,305 64,096 74,841 64,567

Maricopa Care Advantage (MCA) 749 834 220

Covered Lives

University Physicians Healthcare (UPH) Exchange Plan 58 59

Meritas Health Plan 850 1,028

Greater than or equal to 100% of Budget

Within 95% to 100% of Budget

Less than 95% of Budget

Current Month CY Year to Date PY Year to Date

Legend

Page 3


Key Indicator Dashboard - Financial

February 28, 2014

Actual Budget Variance Actual Budget Variance Actual Variance

Consolidated Financials

Maricopa Medical Center 2,259$ (3,828)$ 6,087$ (7,565)$ (6,731)$ (835)$ 1,848$ (9,413)$

Maricopa Health Plan (291)$ 65$ (356)$ 543$ 906$ (363)$ 627$ (84)$

Maricopa Care Advantage (408)$ (228)$ (180)$ (798)$ (456)$ (342)$ -$ (798)$

Total Margin (000s) 1,560$ (3,991)$ 5,551$ (7,820)$ (6,281)$ (1,540)$ 2,475$ (10,295)$

Actual - YTD Budget Actual - YTD

June 30, 2014 FY2014 Variance June 30, 2013 Variance

Liquidity

Total Cash and Investments 118.9$ 183.7$ (64.8)$ 146.7 (27.8)

Total Days Cash on Hand 64.8 97.8 (33.0) 85.4 (20.6)

Days in Account Receivable 74.0 44.0 (30.0) 53.0 21.0

Cushion Ratio 35.8 46.7 (10.9) 47.5 (11.7)

Cash to Debt 552.62% 785.50% (232.88%) 720.00% (167.38%)

Capital Structure

EBITDA Debt Service Coverage 2.1 6.0 (4.0) 11.9 (9.8)

Debt to Net Assets 12.41% 12.40% (0.01%) 10.99% (1.42%)

Actual - YTD Budget - YTD Actual - YTD

June 30, 2014 FY2014 Variance June 30, 2013 Variance

Profitability

Operating Margin (12.92%) (12.95%) 0.03% (7.84%) (5.08%)

Operating Income (Loss) ($52,647,937) ($52,111,815) ($536,123) ($39,453,962) ($13,193,976)

EBITDA Margin 1.68% 2.48% (0.80%) 6.05% (4.37%)

EBITDA $6,889,798 $10,084,922 ($3,195,124) $16,832,445 ($9,942,647)

Excess Margin (1.90%) (1.54%) (0.36%) 2.48% (0.58%)

Increase in Net Asset ($7,820,343) ($6,280,535) ($1,539,808) $2,474,682 ($10,295,024)

Greater than or equal to 100% of Budget

Within 95% to 100% of Budget

Less than 95% of Budget

Legend

Current Month CY Year to Date PY Year to Date

Page 4

Indicator Definition Trend Median

Cash + Short-Term Investments

(Operating Expenses Less - Depreciation) / YTD Days

Net Patient Accounts Receivable (including Due/From)

Net Patient Service Revenue / YTD Days


Principal + Interest Expenses


Long Term Debt

EBITDA

Principal + Interest Expenses

Long Term Debt

Long Term Debt + Unrestricted Assets

Operating Income (Loss)

Operating Revenues

EBITDA

Operating Revenues + Non Operating Revenues

Net Income

Operating Revenues + Non Operating RevenuesAbove

EBITDA Margin = X 100 Up Above

Excess Margin = X 100 Up

AboveCushion Ratio

Above

Debt to Net Assets = X 100 Down Below

Operating Margin = X 100 Up

Above

Cash to Debt = X 100 Up Above

EBITDA Debt Service

Coverage = Up

Up

Up=

Appendix A

Definition of Financial Indicators

Desired Position

Relative to

Above

Days in Accounts

Receivable= Down Below

Total Days Cash on Hand =

Page 5

Maricopa County Special Health Care District Office of the Chief Financial Officer 2601 E. Roosevelt Phoenix, AZ 85008 Phone: (602) 344-1256

DATE: March 19, 2014 TO: Mary A. Harden, R.N., Chairman, District 1

Mark Dewane, Vice Chairman, District 2 Susan Gerard, Director, District 3 Elbert Bicknell, Director, District 4 Terence McMahon, Director, District 5 Steven Purves, Chief Executive Officer

FROM: Michael Ayres, CFO SUBJECT: February CFO Report

Financial Performance Maricopa Integrated Health System (MIHS) recorded a net profit of $1.6M for the period as compared to a budgeted net loss of $4.0M resulting in a $5.6M positive variance to budget. Maricopa Medical Center (MMC) contributed a net profit of $2.3M as compared to a budgeted net loss of $3.8M for a $6.1M positive variance to budget. A positive trend is the reduction of self-pay patient volume. Since December, MMC has experienced an average decline of 16% in its outpatient volume of self-pay patients with a corresponding increase in AHCCCS or other payer categories. For inpatient admissions, the State is backlogged on processing Medicaid applications and many inpatient accounts are still in a pended status. However, while it is still too early to validate that the inpatient volume is experiencing the same trend, initial estimates, based on a review of the completed applications, would indicate a similar trend. Additionally, another factor contributing to the positive bottom-line this month was the conversion to a new financial reporting system. This conversion required posting some revenues earlier than the normal cycle. Maricopa Health Plan (MHP) recorded a net loss of $291K as compared to a budgeted net income of $65K for a $356K negative variance to budget. Maricopa Care Advantage (MCA) recorded a net loss of $408K as compared to a budgeted net loss of $228K for a $180K negative variance to budget. During February, both health plans continued to experience increased

inpatient volumes due to respiratory illnesses. This factor contributed to the negative medical loss ratio to budget for MHP of 93.67% as compared to a budget of 91.61% and for MCA of 115.3% as compared to a budget of 101.10%. The year to date consolidated loss for MIHS is $7.8M as compared to a budgeted net loss of $6.3M for a $1.5M negative variance to budget. February’s financial results, as compared to budget, helped close the year to date negative performance gap to budget significantly. Inpatient acute volumes continue to be less than budget for the month though not by a significant amount. The inpatient acute length of stay came in 2.0% above budget for the month and admissions were under budget by 2.2% resulting in inpatient days under budget by 0.3%. The inpatient behavioral health admission volumes were over budget by 3.1%, however, length of stay was under budget by 0.4 days causing a slight positive behavioral health patient day variance of 0.9%. Outpatient volumes for the month were positive. The FHCs, the CHCs, dental, 7th Avenue Walk-In clinic and the adult and pediatric ED had positive variances to budget of 9.4%, 9.0%, 48.1%, 17.5%, 0.6% and 6.4%, respectively. The outpatient ambulatory surgery volume was the only exception and was only under budget by 1 case or 0.4%. Adjusted Patient Days (APD) for the month was a positive 3.2% as compared to budget. On a year to date basis, APD is a negative 1.0% as compared to budget. Other operating revenue had a positive variance to budget of $7.1M. The majority of this variance, or $7.3M, was in health plan capitation revenue due to the positive variance to budget in member month volume for both MHP and MCA. MHP had an increase in the number of enrolled lives due to AHCCCS restoration and expansion of 10,745 over January’s enrollment or 16.8%. In November and December, MHP averaged 53,000 member months. The February enrollment is 74,841 or approximately 41% higher. In addition, MCA is experiencing a much higher enrollment than budgeted. February’s enrollment of 824 compared favorably to a budget of 220 and year to date, enrollment is 1,583 are 1,163 higher than the budget of 420. For MMC, the overall negative variance of $241K to budget for other operating revenue was caused by two factors; 1) actual projected AHCCCS GME reimbursement is under budget $325K, 2) offset with a positive variance to budget of $69K for cafeteria sales. Due to timing, the FY14 budget for AHCCCS GME was based on the estimated FY13 payment. The FY13 payment will be$3.9M less than expected or $325K per month. MIHS received notification from AHCCCS that MMC’s GME 2013 payment of $34,973,459.18 will be issued on Friday, March 21, 2014. The consolidated operating expenses for February were $65.1M resulting in an $8.2M negative variance to the budget of $56.9M. YTD the system’s consolidated operating expenses are $460.2M, a $5.7M unfavorable variance to budget of $454.5M. The primary driver for this variance is the health plan medical costs. As discussed above, medical costs are higher than budget due to enrollment and inpatient utilization exceeding expectation. Combined, MHP and MCA were $7.8M over budget in operating expenses for the month.

The discussion above identifies several significant variances from budget, primarily the impact of the Affordable Care Act and AHCCCS restoration and expansion on the enrollment in the two health plans, their impact on the change of payer mix as well as the steps necessary to implement the new general ledger system. Included with the financial statements are service line specific reports for each of the major service areas – the hospital, behavioral health, home assist health, ambulatory clinics, Maricopa Care Advantage and Maricopa Health Plan. These statements reflect the revenues and expenses associated with each of the service lines. One note: the service line financial statements provided to the Board do not tie to the financial statements provided to the FQHC Council. This is because several departments are included in the FQHC Council reports that allow the Council to evaluate the full economic impact they have on the system. For the Board reports the departments have been classed in their more appropriate operational service line. These include the outpatient pharmacies and the CHC specialty clinics. One of the unexpected consequences of our success in enrollments at MHP and MCA is the requirement to increase the reserves required for each organization. MHP, in order to meet its financial viability standard, will have to increase its performance bond from its current $12 million to $20 million. The increase was expected but not prior to midyear. In addition, MCA, while not having to increase its performance bond, will need to increase its equity contribution to $2.5 million for the 958 members currently enrolled. This also brings our current ratio into compliance with regulations. Please recall that these are standby funds and would only be used in the event that the plans are unable to meet their current operations. We do not anticipate that is going to occur. Supply Chain and General Ledger Conversion A component of the EAS and Kronos system implementation was a replacement of the legacy general ledger and supply chain management systems. Both products were implemented on March 1st, on time and on budget. We encountered some minor training and educational difficulties in the supply chain management system but otherwise the implementations were without incident and the process for ordering supplies throughout the system is functional. Over the next 30 days we will continue to monitor and verify that data and transactions are functioning as intended. System optimization and enhancement activities will continue for the next 45 to 60 days. The first financial close with the new general ledger system is March 2014, however, daily transactions are live and posting without incident. The general ledger efficacy will be reviewed as part of the 2014 external audit. The next systems scheduled for implementation throughout the summer include cost accounting, decision support, human resources, payroll, workforce analytics and enhanced reporting at the operating level. RBHA Impact on AHCCCS Capitation Rate The implementation of the new RBHA contract on April 1st impacts capitation rates for each of the AHCCCS contractors. The new RBHA model combines payment for seriously mentally ill (SMI) patients for both physical and mental health medicine. As a result, AHCCCS is moving the physical medicine revenue from the existing AHCCCS plans to the RBHA. This reduces the per

member per month payment received by MHP for those patients who historically were enrolled in MHP who are SMI. The impact is expected to be $666,000 for the six month period April 2014 through September 2014 or $111,000 per month. This calculation is actuarially based and not specific to the patients that will actually be reassigned. Theoretically, MIHS will recover this loss through services now paid for by the RBHA. 2015 Budget Process Management continues to develop the information necessary for the 2015 system budget. Meetings have been held with key managers to identify programs and services that will generate additional revenues. Additionally, the discussions focused on ways to potentially reduce operating costs. The productivity study, value analysis programs, the focus on other revenue opportunities and expense reductions activities are well underway. I anticipate providing the Directors with the revised strategic financial forecast at the April meeting as well as a preliminary Operating Plan for 2015. Michael D. Ayres Chief Financial Officer March 19, 2014

MARICOPA COUNTY SPECIAL HEALTH CARE DISTRICTd/b/a MARICOPA MEDICAL CENTER

VolumesFebruary 28, 2014

Current Period Year to Date

Volume Actual Budget Variance Last Year Actual Budget Variance Last Year

AdmissionsAcute 1,088 1,112 (24) 1,129 8,946 9,837 (891) 9,283 Psych 264 256 8 257 2,449 2,401 48 2,389 Total 1,352 1,368 (16) 1,386 11,395 12,238 (843) 11,672

Admits to Observation 483 351 132 341 3,624 2,873 751 2,809

Length of StayAcute 5.0 4.9 (0.1) 4.5 4.9 4.9 (0.0) 4.8 Psych 18.3 18.7 0.4 18.7 16.8 17.4 0.7 17.5 Total 7.6 7.5 (0.1) 7.1 7.5 7.4 (0.1) 7.4

Patient DaysAcute 5,435 5,450 (15) 5,033 44,120 48,300 (4,180) 44,756 Psych 4,841 4,800 41 4,795 41,037 41,872 (835) 41,818 Total 10,276 10,250 26 9,828 85,157 90,172 (5,015) 86,574

Average Daily CensusAcute 194 195 (1) 180 182 199 (17) 184 Psych 173 171 1 171 169 172 (3) 172 Total 367 366 1 351 350 371 (21) 356

Adjusted Patient Days 18,113 17,555 558 18,758 151,732 153,292 (1,560) 158,783

SurgeriesInpatient Cases 339 400 (61) 322 2,887 3,179 (292) 3,079 Outpatient Cases 240 241 (1) 275 2,127 2,062 65 2,111 Total 579 642 (63) 597 5,014 5,241 (227) 5,190

Inpatient Minutes 47,715 52,958 (5,243) 37,920 385,455 420,521 (35,066) 403,500 Outpatient Minutes 22,290 22,554 (264) 25,020 202,515 192,814 9,701 195,975 Total 70,005 75,512 (5,507) 62,940 587,970 613,335 (25,365) 599,475

Deliveries 204 222 (18) 194 1,867 1,841 26 1,746

ED Visits Adult 3,803 3,781 22 3,666 32,209 32,497 (288) 31,508 Peds 1,823 1,713 110 1,631 12,409 13,104 (695) 12,498 Total 5,626 5,495 131 5,297 44,618 45,601 (983) 44,006

7th Ave. walk-in clinic 2,303 1,960 343 2,711 17,727 17,127 600 16,901

OP VisitsFHC 16,369 14,966 1,403 15,058 130,247 129,582 665 123,099 CHC 12,965 11,893 1,072 12,205 102,826 100,190 2,636 99,898 Dental 2,693 1,818 875 1,894 16,746 15,876 870 14,684 Total 32,027 28,677 3,350 29,157 249,819 245,648 4,171 237,681


VolumesFebruary 28, 2014

Current Period Year to Date

Department Volume Actual Budget Variance Last Year Actual Budget Variance Last Year

RadiologyCT Scan Procedures 2,477 2,270 207 2,330 20,330 19,693 637 19,619 Diagnostic Procedures 4,669 4,260 409 4,442 35,996 37,108 (1,112) 36,763 Therapeutic/MRI Procedures 373 450 (77) 278 2,692 3,898 (1,206) 2,329 Ultrasound Procedures 1,801 1,472 329 1,578 14,764 12,685 2,079 12,851 Nuclear Medicine Procedures 98 99 (1) 106 767 852 (85) 867 Spec Procedures/Angio Procedures 212 - 212 163 1,477 - 1,477 1,945 Outpatient/Offsite Procedures 2,373 1,795 578 1,906 20,014 15,301 4,713 15,771

12,003 10,346 1,657 10,803 96,040 89,537 6,503 90,145

OtherCardiac Cath Lab Cases 32 56 (24) 60 361 490 (129) 429 Therapy Procedures 12,497 10,561 1,936 11,477 111,150 92,764 18,386 90,970 Respiratory Procedures 7,612 6,623 989 8,305 58,643 58,562 81 60,767 Dialysis Treatments 1,247 1,237 10 1,132 10,152 9,898 254 10,048 Lab Billable Tests 112,523 110,867 1,656 109,813 918,735 962,831 (44,096) 953,138 Pulmonary Function Procedures 124 82 42 77 678 688 (10) 697 Echo Lab/EKG Services Procedures 2,129 2,024 105 2,062 17,634 17,604 30 17,433 Cardiology Services Visits 539 751 (212) 615 4,342 5,619 (1,277) 5,369 Endoscopy Procedures 297 270 27 237 2,149 2,220 (71) 2,230

Comfort Care Billable hours 60,152 60,922 (770) 59,195 511,155 516,174 (5,019) 516,513

Burn Clinic Visits 474 577 (103) 513 4,575 4,697 (122) 4,323

PharmacyAcute Orders Processed 186,247 181,513 4,734 172,901 1,539,586 1,600,704 (61,118) 1,521,515 O/P DISCHARGE Scripts 4,391 4,533 (142) 4,000 34,651 32,222 2,429 31,565 CHC Scripts 6,164 6,259 (95) 6,306 52,777 50,731 2,046 51,113 FHC Scripts 23,618 20,495 3,123 23,090 191,138 181,281 9,857 179,445

MARICOPA COUNTY SPECIAL HEALTH CARE DISTRICTCONSOLIDATED SYSTEM

Balance SheetFebruary 28, 2014

February 28, 2014 June 30, 2013Assets

Current AssetsCash and cash equivalents General funds Delivery system 50,230,630$ 103,557,526$ Health Plans 19,748,714 19,356,070 Total cash and cash equivalents - general funds 69,979,344 122,913,596 Board designated for future obligations Delivery system 20,550,731 20,968,375 Health Plans 28,370,401 5,137,232 Total cash and cash equivalents - board designated 48,921,132 26,105,607

Patient A/R, net of allowances 75,501,843 53,393,900Other receivables and prepaid items 15,490,297 15,578,243Estimated amounts due from third-party payors 70,314,768 44,483,790Due from related parties 5,273,943 182,647

Total current assets 285,481,327 262,657,783

Capital Assets, Net 133,757,050 125,444,254

Other Assets 4,386,429 5,000,000

Total assets 423,624,805$ 393,102,037$

Liabilities and Net Assets

Current LiabilitiesCurrent maturities of long-term debt 3,201,361$ 2,549,372$ Accounts payable 47,796,402 41,310,305Accrued payroll and expenses 21,392,511 20,074,547Medical claims payable 28,157,196 13,444,990Other current liabilities 37,432,578 23,695,418

Total current liabilities 137,980,049 101,074,632

Long-term Debt 21,515,724 20,378,170

Total liabilities 159,495,773 121,452,801

Net AssetsInvested in capital assets, net of related debt 112,241,325 105,066,084Unrestricted 151,887,707 166,583,151

Total net assets 264,129,032 271,649,236

Total liabilities and net assets 423,624,805$ 393,102,037$

MARICOPA COUNTY SPECIAL HEALTH CARE DISTRICTStatement of Revenues, Expenses, and Changes in Net Assets

For the month ending February 28, 2014

Current Month - Actual Current MonthAcute Behavioral HomeAssist Ambulatory Maricopa Maricopa Consolidated Consolidated

Hospital Health Health Clinics Care Advantage Health Plan Actual Budget Variance

Patient Service Revenue 56,818,102$ 1,193,743$ 502,608$ 1,542,535$ -$ -$ 60,056,988$ 62,769,096$ (2,712,108)$

Allocated ancillary/overhead revenue (11,886,671) 2,688,220 0 9,198,451 0 0 0 0 0Safety net care pool revenue 0 0 0 0 0 0 0 0 0Self-pay and bad debt deductions (19,220,578) (310,679) 19,615 (6,314,463) 0 0 (25,826,105) (35,092,410) 9,266,305

Net Patient Service Revenue 25,710,853 3,571,284 522,223 4,426,523 0 0 34,230,883 27,676,686 6,554,197

Other revenue 2,429,581 4,795 0 1,794,506 968,537 20,822,497 26,019,916 18,943,616 7,076,300

Total operating revenues 28,140,434 3,576,079 522,223 6,221,029 968,537 20,822,497 60,250,799 46,620,302 13,630,497

Operating ExpensesSalaries and wages 13,367,315 1,863,060 756,477 2,120,372 0 0 18,107,224 18,302,344 195,120Employee benefits 4,548,615 582,767 176,115 789,662 0 0 6,097,159 5,978,206 (118,953)Medical service fees 4,411,779 28,868 0 1,471,271 0 0 5,911,918 6,122,653 210,735Supplies 4,648,708 159,095 5,552 557,714 0 0 5,371,069 4,709,520 (661,549)Purchased services 1,848,981 69,737 (163) 50,387 259,695 1,629,975 3,858,612 3,666,941 (191,670)Medical claims 0 0 0 0 1,116,770 19,056,551 20,173,321 12,949,988 (7,223,333)Other expenses 3,020,002 24,834 37,094 234,191 0 427,338 3,743,459 3,067,082 (676,377)Depreciation 1,807,086 0 0 0 0 0 1,807,086 2,096,901 289,814Allocated ancillary/overheard expenses (4,083,622) 1,406,501 0 2,677,121 0 0 0 0 0

Total operating expenses 29,568,864 4,134,862 975,075 7,900,718 1,376,465 21,113,864 65,069,848 56,893,635 (8,176,213)

Operating Income (1,428,430) (558,783) (452,852) (1,679,689) (407,928) (291,367) (4,819,049) (10,273,333) 5,454,284

Nonoperating Revenues (Expenses)Noncapital grants 1,276,428 0 0 0 0 0 1,276,428 985,106 291,322Noncapital transfers from County 0 295,658 0 0 0 0 295,658 295,658 0Investment income 24,038 0 0 0 0 0 24,038 53,555 (29,517)Other nonoperating revenue (expenses) (169,093) 0 0 0 0 0 (169,093) 3,941 (173,034)Noncapital grants related expenses (208,139) 0 0 0 0 0 (208,139) (219,604) 11,465Interest expense (42,433) (2,263) 0 (3,898) 0 0 (48,594) (44,825) (3,769)Kidscare expense 0 0 0 0 0 0 0 0 0Tax levy 3,980,388 117,331 191 1,110,352 0 0 5,208,262 5,208,262 0

Total nonoperating revenues (expenses) 4,861,189 410,726 191 1,106,454 0 0 6,378,560 6,282,092 96,468

Excess of Revenues Over Expenses Before Extraordinary Items 3,432,760 (148,057) (452,661) (573,235) (407,928) (291,367) 1,559,512 (3,991,240) 5,550,752

Extraordinary Item 0 0 0 0 0 0 0 0 0

Increase in Net Assets 3,432,760$ (148,057)$ (452,661)$ (573,235)$ (407,928)$ (291,367)$ 1,559,512$ (3,991,240)$ 5,550,752$

MARICOPA COUNTY SPECIAL HEALTH CARE DISTRICTStatement of Revenues, Expenses, and Changes in Net Assets

For the Eight Months Ended February 28, 2014

Year to Date - Actual Year to DateAcute Behavioral HomeAssist Ambulatory Maricopa Maricopa Consolidated Consolidated

Hospital Health Health Clinics Care Advantage Health Plan Actual Budget Variance

Patient Service Revenue 508,827,228$ 11,948,697$ 6,489,258$ 12,732,795$ -$ -$ 539,997,978$ 531,669,079$ 8,328,899$

Allocated ancillary/overhead revenue (98,346,511) 23,930,190 0 74,416,321 0 0 0 0 0Safety net care pool revenue 23,159,973 0 0 5,783,202 0 0 28,943,175 27,708,592 1,234,583Self-pay and bad debt deductions (263,057,803) (5,641,162) 169,959 (50,811,765) 0 0 (319,340,771) (305,632,532) (13,708,238)

Net Patient Service Revenue 170,582,888 30,237,725 6,659,217 42,120,553 0 0 249,600,383 253,745,139 (4,144,757)

Other revenue ** 34,908,155 47,254 0 14,682,271 1,798,354 106,564,066 158,000,100 148,662,138 9,337,962

Total operating revenues 205,491,043 30,284,979 6,659,217 56,802,824 1,798,354 106,564,066 407,600,483 402,407,277 5,193,206

Operating ExpensesSalaries and wages 114,283,733 15,708,950 6,434,165 18,599,302 0 0 155,026,150 156,334,047 1,307,896Employee benefits 31,756,492 4,720,088 1,470,829 5,975,093 0 0 43,922,502 47,390,812 3,468,310Medical service fees 36,326,616 1,098,155 0 11,303,218 0 0 48,727,989 49,045,431 317,442Supplies 38,683,313 1,334,523 19,378 5,080,044 0 0 45,117,258 40,932,379 (4,184,880)Purchased services 19,369,186 484,881 597 378,927 553,235 9,685,498 30,472,324 31,038,929 566,605Medical claims 0 0 0 0 2,042,836 94,253,038 96,295,874 87,286,718 (9,009,156)Other expenses 21,054,071 415,816 320,406 2,400,367 0 2,154,886 26,345,546 26,499,245 153,699Depreciation 14,340,776 0 0 0 0 0 14,340,776 15,991,531 1,650,755Allocated ancillary/overheard expenses (34,217,985) 12,188,668 0 22,029,317 0 0 0 0 0

Total operating expenses 241,596,203 35,951,081 8,245,375 65,766,268 2,596,071 106,093,422 460,248,420 454,519,092 (5,729,328)

Operating Income (36,105,160) (5,666,102) (1,586,158) (8,963,444) (797,717) 470,644 (52,647,937) (52,111,815) (536,122)

Nonoperating Revenues (Expenses)Noncapital grants 5,446,977 0 0 0 0 0 5,446,977 5,270,444 176,532Noncapital transfers from County 0 2,365,264 0 0 0 0 2,365,264 2,365,264 0Investment income 180,651 0 0 0 0 72,000 252,651 415,323 (162,672)Other nonoperating revenue (expenses) (778,234) 0 0 0 0 0 (778,234) 33,927 (812,161)Noncapital grants related expenses (1,805,305) 0 0 0 0 0 (1,805,305) (1,905,848) 100,543Interest expense (326,990) (18,101) 0 (24,274) 0 0 (369,365) (373,926) 4,562Kidscare expense (1,491,109) 0 0 (459,381) 0 0 (1,950,490) (1,640,000) (310,490)Tax levy 34,006,727 586,753 674 7,071,942 0 0 41,666,096 41,666,096 0

Total nonoperating revenues (expenses) 35,232,717 2,933,916 674 6,588,287 0 72,000 44,827,594 45,831,280 (1,003,685)

Excess of Revenues Over Expenses Before Extraordinary Items (872,443) (2,732,186) (1,585,484) (2,375,157) (797,717) 542,644 (7,820,343) (6,280,535) (1,539,807)

Extraordinary Item 0 0 0 0 0 0 0 0 0

Increase in Net Assets (872,443)$ (2,732,186)$ (1,585,484)$ (2,375,157)$ (797,717)$ 542,644$ (7,820,343)$ (6,280,535)$ (1,539,807)$


Payor Mix Cases and Percentages - Trended (All Plans)

February 28, 2014

INPATIENT ADMISSIONS FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014 FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014

AHCCCS NON MHP 4,923 358 386 325 407 407 356 3,005 33% 30% 29% 29% 33% 33% 33% 31%

AHCCCS - MHP 1,310 79 126 101 116 133 130 897 9% 7% 10% 9% 9% 11% 12% 9%

PRE-AHCCCS 1 - 2 - 68 221 199 491 0% 0% 0% 0% 5% 18% 19% 5%

AGENCY (RBHA) - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

MEDICARE 689 51 61 46 63 52 47 432 5% 4% 5% 4% 5% 4% 4% 4%

MEDICARE RISK 590 61 57 38 24 42 39 359 4% 5% 4% 3% 2% 3% 4% 4%

HMO/PPO 956 70 72 61 64 65 50 515 6% 6% 5% 6% 5% 5% 5% 5%

COMMERCIAL 116 14 16 16 11 13 8 106 1% 1% 1% 1% 1% 1% 1% 1%

SELF PAY 3,429 319 342 279 211 81 60 1,969 23% 27% 26% 25% 17% 6% 6% 20%

OTHER 2,857 248 256 236 276 238 176 1,938 19% 21% 19% 21% 22% 19% 17% 20%

Total 14,871 1,200 1,318 1,102 1,240 1,252 1,065 9,712 100% 100% 100% 100% 100% 100% 100% 100%

INPATIENT PATIENT DAYS FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014 FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014

AHCCCS NON MHP 18,757 1,271 1,233 1,149 1,433 1,749 1,682 11,160 28% 24% 23% 22% 25% 29% 31% 25%

AHCCCS - MHP 3,834 401 444 514 563 493 446 3,632 6% 8% 8% 10% 10% 8% 8% 8%

PRE-AHCCCS - - 9 25 454 1,156 1,187 2,837 0% 0% 0% 0% 8% 19% 22% 6%

AGENCY (RBHA) - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

MEDICARE 4,507 412 329 375 417 445 373 2,993 7% 8% 6% 7% 7% 7% 7% 7%

MEDICARE RISK 4,024 331 377 281 244 308 311 2,543 6% 6% 7% 5% 4% 5% 6% 6%

HMO/PPO 5,981 314 262 357 526 486 318 2,952 9% 6% 5% 7% 9% 8% 6% 7%

COMMERCIAL 576 60 155 119 55 97 85 808 1% 1% 3% 2% 1% 2% 2% 2%

SELF PAY 16,093 1,357 1,554 1,532 916 337 178 8,907 24% 26% 28% 29% 16% 6% 3% 20%

OTHER 12,448 1,053 1,111 933 1,013 958 842 8,127 19% 20% 20% 18% 18% 16% 16% 18%

Total 66,220 5,199 5,474 5,285 5,621 6,029 5,422 43,959 100% 100% 100% 100% 100% 100% 100% 100%

from SRCOUTPATIENT CASES FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014 FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014

AHCCCS NON MHP 25,007 1,934 1,849 1,766 1,849 2,309 2,068 15,346 25% 24% 22% 23% 24% 26% 26% 24%

AHCCCS - MHP 10,485 731 798 746 751 982 900 6,388 10% 9% 9% 10% 10% 11% 11% 10%

PRE-AHCCCS 3 1 - - 34 108 110 253 0% 0% 0% 0% 0% 1% 1% 0%

AGENCY (RBHA) 1 - - - 1 - 6 14 0% 0% 0% 0% 0% 0% 0% 0%

MEDICARE 8,375 534 622 497 471 534 458 4,163 8% 7% 7% 6% 6% 6% 6% 6%

MEDICARE RISK 4,934 391 393 347 348 382 355 3,045 5% 5% 5% 4% 4% 4% 5% 5%

HMO/PPO 8,499 556 630 545 591 612 518 4,716 8% 7% 7% 7% 8% 7% 7% 7%

COMMERCIAL 685 68 96 112 99 83 104 759 1% 1% 1% 1% 1% 1% 1% 1%

SELF PAY 34,791 3,219 3,272 2,946 2,910 2,915 2,455 24,244 35% 40% 39% 38% 37% 33% 31% 37%

OTHER 7,952 663 750 755 784 851 854 6,084 8% 8% 9% 10% 10% 10% 11% 9%

Total 100,732 8,097 8,410 7,714 7,838 8,776 7,828 65,012 100% 100% 100% 100% 100% 100% 100% 100%

FEB 2014 MMC Payor Mix.xlsx, Payor Type Trend, 3/12/2014, 10:44 AM Page 1 of 4



February 28, 2014

PSYCHIATRIC ADMISSIONS FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014 FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014

AHCCCS NON MHP 20 - 1 3 2 4 4 18 1% 0% 0% 1% 1% 1% 2% 1%

AHCCCS - MHP - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

PRE-AHCCCS 4 1 3 - 1 5 2 19 0% 0% 1% 0% 0% 2% 1% 1%

AGENCY (RBHA) 2,028 162 200 140 176 187 145 1,380 57% 58% 59% 54% 57% 60% 58% 58%

MEDICARE 505 32 47 34 38 45 37 326 14% 11% 14% 13% 12% 15% 15% 14%

MEDICARE RISK 353 35 33 25 25 23 23 224 10% 13% 10% 10% 8% 7% 9% 9%

HMO/PPO 535 22 25 27 26 20 11 174 15% 8% 7% 10% 8% 6% 4% 7%

COMMERCIAL 77 26 30 31 39 24 27 245 2% 9% 9% 12% 13% 8% 11% 10%

SELF PAY 37 2 1 - - 2 - 12 1% 1% 0% 0% 0% 1% 0% 1%

OTHER 2 - - - 1 - - 1 0% 0% 0% 0% 0% 0% 0% 0%

Total 3,561 280 340 260 308 310 249 2,399 100% 100% 100% 100% 100% 100% 100% 100%

PSYCHIATRIC PATIENT DAYS FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014 FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014

AHCCCS NON MHP 434 (19) 59 79 58 86 (29) 279 1% 0% 1% 2% 1% 2% -1% 1%

AHCCCS - MHP - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

PRE-AHCCCS - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

AGENCY (RBHA) 25,930 1,932 1,866 1,883 1,774 2,569 2,260 16,146 47% 40% 42% 37% 38% 49% 53% 43%

MEDICARE 9,902 836 457 863 917 928 931 6,682 18% 17% 10% 17% 20% 18% 22% 18%

MEDICARE RISK 6,412 776 637 757 624 478 402 4,621 12% 16% 14% 15% 13% 9% 9% 12%

HMO/PPO 7,023 325 558 636 732 707 170 4,192 13% 7% 12% 12% 16% 14% 4% 11%

COMMERCIAL 848 311 216 248 (7) 108 81 1,255 2% 6% 5% 5% 0% 2% 2% 3%

SELF PAY 4,735 640 681 692 579 333 483 4,481 9% 13% 15% 13% 12% 6% 11% 12%

OTHER 5 - - (7) - - - - 0% 0% 0% 0% 0% 0% 0% 0%

Total 55,289 4,801 4,474 5,151 4,677 5,209 4,298 37,656 100% 100% 100% 100% 100% 100% 100% 100%

DENTAL VISITS FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014 FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014

AHCCCS NON MHP 2,300 167 236 174 167 193 269 1,660 10% 9% 12% 9% 9% 10% 10% 10%

AHCCCS - MHP 3,242 220 248 227 192 231 337 2,060 14% 11% 12% 11% 10% 12% 13% 12%

PRE-AHCCCS - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

AGENCY (RBHA) - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

MEDICARE 113 - - 3 1 (1) 2 5 0% 0% 0% 0% 0% 0% 0% 0%

MEDICARE RISK 415 48 37 37 54 59 68 385 2% 2% 2% 2% 3% 3% 3% 2%

HMO/PPO 2,292 150 181 191 175 186 236 1,453 10% 8% 9% 10% 9% 10% 9% 9%

COMMERCIAL 72 - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

SELF PAY 13,216 1,218 1,140 1,195 1,132 1,080 1,517 9,818 56% 62% 56% 60% 61% 58% 56% 59%

OTHER 1,796 148 180 155 133 129 264 1,365 8% 8% 9% 8% 7% 7% 10% 8%

Total 23,446 1,951 2,022 1,982 1,854 1,877 2,693 16,746 100% 100% 100% 100% 100% 100% 100% 100%




February 28, 2014

CHC CASES FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014 FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014

AHCCCS NON MHP 34,820 2,725 3,045 2,450 2,475 3,222 2,933 22,674 22% 21% 21% 20% 20% 23% 23% 21%

AHCCCS - MHP 25,421 1,823 1,890 1,555 1,590 2,036 1,985 14,785 16% 14% 13% 13% 13% 14% 16% 14%

PRE-AHCCCS - - - - 34 115 101 251 0% 0% 0% 0% 0% 1% 1% 0%

AGENCY (RBHA) 3 1 1 - - - 1 5 0% 0% 0% 0% 0% 0% 0% 0%

MEDICARE 9,890 784 846 676 620 767 706 6,036 6% 6% 6% 6% 5% 5% 6% 6%

MEDICARE RISK 10,917 863 939 791 761 854 782 6,826 7% 7% 6% 7% 6% 6% 6% 6%

HMO/PPO 11,488 830 978 793 814 977 859 7,194 7% 6% 7% 7% 7% 7% 7% 7%

COMMERCIAL 486 34 40 36 35 47 41 307 0% 0% 0% 0% 0% 0% 0% 0%

SELF PAY 60,766 5,632 6,238 5,316 5,275 5,549 4,725 44,781 38% 43% 43% 44% 44% 39% 37% 42%

OTHER 5,770 493 530 468 490 544 473 4,004 4% 4% 4% 4% 4% 4% 4% 4%

Total 159,561 13,185 14,507 12,085 12,094 14,111 12,606 106,863 100% 100% 100% 100% 100% 100% 100% 100%

FHC CASES FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014 FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014

AHCCCS NON MHP 53,943 4,370 4,650 3,986 3,761 5,334 4,658 35,638 25% 24% 23% 23% 23% 26% 26% 24%

AHCCCS - MHP 32,962 2,266 2,440 2,142 1,981 2,932 2,869 19,810 15% 12% 12% 12% 12% 14% 16% 13%

PRE-AHCCCS - - - - 7 18 10 36 0% 0% 0% 0% 0% 0% 0% 0%

AGENCY (RBHA) 14 2 - - - - 2 4 0% 0% 0% 0% 0% 0% 0% 0%

MEDICARE 13,013 986 1,148 968 959 1,179 987 8,424 6% 5% 6% 6% 6% 6% 6% 6%

MEDICARE RISK 14,206 1,252 1,426 1,124 1,149 1,491 1,225 10,097 7% 7% 7% 7% 7% 7% 7% 7%

HMO/PPO 14,641 1,040 1,288 1,126 1,061 1,274 1,182 9,289 7% 6% 6% 7% 6% 6% 7% 6%

COMMERCIAL 291 25 36 24 22 27 22 204 0% 0% 0% 0% 0% 0% 0% 0%

SELF PAY 77,139 7,948 8,200 7,097 7,044 7,289 6,153 58,894 36% 43% 41% 41% 42% 36% 35% 40%

OTHER 9,143 652 925 798 676 695 570 6,297 4% 4% 5% 5% 4% 3% 3% 4%

Total 215,352 18,541 20,113 17,265 16,660 20,239 17,678 148,693 100% 100% 100% 100% 100% 100% 100% 100%

7th AVE WIC CASES FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014 FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014

AHCCCS NON MHP 6,774 527 505 471 513 634 494 4,149 32% 30% 29% 29% 30% 31% 31% 29%

AHCCCS - MHP 1,393 117 143 102 114 151 137 972 7% 7% 8% 6% 7% 7% 8% 7%

PRE-AHCCCS - - - - 2 10 11 23 0% 0% 0% 0% 0% 0% 1% 0%

AGENCY (RBHA) - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

MEDICARE 449 35 32 25 45 26 46 288 2% 2% 2% 2% 3% 1% 3% 2%

MEDICARE RISK 676 47 47 61 65 55 48 469 3% 3% 3% 4% 4% 3% 3% 3%

HMO/PPO 1,475 96 72 74 105 97 81 714 7% 5% 4% 5% 6% 5% 5% 5%

COMMERCIAL 146 19 14 17 14 24 9 131 1% 1% 1% 1% 1% 1% 1% 1%

SELF PAY 10,092 929 882 875 861 1,049 779 7,502 48% 52% 52% 53% 50% 51% 48% 52%

OTHER 107 6 17 17 18 18 14 102 1% 0% 1% 1% 1% 1% 1% 1%

Total 21,112 1,776 1,712 1,642 1,737 2,064 1,619 14,350 100% 100% 100% 100% 100% 100% 100% 100%




February 28, 2014

DIALYSIS VISITS FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014 FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014

AHCCCS NON MHP 26 2 2 3 3 4 4 21 2% 1% 1% 2% 2% 4% 4% 2%

AHCCCS - MHP 64 4 4 5 5 5 5 37 4% 3% 3% 4% 3% 5% 4% 3%

PRE-AHCCCS - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

AGENCY (RBHA) - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

MEDICARE 270 19 17 17 19 17 18 146 16% 13% 12% 12% 12% 16% 16% 13%

MEDICARE RISK 66 5 5 5 5 7 7 44 4% 3% 4% 4% 3% 6% 6% 4%

HMO/PPO 22 - - - - 1 1 4 1% 0% 0% 0% 0% 1% 1% 0%

COMMERCIAL - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

SELF PAY 28 4 3 3 6 5 8 32 2% 3% 2% 2% 4% 5% 7% 3%

OTHER 1,171 117 111 107 124 69 70 828 71% 77% 78% 76% 77% 64% 62% 74%

Total 1,647 151 142 140 162 108 113 1,112 100% 100% 100% 100% 100% 100% 100% 100%

COMPLETE COMFORT CARE VISITS FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014 FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014

AHCCCS NON MHP 7,696 613 618 637 640 647 610 5,000 100% 100% 100% 99% 100% 100% 98% 100%

AHCCCS - MHP - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

PRE-AHCCCS - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

AGENCY (RBHA) - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

MEDICARE - - - - - - 2 2 0% 0% 0% 0% 0% 0% 0% 0%

MEDICARE RISK 4 1 - - - - 8 10 0% 0% 0% 0% 0% 0% 1% 0%

HMO/PPO - - - 1 - - - 1 0% 0% 0% 0% 0% 0% 0% 0%

COMMERCIAL - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

SELF PAY 5 1 3 3 2 2 - 12 0% 0% 0% 0% 0% 0% 0% 0%

OTHER - - - - - - - - 0% 0% 0% 0% 0% 0% 0% 0%

Total 7,705 615 621 641 642 649 620 5,025 100% 100% 100% 100% 100% 100% 100% 100%

ADMISSIONS/CASES/VISITS (No Days) FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014 FYE 2013 SEP OCT NOV DEC JAN FEB FYTD 2014

AHCCCS NON MHP 135,509 10,696 11,292 9,815 9,817 12,754 11,396 87,511 25% 23% 23% 23% 23% 26% 26% 24%

AHCCCS - MHP 74,877 5,240 5,649 4,878 4,749 6,470 6,363 44,949 14% 11% 11% 11% 11% 13% 14% 12%

PRE-AHCCCS 8 2 5 - 146 477 433 1,073 0% 0% 0% 0% 0% 1% 1% 0%

AGENCY (RBHA) 2,046 165 201 140 177 187 154 1,403 0% 0% 0% 0% 0% 0% 0% 0%

MEDICARE 33,304 2,441 2,773 2,266 2,216 2,619 2,303 19,822 6% 5% 6% 5% 5% 5% 5% 5%

MEDICARE RISK 32,161 2,703 2,937 2,428 2,431 2,913 2,555 21,459 6% 6% 6% 6% 6% 6% 6% 6%

HMO/PPO 39,908 2,764 3,246 2,818 2,836 3,232 2,938 24,060 7% 6% 7% 7% 7% 7% 7% 7%

COMMERCIAL 1,873 186 232 236 220 218 211 1,752 0% 0% 0% 1% 1% 0% 0% 0%

SELF PAY 199,503 19,272 20,081 17,714 17,441 17,972 15,697 147,264 36% 42% 41% 41% 41% 36% 35% 40%

OTHER 28,798 2,327 2,769 2,536 2,502 2,544 2,421 20,619 5% 5% 6% 6% 6% 5% 5% 6%

Grand Total 547,987 45,796 49,185 42,831 42,535 49,386 44,471 369,912 100% 100% 100% 100% 100% 100% 100% 100%


Maricopa County Special Health Care District Board

Financial Report

February 28, 2014

Maricopa Medical Center

Arizona Burn Center

Comprehensive Healthcare Center

Family Health Centers

McDowell Healthcare Center (HIV Specialty Clinic)

Behavioral Health

Phoenix Cancer Center

Maricopa Attendant Care Program

Maricopa Health Plan

Pros Cons

1 Uncompensated care under budget 9,266,305 1 MHP - Operating income under budget (342,870)

2 MMC - Operating income over budget 5,977,180 2 MMC - Operating expenses over budget (335,659)

3 MMC - OP visits over budget 3,350 3 MMC - Other revenue under budget (241,358)

4 Adjusted patient days over budget 558 4 MMC - Surgeries under budget (63)

5 Urgent Care visits over budget 343 5 Contract labor FTE over budget (23)

6 ED visits over budget 131 6 Deliveries under budget (18)

7 Patient Days over budget 26 7 Admissions under budget (16)

Policy References:

1. Special Health Care District Board of Directors Bylaws

2. Board Policy 99012G



Chief Executive Officer Approved


Board Report Summary

February 28, 2014

Overview: Financial Performance for Current Month The Board shall monitor the financial performance of the District by receiving a financial report on a monthly basis which includes but not limited to: a balance sheet, income statement, and cash flow statement.

Motion: No motion required

MIHS Consolidated Income Statement 1

Admissions 2

Length of Stay 3

Patient Days 4

Adjusted Patient Days 4

Emergency Visits 5

Deliveries 5

Surgeries 5

Ambulatory 6

Inpatient and Outpatient Trended Payor Mix Based on Admissions and Cases 7

CHC and FHC Trended Payor Mix Based on Cases 8

7th Avenue Walk-in Clinic (7AWIC) and Behavioral Trended Payor Mix Based on Cases and Days 9

Financial Assistance Program Write-offs and Bad Debts per Adjusted Patient Day 10

Net Operating Revenue per Adjusted Patient Day 10

FTEs 11

RN Hours 12

FTEs per Adjusted Occupied Bed 12

Average Hourly Rate 12

Expenses per Adjusted Patient Day 13

Net Income 14

Property Tax Levy, Cash and Net Accounts Receivable Days 15

MHP Volumes 16

MHP Per Member Per Month 16

MHP Medical Loss Ratio 17

MHP Revenues, Expenses, and Net Income 17

Consolidated Financial Indicators 18

Individual Financial Performance Dashboard 19

Consolidated Statement of Revenues, Expenses and Changes in Net Assets 29

Consolidated Balance Sheet 30

Consolidated Cash Flow Statement 31

MMC Statement of Revenues, Expenses and Changes in Net Assets 32

MMC Balance Sheet 33

MMC Cash Flow Statement 34

MHP Statement of Revenues, Expenses and Changes in Net Assets 35

MHP Balance Sheet 36

MHP Cash Flow Statement 37

MCA Statement of Revenues, Expenses and Changes in Net Assets 38

MCA Balance Sheet 39

MCA Cash Flow Statement 40

YTD Operational Performance Dashboard 41

Summary of Accounts Receivable Write-offs 42

Collection Agency Results 43

Post Implementation Review Schedule 44


Monthly Financial Package

Finance Reports

Board Package

Current Month

Feb 2014 Feb 2014 Feb 2013Actual Budget Variance Actual

Operating Income / (loss)

Maricopa Medical Center (4,119,754)$ (10,096,934)$ 5,977,180$ (5,573,470)$

Maricopa Health Plan (291,367) 51,503 (342,870) 14,512Maricopa Care Advantage (407,928) (227,902) (180,026) 0

Total: (4,819,049)$ (10,273,333)$ 5,454,284$ (5,558,958)$

Total Income / (loss)

Maricopa Medical Center 2,258,807$ (3,828,400)$ 6,087,207$ (50,232)$

Maricopa Health Plan (291,367) 65,062 (356,429) 24,712Maricopa Care Advantage (407,928) (227,902) (180,026) 0

Total: 1,559,512$ (3,991,240)$ 5,550,752$ (25,520)$

Year to Date

Feb 2014 Feb 2014 Feb 2013Actual Budget Variance Actual

Operating Income / (loss)

Maricopa Medical Center (52,320,864)$ (52,467,686)$ 146,821$ (39,999,362)$

Maricopa Health Plan 470,644 811,411 (340,767) 545,400Maricopa Care Advantage (797,717) (455,540) (342,177) 0

Total: (52,647,937)$ (52,111,815)$ (536,123)$ (39,453,962)$

Total Income / (loss)

Maricopa Medical Center (7,565,270)$ (6,730,757)$ (834,513)$ 1,847,728$

Maricopa Health Plan 542,644 905,762 (363,118) 626,954Maricopa Care Advantage (797,717) (455,540) (342,177) 0

Total: (7,820,343)$ (6,280,535)$ (1,539,808)$ 2,474,682$

INCOME STATEMENT - MIHS CONSOLIDATED

INCOME STATEMENT - MIHS CONSOLIDATED

Page 1

J A S O N D J F M A M JFYETotal

YTD

FY13A 1,105 1,201 1,142 1,107 1,179 1,168 1,252 1,129 1,226 1,068 1,060 1,029 13,666 9,283

FY14B 1,172 1,284 1,227 1,199 1,266 1,250 1,326 1,112 1,300 1,161 1,136 1,135 14,570 9,837

FY14A 1,129 1,161 1,017 1,057 1,089 1,155 1,250 1,088 8,946 8,946

1,000

1,050

1,100

1,150

1,200

1,250

1,300

1,350

Admissions: Acute


YTD

FY13A 351 324 276 342 268 274 297 257 317 302 330 291 3,629 2,389

FY14B 353 327 277 345 270 275 297 256 317 303 330 290 3,641 2,401

FY14A 331 345 287 310 289 297 326 264 2,449 2,449

250

275

300

325

350

375

Admissions: Behavioral Health

J A S O N D J F M A M J FYE Total YTD

FY13A 1,456 1,525 1,418 1,449 1,447 1,442 1,549 1,386 1,543 1,370 1,390 1,320 17,295 11,672

FY14B 1,525 1,612 1,505 1,545 1,536 1,525 1,623 1,368 1,617 1,464 1,467 1,425 18,211 12,238

FY14A 1,460 1,506 1,304 1,367 1,378 1,452 1,576 1,352 11,395 11,395

1,225

1,325

1,425

1,525

1,625

1,725

Admissions: Total

Page 2


YTD

FY13A 5.1 4.8 5.0 5.0 4.8 4.7 4.7 4.5 4.7 5.1 5.0 5.2 4.9 4.8

FY14B 5.1 4.9 5.0 5.0 4.8 4.8 4.9 4.9 4.8 5.1 5.0 5.1 4.9 4.9

FY14A 4.7 4.9 5.1 5.2 4.9 4.9 4.9 5.0 4.9 4.9

4.4

4.6

4.8

5.0

5.2

5.4

Length of Stay: Acute


YTD

FY13A 4.2 4.1 4.2 4.2 4.0 4.0 4.0 3.9 4.0 4.3 4.3 4.3 4.1 4.1

FY14B 4.2 4.1 4.2 4.1 3.9 4.0 4.0 4.3 4.0 4.3 4.3 4.2 4.1 4.1

FY14A 4.0 4.0 4.4 4.4 4.1 4.1 4.0 4.3 4.1 4.1

3.8

3.9

4.0

4.1

4.2

4.3

4.4

4.5

Length of Stay: Acute Without Burn


FY13A 15.1 16.4 19.0 15.7 18.9 19.3 18.3 18.7 16.7 17.2 16.6 17.3 17.3 17.5

FY14B 15.0 16.3 19.0 15.6 18.8 19.3 18.3 18.7 16.7 17.2 16.6 17.4 17.3 17.4

FY14A 15.6 14.8 17.9 17.0 17.6 17.2 16.4 18.3 16.8 16.8

14.0

15.0

16.0

17.0

18.0

19.0

20.0

Length of Stay: Behavioral Health

Page 3


YTD

FY13A 5,581 5,823 5,707 5,539 5,614 5,521 5,938 5,033 5,766 5,412 5,290 5,343 66,567 44,756

FY14B 5,997 6,268 6,158 5,960 6,067 5,961 6,439 5,450 6,226 5,863 5,712 5,762 71,863 48,300

FY14A 5,335 5,648 5,222 5,494 5,296 5,619 6,071 5,435 44,120 44,120

4,900

5,200

5,500

5,800

6,100

6,400

6,700

Patient Days: Acute


YTD

FY13A 5,292 5,327 5,251 5,367 5,052 5,294 5,440 4,795 5,300 5,199 5,468 5,027 62,812 41,818

FY14B 5,299 5,334 5,258 5,375 5,059 5,299 5,449 4,800 5,304 5,204 5,475 5,032 62,888 41,872

FY14A 5,161 5,089 5,134 5,276 5,079 5,116 5,341 4,841 41,037 41,037

4,750

4,850

4,950

5,050

5,150

5,250

5,350

5,450

5,550

Patient Days: Behavioral Health


YTD

FY13A 10,873 11,150 10,958 10,906 10,666 10,815 11,378 9,828 11,066 10,611 10,758 10,370 129,379 86,574

FY14B 11,296 11,602 11,416 11,334 11,125 11,261 11,888 10,250 11,530 11,067 11,187 10,794 134,751 90,172

FY14A 10,496 10,737 10,356 10,770 10,375 10,735 11,412 10,276 85,157 85,157

9,600

10,100

10,600

11,100

11,600

12,100

Patient Days: Total


YTD

FY13A 20,153 20,814 19,441 20,639 18,852 19,603 20,576 18,758 20,924 20,649 21,656 19,803 241,800 158,783

FY14B 19,636 19,856 19,027 19,451 18,256 19,161 20,369 17,555 19,913 19,118 19,736 18,867 230,878 153,292

FY14A 19,041 18,956 18,861 19,989 18,231 18,528 20,051 18,113 151,732 151,732

17,500

18,250

19,000

19,750

20,500

21,250

22,000

Adjusted Patient Days

Page 4


YTD

FY13A 4,132 4,136 3,932 3,939 3,675 3,867 4,161 3,666 4,149 4,169 4,383 4,255 48,464 31,508

FY14B 4,260 4,266 4,054 4,061 3,791 3,991 4,293 3,781 4,279 4,300 4,518 4,385 49,979 32,497

FY14A 3,979 4,202 4,090 4,057 3,872 3,858 4,348 3,803 32,209 32,209

3,500

3,700

3,900

4,100

4,300

4,500

4,700

Adult Emergency Visits


YTD

FY13A 1,031 1,400 1,462 1,410 1,505 1,645 2,414 1,631 1,698 1,781 1,561 1,152 18,690 12,498

FY14B 1,083 1,472 1,533 1,479 1,578 1,723 2,523 1,713 1,785 1,864 1,630 1,203 19,586 13,104

FY14A 1,100 1,314 1,506 1,461 1,628 1,637 1,940 1,823 12,409 12,409

800

1,100

1,400

1,700

2,000

2,300

2,600

Pediatric Emergency Visits


YTD

FY13A 217 235 231 225 234 216 194 194 194 176 210 196 2,522 1,746

FY14B 224 237 236 232 239 220 231 222 130 236 229 238 2,674 1,841

FY14A 241 247 210 234 232 249 250 204 1,867 1,867

100

125

150

175

200

225

250

275

Deliveries


YTD

FY13A 659 750 624 650 622 629 659 597 669 731 674 664 7,928 5,190

FY14B 659 750 624 650 622 629 665 642 678 667 659 615 7,859 5,241

FY14A 683 660 630 616 579 604 663 579 5,014 5,014

550

600

650

700

750

800

Surgeries

Page 5


YTD

FY13A 11,779 13,899 11,958 13,414 11,961 11,103 13,579 12,205 13,067 14,346 13,557 12,641 153,509 99,898

FY14B 12,705 13,889 12,004 13,220 11,652 12,069 12,758 11,893 12,898 13,000 12,667 12,927 151,683 100,190

FY14A 13,189 13,733 12,635 13,636 12,129 11,492 13,047 12,965 102,826 102,826

10,750

11,250

11,750

12,250

12,750

13,250

13,750

14,250

14,750

Comprehensive Health Care Center Visits


YTD

FY13A 14,372 16,705 14,484 16,611 14,655 13,778 17,436 15,058 16,274 17,054 15,692 15,148 187,267 123,099

FY14B 17,034 17,092 15,604 17,160 14,825 16,380 16,521 14,966 16,522 17,303 16,524 16,525 196,456 129,582

FY14A 15,788 16,806 16,087 17,960 15,349 14,680 17,208 16,369 130,247 130,247

13,500

14,500

15,500

16,500

17,500

18,500

Family Health Care Center Visits


YTD

FY13A 1,905 2,124 1,836 1,403 2,015 1,784 1,723 1,894 2,204 2,234 2,184 2,140 23,446 14,684

FY14B 2,102 2,104 1,913 2,104 1,819 2,008 2,008 1,818 2,007 2,102 2,007 2,009 24,001 15,876

FY14A 2,160 2,207 1,951 2,022 1,982 1,854 1,877 2,693 16,746 16,746

1,300

1,600

1,900

2,200

2,500

2,800

Dental Health Care Center Visits


YTD

FY13A 1,532 1,995 2,109 2,174 2,060 2,347 1,973 2,711 2,203 2,411 2,368 2,018 25,901 16,901

FY14B 2,269 2,270 2,064 2,270 1,960 2,167 2,167 1,960 2,167 2,270 2,167 2,167 25,898 17,127

FY14A 2,092 2,450 2,119 2,150 2,044 2,183 2,386 2,303 17,727 17,727

1,400

1,600

1,800

2,000

2,200

2,400

2,600

2,800

7th Avenue Walk-in Clinic (7AWIC) Visits

Page 6

AHCCCS NonMHP

AHCCCS - MHP Medicare Medicare Risk HMO/PPO Commercial Self PayLow Income

SupportOther

FYE 06/30/12 32.1% 10.4% 5.5% 4.7% 6.8% 0.9% 14.2% 5.1% 20.2%

FYE 06/30/13 33.1% 8.8% 4.6% 4.0% 6.4% 0.8% 17.0% 6.1% 19.2%

FYTD 06/30/14 31.4% 9.3% 4.5% 3.7% 5.3% 1.1% 19.0% 5.2% 20.5%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

40.0%

Maricopa Medical Center Trended Payor Type Cases as a Percentage of Total Inpatient Cases

AHCCCS NonMHP


SupportOther

FYE 06/30/12 27.4% 12.0% 9.6% 5.1% 8.7% 0.8% 20.7% 7.4% 8.2%

FYE 06/30/13 24.8% 10.4% 8.3% 4.9% 8.4% 0.7% 25.4% 9.1% 7.9%

FYTD 06/30/14 23.6% 9.8% 6.4% 4.7% 7.3% 1.2% 29.9% 7.7% 9.4%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

40.0%

Maricopa Medical Center Trended Payor Type Cases as a Percentage of Total Outpatient Cases (Excluding CHC, FHC, 7AWIC)

Page 7

AHCCCS NonMHP


SupportOther

FYE 06/30/12 21.0% 19.3% 6.3% 7.1% 7.2% 0.4% 16.6% 18.7% 3.4%

FYE 06/30/13 21.8% 15.9% 6.2% 6.8% 7.2% 0.3% 17.9% 20.2% 3.6%

FYTD 06/30/14 21.2% 13.8% 5.6% 6.4% 6.7% 0.3% 25.0% 17.2% 3.7%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

Maricopa Medical Center Trended Payor Type Cases as a Percentage of Total CHC Cases

AHCCCS NonMHP


SupportOther

FYE 06/30/12 26.2% 19.4% 6.1% 6.2% 6.8% 0.1% 14.7% 16.5% 4.0%

FYE 06/30/13 25.0% 15.3% 6.0% 6.6% 6.8% 0.1% 16.8% 19.0% 4.2%

FYTD 06/30/14 24.0% 13.3% 5.7% 6.8% 6.2% 0.1% 23.4% 16.2% 4.2%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

Maricopa Medical Center Trended Payor Type Cases as a Percentage of Total FHC Cases

Page 8

AHCCCS NonMHP


SupportOther

FYE 06/30/12 37.4% 7.8% 2.3% 3.8% 7.5% 0.7% 18.8% 21.2% 0.5%

FYE 06/30/13 32.1% 6.6% 2.1% 3.2% 7.0% 0.7% 22.5% 25.3% 0.5%

FYTD 06/30/14 28.9% 6.8% 2.0% 3.3% 5.0% 0.9% 31.5% 20.9% 0.7%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

40.0%

45.0%

50.0%

Maricopa Medical Center Trended Payor Type Cases as a Percentage of Total 7th Avenue Walk-in Clinic Cases

AHCCCS NonMHP

Agency (RBHA) Medicare Medicare Risk HMO/PPO Commercial Self PayLow Income

SupportOther

FYE 06/30/12 1.1% 47.2% 19.1% 10.6% 13.3% 1.4% 5.4% 1.9% 0.0%

FYE 06/30/13 0.8% 46.9% 17.9% 11.6% 12.7% 1.5% 6.3% 2.3% 0.0%

FYTD 06/30/14 0.7% 42.9% 17.7% 12.3% 11.1% 3.3% 9.3% 2.6% 0.0%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

40.0%

45.0%

50.0%

Maricopa Medical Center Trended Payor Type Cases as a Percentage of Total Behavioral Days

Page 9


FY13A 3,631 2,536 2,955 2,046 2,600 2,251 2,450 2,205 2,327 2,749 2,561 2,705 2,585 2,585

FY14B 1,958 2,050 1,993 1,970 2,045 1,971 1,967 1,999 1,913 1,923 1,761 1,809 1,946 1,994

FY14A 2,070 3,296 1,871 2,125 2,537 1,929 1,590 1,426 2,105 2,105

1,000

1,500

2,000

2,500

3,000

3,500

4,000

Financial Assistance Program Write-offs & Bad Debt Per Adjusted Patient Day


FY13A 1,678 1,940 1,808 1,816 1,930 1,847 1,874 1,931 1,965 1,853 1,975 1,967 1,883 1,853

FY14B 1,955 1,950 2,199 1,961 2,163 2,063 1,759 1,831 1,899 1,986 2,055 2,258 2,005 1,984

FY14A 1,879 1,750 2,207 1,841 2,173 2,129 1,714 2,123 1,972 1,972

1,500

1,700

1,900

2,100

2,300

2,500

Net Operating Revenue Per Adjusted Patient Day

Page 10


YTD

FY13A 19 26 21 20 20 14 8 7 9 9 3 3 13 17

FY14B 1 1 1 1 1 1 1 1 1 1 1 1 1 1

FY14A 1 4 4 2 1 1 3 2 2 2

0

5

10

15

20

25

30

FTEs: Nursing Contract Labor


YTD

FY13A 83 105 85 53 95 85 77 79 48 43 44 34 69 83

FY14B 28 28 28 28 28 27 28 28 28 28 28 29 28 28

FY14A 45 53 38 51 45 66 51 50 50 50

20

30

40

50

60

70

80

90

100

110

FTEs: Non Nursing Contract Labor


YTD

FY13A 103 131 107 73 115 99 86 86 58 52 47 37 83 100

FY14B 29 29 29 29 29 28 29 29 29 29 29 30 29 29

FY14A 46 57 43 53 46 68 54 52 52 52

0

20

40

60

80

100

120

140

FTEs: Contract Labor


YTD

FY13A 3,895 3,882 3,934 3,918 4,061 3,948 3,907 3,987 4,004 3,930 3,901 4,012 3,948 3,941

FY14B 4,051 4,102 4,099 4,093 4,101 4,067 4,151 4,114 4,100 4,110 4,061 4,082 4,094 4,097

FY14A 4,054 3,926 3,974 3,976 3,980 3,966 3,977 4,008 3,982 3,982

3,850

3,900

3,950

4,000

4,050

4,100

4,150

4,200

FTEs: Total (Payroll and Contract Labor)

Page 11

J A S O N D J F M A M JYTDAVG

FY13A 12.2 12.3 12.1 11.9 11.9 12.1 11.8 12.4 12.3 12.3 13.4 13.0 12.3

FY14B 12.7 12.6 12.6 12.8 12.6 12.9 12.5 12.8 12.2 12.6 12.6 12.7 12.6

FY14A 13.5 12.3 13.1 13.1 12.8 12.6 11.5 12.4 12.6

11.0

11.5

12.0

12.5

13.0

13.5

14.0

RN Hours per Acute Day

J A S O N D J F M A M JYTDAVG

FY13A 2.9 2.8 3.0 2.8 3.0 2.8 3.0 3.0 3.0 2.9 2.9 2.9 2.9

FY14B 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2

FY14A 3.1 3.1 3.0 2.9 3.1 3.1 2.9 3.1 3.0

2.7

2.8

2.9

3.0

3.1

3.2

RN Hours per Behavioral Health Day


YTD

FY13A 6.0 5.8 6.1 5.9 6.5 6.2 5.9 6.0 5.9 5.7 5.6 6.1 6.0 6.0

FY14B 6.4 6.4 6.5 6.5 6.7 6.6 6.3 6.6 6.4 6.4 6.4 6.5 6.5 6.5

FY14A 6.6 6.4 6.3 6.2 6.5 6.6 6.1 6.2 6.4 6.4

5.50

5.75

6.00

6.25

6.50

6.75

7.00

FTEs Per Adjusted Occupied Bed

J A S O N D J F M A M J YTD

RN 41.62 41.08 41.17 41.03 41.04 42.17 42.05 42.08 41.53

Clinical/Technical 19.45 19.18 19.30 19.18 19.24 19.46 19.43 19.55 19.35

All Other 27.69 27.89 27.84 28.01 28.02 28.81 28.42 28.49 28.14

14.00

19.00

24.00

29.00

34.00

39.00

44.00

Average Hourly Rate

Page 12


YTD

FY13A 947 916 964 937 1,042 1,024 931 960 954 910 888 967 952 964

FY14B 1,018 1,012 1,024 1,031 1,082 1,076 1,034 1,065 1,032 1,046 1,030 1,053 1,041 1,042

FY14A 1,065 1,029 1,020 1,002 1,082 1,110 1,013 1,013 1,041 1,041

850

925

1,000

1,075

1,150

1,225

Salaries and Contract Labor Expense Per Adjusted Patient Day


YTD

FY13A 221 272 248 278 266 258 289 251 262 291 255 278 264 261

FY14B 261 272 270 267 274 264 260 268 262 263 251 256 264 267

FY14A 304 313 295 277 263 335 296 297 297 297

210

230

250

270

290

310

330

350

Supplies Expense Per Adjusted Patient Day


FY13A 2,003 2,009 2,087 2,043 2,224 2,141 2,118 2,228 2,089 2,112 2,000 1,970 2,084 2,105

FY14B 2,259 2,263 2,298 2,297 2,421 2,418 2,261 2,406 2,254 2,305 2,268 2,309 2,312 2,326

FY14A 2,357 2,352 2,265 2,181 2,317 2,526 2,203 2,351 2,317 2,317

1,900

2,000

2,100

2,200

2,300

2,400

2,500

2,600

Total Operating Expense Per Adjusted Patient Day

Page 13


YTD

FY13A (1,498) 3,654 (583) 460 11 (659) 513 (50) 3,243 (448) 3,985 4,823 13,451 1,848

FY14B (666) (907) 3,401 (688) 1,127 (938) (4,231) (3,828) (1,125) (171) 1,712 4,952 (1,363) (6,731)

FY14A (3,945) (6,199) 3,515 (951) 3,234 (1,267) (4,211) 2,259 (7,565) (7,565)

(8,000)

(6,000)

(4,000)

(2,000)

0

2,000

4,000

6,000

8,000

10,000

Maricopa Medical Center Net Income (Loss) (000's)


YTD

FY13A (654) 275 588 (107) 204 268 28 25 395 221 296 1,622 3,161 627

FY14B 252 249 253 18 15 11 42 65 88 112 136 156 1,397 906

FY14A 86 69 72 138 201 549 (281) (291) 543 543

(1,000)

(500)

0

500

1,000

1,500

2,000

Maricopa Health Plan Net Income (Loss) (000's)


YTD

FY13A

FY14B (228) (228) (228) (228) (229) (292) (1,433) (456)

FY14A (390) (408) (798) (798)

(500)

(450)

(400)

(350)

(300)

(250)

(200)

(150)

(100)

(50)

0

Maricopa Care Advantage Net Income (Loss) (000's)


YTD

FY13A (2,152) 3,929 5 354 214 (391) 541 (26) 3,638 (227) 4,281 6,445 16,612 2,475

FY14B (414) (657) 3,654 (670) 1,142 (927) (4,416) (3,991) (1,265) (288) 1,619 4,816 (1,400) (6,281)

FY14A (3,859) (6,129) 3,587 (813) 3,435 (718) (4,882) 1,560 (7,820) (7,820)

(8,000)

(6,000)

(4,000)

(2,000)

0

2,000

4,000

6,000

8,000

10,000

Consolidated Net Income (Loss) (000's)

Page 14

Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May JunFYETotal

YTD

FY11 289 231 4,580 14,117 10,781 1,927 1,159 2,437 2,950 8,796 10,512 486 58,265 35,521

FY12 462 245 4,381 16,088 9,299 2,135 1,316 1,753 2,827 6,382 13,098 678 58,665 35,680

FY13 - 275 202 5,017 15,840 11,788 2,416 1,266 36,804 36,804

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

Property Tax Actual Collections (000's)

-

25,000

50,000

75,000

100,000

125,000

150,000

175,000

M-13 A-13 M-13 J-13 J-13 A-13 S-13 O-13 N-13 D-13 J-14 F-14

Total 157,760 152,895 145,328 149,019 131,662 108,358 123,388 113,328 116,123 131,454 131,354 118,900

MMC 131,709 128,894 121,380 124,526 107,648 82,845 100,514 89,600 91,336 105,413 95,152 71,279

MHP 26,052 24,001 23,948 24,493 24,014 25,513 22,874 23,728 24,786 26,041 34,129 45,100

MCA - - - - - - - - - - 2,072 2,521

MIHS Monthly Trended Consolidated Cash Balance (000's)

40

45

50

55

60

65

70

75

80

85

Jan-13 Feb-13 Mar-13 Apr-13 May-13 Jun-13 Jul-13 Aug-13 Sep-13 Oct-13 Nov-13 Dec-13 Jan-14 Feb-14

# Days 46 45 47 46 47 53 58 60 69 71 73 74 73 74

Maricopa Medical Center Net Accounts Receivable Days

Page 15

Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun FYE Total FYE AVG

FY13A 54,720 54,863 54,132 53,304 52,006 51,961 51,463 51,059 50,850 50,257 50,269 49,622 624,506 52,042

FY14B 47,944 47,319 46,670 59,685 59,952 60,297 62,855 64,567 66,389 68,099 69,241 70,235 723,253 60,271

FY14A 49,651 49,330 49,224 50,418 50,694 51,305 64,096 74,841 439,559 54,945

45,000

50,000

55,000

60,000

65,000

70,000

75,000

MHP Member Months

Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May JunFYEAVG

FY13A 180 190 187 186 166 168 183 163 164 153 153 147 170

FY14B 163 162 164 161 165 167 164 146 168 182 171 180 166

FY14A 164 170 147 179 151 180 209 193 174

140

150

160

170

180

190

200

210

220

MHP Admits Per Thousand

Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May JunFYEAVG

FY13A 678 669 672 655 645 613 655 553 548 557 544 640 619

FY14B 597 594 590 602 601 599 612 620 627 634 642 648 614

FY14A 562 569 517 627 533 636 750 746 617

500

550

600

650

700

750

800

MHP Days Per Thousand

Page 16

J A S O N D J F M A M J FYE AVG

FY13A 95.07% 87.13% 84.42% 90.55% 86.78% 87.38% 88.97% 88.40% 85.32% 87.13% 85.89% 74.52% 86.80%

FY14B 89.74% 89.69% 89.57% 91.75% 91.76% 91.76% 91.67% 91.61% 91.56% 91.51% 91.46% 91.42% 91.13%

FY14A 87.66% 88.17% 87.67% 90.65% 91.94% 87.38% 93.48% 93.67% 90.08%

70.00%

75.00%

80.00%

85.00%

90.00%

95.00%

100.00%

MHP Medical Loss Ratio

Jul (A) Aug (A) Sep (A) Oct (A) Nov (A) Dec (A) Jan (A) Feb (A) Mar (A) Apr (A) May (A) Jun (A) YTD

Revenues 10,823 11,037 10,586 11,119 14,086 11,608 16,555 20,822 106,636

Net Med Expense 9,225 9,442 9,024 9,825 12,699 9,885 15,080 19,057 94,237

Admin Exp 1,512 1,525 1,489 1,156 1,186 1,174 1,756 2,057 11,856

Net Income 86 69 72 138 201 549 (281) (291) 543

(2,500)

0

2,500

5,000

7,500

10,000

12,500

15,000

17,500

20,000

22,500

MHP Revenues, Net Medical Expenses, Administration Expenses and Net Income (A)ctual (000's)

Page 17

Rating

Actual Actual Actual Actual - YTD Budget Agency

June 30, 2011 June 30, 2012 June 30, 2013 June 30, 2014 FY2014 Averages

LIQUIDITY:

Total Cash and Investments $130.4M $104.2M $146.7M $118.9M $183.7M

Total Days Cash on Hand 75.1 62.4 85.4 64.8 97.8 115.4

Maricopa Medical Center 80.7 63.7 91.3 51.4 108.0

Maricopa Health Plan 62.1 58.9 64.6 103.3 73.0

Maricopa Care Advantage 0.0 0.0 0.0 57.3

Days in Accounts Receivable (Hospital only) 58.0 47.0 53.0 74.0 44.0 43.9

Cushion Ratio 23.6 30.9 47.5 35.8 46.7 9.1

Cash to Debt 651.2% 501.4% 720.0% 552.6% 785.5% 77.9%

CAPITAL STRUCTURE:

EBITDA Debt Service Coverage 8.3 11.6 11.9 2.1 6.0 2.6

Debt to Net Assets 12.4% 12.4% 11.0% 12.4% 12.4% 53.1%

PROFITABILITY:

Operating Margin -5.3% -7.8% -7.8% -12.9% -11.0% 1.3%

EBITDA Margin 7.3% 6.6% 6.1% 1.7% 3.4% 9.4%

Excess Margin 4.7% 3.4% 2.5% -1.9% -0.2% 2.3%

Financial Indicators - Consolidated

Page 18

($ 000'S)

Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr. Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr.

Gross Patient Revenue 140,972 138,356 150,870 143,899 138,735 1,139,920 1,195,316 1,253,616 Adjusted Operating Rev / APD 2,823 2,810 2,266 3,080 2,396 2,680 2,536 2,587

Net Patient Revenue 33,834 33,447 32,629 37,598 29,856 268,929 266,572 264,661

Other Revenue (Operating) 3,104 4,719 3,364 2,835 3,067 34,908 34,903 29,052 Adjusted Operating Exp / APD 3,140 3,338 2,860 3,139 3,138 3,092 3,004 2,961

Actual Operating Revenue 36,937 38,166 35,993 40,432 32,923 303,838 301,475 293,713

Less: Allocated Ancillary Rev (11,012) (10,362) (11,670) (11,316) (10,345) (89,763) (89,176) (87,971) Adjusted Oper Margin / APD (318) (527) (594) (58) (743) (412) (468) (374)

Less: Allocated Overhead Rev (776) (1,202) (776) (570) (784) (8,583) (9,314) (7,745)

Adjusted Operating Revenue 25,150 26,601 23,547 28,546 21,793 205,491 202,985 197,997 Actual Labor / APD 1,473 1,574 1,425 1,444 1,497 1,499 1,447 1,458

Actual Operating Expenses 32,302 36,126 33,966 33,169 32,771 271,326 275,671 258,988 Actual Supplies / APD 455 512 487 500 444 502 440 469

Less: Allocated Ancillary Exp (859) (861) (900) (789) (844) (6,847) (7,209) (6,824)

Less: Allocated Overhead Exp (3,460) (3,673) (3,347) (3,295) (3,376) (27,371) (27,988) (25,539)

Adjusted Operating Expenses 27,983 31,592 29,719 29,086 28,552 237,108 240,474 226,625

Actual Oper. Margin + Ancillaries (5,517) (7,462) (8,743) (3,264) (9,349) (50,405) (56,163) (46,422) (All Excluding Normal Newborns) Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr.

% of Net Revenue (21.3%) (26.8%) (35.9%) (11.2%) (41.4%) (23.5%) (26.5%) (22.6%)

AHCCCS Total

Adjusted Operating Margin (2,833) (4,991) (6,172) (540) (6,758) (31,617) (37,488) (28,627) Cases Assigned DRG 319 272 338 321 2,096 2,612

% of Net Revenue (11.3%) (18.8%) (26.2%) (1.9%) (31.0%) (15.4%) (18.5%) (14.5%) Assigned Case Mix 1.19 1.44 1.48 1.63 1.50 1.45

AHCCCS Surgical and Medical

Cases Assigned DRG 313 259 317 315 2,002 2,510

Assigned Case Mix 1.13 1.41 1.38 1.56 1.40 1.40

Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr.

Payroll FTEs 2,543 2,501 2,548 2,568 2,660 2,548 2,654 2,493 AHCCCS Burn

Contract FTEs 74 64 47 50 24 47 24 86 Cases Assigned DRG 6 13 21 6 94 102

Actual Total Paid FTEs 2,617 2,565 2,596 2,618 2,685 2,595 2,678 2,579 Assigned Case Mix 4.33 1.89 2.94 5.53 3.50 2.72

Less: Allocated Overhead FTEs (320) (299) (302) (299) (299) (305) (298) (306)

Adjusted Total Paid FTEs 2,297 2,265 2,294 2,319 2,386 2,291 2,380 2,274 AHCCCS Surgical

Cases Assigned DRG 43 44 56 62 339 419

OT % of Productive Worked Hrs 2.7% 2.3% 1.8% 2.3% 2.0% 2.2% 2.0% 3.3% Assigned Case Mix 1.59 1.77 2.06 2.81 2.21 2.58

Benefit % of Salary 33.6% 28.0% 22.7% 34.0% 33.9% 27.8% 30.7% 29.9% AHCCCS Medical


Actual Paid FTE / AOB 8.2 8.4 7.7 7.9 8.3 8.2 8.1 8.2 Assigned Case Mix 1.05 1.34 1.24 1.25 1.24 1.16

Actual Paid FTE / AOB w/o Residents 7.5 7.7 7.1 7.2 7.6 7.5 7.4 7.5

Adjusted Paid FTE / AOB 7.2 7.4 6.8 7.0 7.3 7.3 7.2 7.2

Adjusted Paid FTE / AOB w/o Residents 6.5 6.7 6.2 6.3 6.6 6.5 6.5 6.5


AHCCCS Non MHP 33.6% 33.2% 33.7% 34.6% 34.0% 31.3% 34.0% 33.6%

AHCCCS - MHP 8.6% 9.4% 10.9% 12.5% 10.0% 9.3% 10.0% 9.2%

Medicare 4.0% 5.1% 4.2% 4.5% 4.7% 4.5% 4.7% 4.6%

Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr. Medicare Risk 5.2% 1.9% 3.4% 3.7% 4.1% 3.7% 4.1% 3.8%

Admissions 1,129 1,155 1,250 1,088 1,112 8,946 9,837 9,283 HMO/PPO 6.7% 5.2% 5.3% 4.8% 6.4% 5.3% 6.4% 6.6%

Admits to OBS 341 458 519 483 351 3,624 2,873 2,809 Commercial 0.9% 0.9% 1.1% 0.8% 0.9% 1.1% 0.9% 0.8%

Self pay 23.8% 21.5% 20.7% 20.7% 19.2% 24.3% 19.2% 21.7%

Patient Days 5,033 5,619 6,071 5,435 5,450 44,120 48,300 44,756 Other 17.2% 22.8% 20.8% 18.4% 20.7% 20.5% 20.7% 19.7%

Adjusted Patient Days 8,910 9,465 10,391 9,267 9,097 76,673 80,057 76,530

Observation Days 420 518 555 524 542 4,191 4,411 3,039

Average Daily Census 180 181 196 194 195 182 199 184 Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr.

Average Length of Stay (ALOS) 4.5 4.9 4.9 5.0 4.9 4.9 4.9 4.8 AHCCCS Non MHP 25.6% 23.6% 26.5% 26.6% 28.3% 23.7% 28.3% 25.1%

AHCCCS - MHP 10.4% 9.6% 11.2% 11.5% 11.9% 9.8% 11.9% 10.9%

Medicare 7.6% 6.0% 6.1% 5.9% 8.3% 6.4% 8.3% 9.1%

Medicare Risk 4.8% 4.4% 4.4% 4.5% 4.9% 4.7% 4.9% 5.0%

($ 000'S) HMO/PPO 8.9% 7.6% 7.0% 6.6% 8.4% 7.3% 8.4% 8.5%

Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr. Commercial 0.5% 1.3% 0.9% 1.3% 0.7% 1.2% 0.7% 0.7%

Self pay 34.9% 37.5% 34.2% 32.5% 29.6% 37.6% 29.6% 32.8%

Non-Operating Revenue 4,867 5,343 4,949 5,241 5,248 40,956 41,987 38,684 Other 7.3% 10.0% 9.7% 10.9% 7.9% 9.4% 7.9% 7.8%

Non-Operating Expense 25 44 43 42 43 2,277 1,996 2,146


Maricopa Medical Center Acute Dashboard

February 2014

FINANCIAL INFORMATION

Monthly Year to Date

NON-OPERATING REVENUE & EXPENSE INFORMATION


PERFORMANCE MEASURES


CASE MIX INDEX - AHCCCS


PAYOR MIX - INPATIENT

FTE INFORMATION


STATISTICAL INFORMATION



PAYOR MIX - OUTPATIENT


Page 19

($ 000'S)


Gross Patient Revenue 9,266 8,892 9,297 8,408 8,358 71,386 72,810 80,759 Adjusted Operating Rev / APD 727 660 693 731 744 730 767 758

Net Patient Revenue 930 327 897 883 964 6,308 8,390 8,481

Other Revenue (Operating) 5 5 6 5 5 47 39 39 Adjusted Operating Exp / APD 835 939 826 846 861 867 848 797

Actual Operating Revenue 935 332 903 888 968 6,355 8,430 8,520

plus: Allocated Ancillary Rev 2,272 2,680 2,516 2,466 2,341 20,536 20,397 20,218 Adjusted Oper Margin / APD (108) (279) (133) (114) (117) (137) (81) (39)

plus: Allocated Overhead Rev 311 406 328 223 301 3,394 3,575 3,250

Adjusted Operating Revenue 3,518 3,417 3,746 3,576 3,611 30,285 32,402 31,988 Actual Labor / APD 362 406 370 385 370 382 370 363

Actual Operating Expenses 2,638 3,147 2,978 2,728 2,716 23,762 23,502 22,178 Actual Supplies / APD 28 34 32 33 31 32 31 28

plus: Allocated Ancillary Exp 219 265 225 209 242 1,921 2,086 1,947

plus: Allocated Overhead Exp 1,183 1,450 1,259 1,198 1,220 10,268 10,238 9,508

Adjusted Operating Expenses 4,040 4,862 4,462 4,135 4,177 35,951 35,826 33,633

Actual Oper. Margin + Ancillaries 350 (400) 216 416 352 1,207 3,239 4,614 Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr.

% of Net Revenue 10.9% (13.3%) 6.3% 12.4% 10.6% 4.5% 11.2% 16.1%


Adjusted Operating Margin (522) (1,445) (716) (559) (566) (5,666) (3,423) (1,645) Assigned Case Mix 0.93 0.96 0.97 0.97 0.94 0.90

% of Net Revenue (14.8%) (42.3%) (19.1%) (15.6%) (15.7%) (18.7%) (10.6%) (5.1%)


Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr. AHCCCS Non MHP 3.4% 1.2% 1.7% 0.0% 1.0% 0.7% 1.0% 0.7%

Payroll FTEs 386 407 397 403 401 401 403 391 AHCCCS - MHP 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Contract FTEs 7 3 4 3 3 4 3 8 Agency (RBHA) 32.2% 37.9% 49.3% 52.6% 48.0% 42.9% 48.0% 45.4%

Actual Total Paid FTEs 393 410 401 406 404 405 406 399 Medicare 19.0% 19.6% 17.8% 21.7% 14.8% 17.7% 14.8% 19.0%

plus: Allocated Overhead FTEs 109 118 114 103 3 114 109 114 Medicare Risk 16.2% 13.3% 9.2% 9.4% 9.4% 12.3% 9.4% 10.5%

Adjusted Total Paid FTEs 503 529 515 509 407 520 515 513 HMO/PPO 10.6% 15.7% 13.6% 4.0% 14.7% 11.1% 14.7% 13.2%

Commercial 2.7% 0.0% 2.1% 1.9% 1.6% 3.3% 1.6% 1.4%

OT % of Productive Worked Hrs 3.6% 7.4% 3.8% 7.7% 3.7% 5.7% 3.7% 5.5% Self pay 15.6% 12.4% 6.4% 11.2% 10.4% 11.9% 10.4% 9.7%

Other 0.4% 0.0% 0.0% 0.0% 0.1% 0.0% 0.1% 0.1%

Benefit % of Salary 30.3% 29.3% 27.1% 31.3% 29.3% 30.0% 29.0% 28.5%

Actual Paid FTE / AOB 2.3 2.5 2.3 2.3 2.3 2.4 2.3 2.3

Adjusted Paid FTE / AOB 2.9 3.2 3.0 2.9 2.3 3.0 3.0 3.0

Year to Date


Admissions 257 297 326 264 256 2,449 2,401 2,389

Patient Days 4,795 5,116 5,341 4,841 4,800 41,037 41,872 41,818

Adjusted Patient Days 4,838 5,179 5,402 4,890 4,851 41,484 42,260 42,189

Average Daily Census 171 165 172 173 171 169 172 172

Average Length of Stay (ALOS) 18.7 17.2 16.4 18.3 18.7 16.8 17.4 17.5

($ 000'S)


Non-Operating Revenue 296 296 296 296 296 2,365 2,369 2,365

Non-Operating Expense 3 2 2 2 2 18 18 27

Year to Date


Behavioral Health Dashboard

February 2014






CASE MIX INDEX - PSYCHIATRY


PAYOR MIX - INPATIENT BY DAYS

MonthlyFTE INFORMATION



Monthly


Page 20

($ 000'S)


Gross Patient Revenue 8,279 3,212 3,794 4,100 3,215 29,128 27,834 69,908

Net Patient Revenue (2,680) (946) (2,948) (2,790) (2,171) (17,901) (15,564) (16,269) Visits 15,058 14,680 17,208 16,369 14,966 130,247 129,582 123,099

Other Revenue (Operating) 886 1,396 1,354 1,213 1,238 10,169 10,739 7,538

Actual Operating Revenue (1,794) 449 (1,593) (1,578) (934) (7,732) (4,825) (8,732) Average Visits / Session 7.8 7.4 7.7 7.7 8.4 7.6 8.4 7.7

plus: Allocated Ancillary Rev 3,755 3,547 4,035 4,211 3,660 32,150 31,675 30,138

plus: Allocated Overhead Rev 140 465 234 175 248 2,672 2,922 1,947 Average Visits / Working Day 793 699 819 862 788 785 781 746

Adjusted Operating Revenue 2,101 4,462 2,676 2,809 2,975 27,089 29,772 23,353

Actual Operating Expenses 2,654 2,368 2,460 2,482 2,463 19,777 20,637 18,584


plus: Allocated Overhead Exp 1,190 1,102 1,050 1,101 1,101 8,604 8,970 8,018 Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr.

Adjusted Operating Expenses 4,067 3,695 3,721 3,800 3,772 30,125 31,388 28,361 Adjusted Operating Rev / Visit 140 304 156 172 199 208 230 190

Actual Oper. Margin + Ancillaries (916) 1,404 (229) (65) 57 2,896 4,432 1,063 Adjusted Operating Exp / Visit 270 252 216 232 252 231 242 230

% of Net Revenue (46.7%) 35.1% (9.4%) (2.5%) 2.1% 11.9% 16.5% 5.0%

Adjusted Oper Margin / Visit (131) 52 (61) (61) (53) (23) (12) (41)

Adjusted Operating Margin (1,966) 767 (1,045) (991) (796) (3,036) (1,616) (5,009)

% of Net Revenue (93.5%) 17.2% (39.0%) (35.3%) (26.8%) (11.2%) (5.4%) (21.4%) Actual Labor / Visit 55 63 51 49 57 54 57 54

Actual Supplies / Visit 17.1 8.9 6.7 8.8 8.2 7.6 8.1 7.7


Payroll FTEs 236 234 228 232 248 234 246 226

Contract FTEs 1 0 0 0 0 0 0 0 Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr.

Actual Total Paid FTEs 238 234 228 232 248 234 246 226 AHCCCS Non MHP 24.7% 22.6% 26.4% 26.3% 28.6% 24.0% 28.6% 25.7%

plus: Allocated Overhead FTEs 110 90 95 100 98 96 96 96 AHCCCS - MHP 14.9% 11.9% 14.5% 16.2% 17.4% 13.3% 17.4% 16.4%

Adjusted Total Paid FTEs 348 324 323 332 345 329 342 322 Agency (RBHA) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Medicare 5.7% 5.8% 5.8% 5.6% 6.0% 5.7% 6.0% 6.2%

OT % of Productive Worked Hrs 1.9% 1.7% 1.4% 1.8% 1.3% 1.8% 1.3% 1.4% Medicare Risk 6.6% 6.9% 7.4% 6.9% 6.6% 6.8% 6.6% 6.5%

HMO/PPO 7.3% 6.4% 6.3% 6.7% 6.8% 6.2% 6.8% 6.8%

Benefit % of Salary 37.5% 31.0% 29.4% 39.7% 35.4% 35.5% 34.9% 33.5% Commercial 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1%

Self pay 36.6% 42.3% 36.1% 34.9% 30.3% 39.6% 30.3% 34.2%

Actual Worked Hours / Visit 2.25 2.40 1.84 2.01 2.24 2.15 2.24 2.18 Other 4.1% 4.1% 3.4% 3.2% 4.2% 4.2% 4.2% 4.1%

Adjusted Worked Hours / Visit 3.32 3.41 2.77 2.94 3.25 3.11 3.23 3.16

($ 000'S)


Non-Operating Revenue 0 0 0 0 0 0 0 0



Family Health Centers Dashboard

February 2014





FTE INFORMATION






PAYOR MIX - BY CASES


Page 21

($ 000'S)



Net Patient Revenue (2,229) (2,081) (3,604) (2,773) (2,491) (21,596) (19,710) (18,613) Visits 12,205 11,492 13,047 12,965 11,893 102,826 100,190 99,898

Other Revenue (Operating) 372 399 380 367 324 2,932 2,828 3,143

Actual Operating Revenue (1,857) (1,682) (3,224) (2,407) (2,167) (18,664) (16,882) (15,470)

plus: Allocated Ancillary Rev 4,736 3,910 4,797 4,276 4,133 35,014 35,266 35,789

plus: Allocated Overhead Rev 257 270 151 124 179 1,892 2,152 2,085 Average Visits / Working Day 642 547 621 682 626 619 604 605

Adjusted Operating Revenue 3,137 2,498 1,724 1,994 2,146 18,242 20,536 22,404

Actual Operating Expenses 1,549 1,608 1,530 1,463 1,538 12,822 13,009 12,255


plus: Allocated Overhead Exp 806 834 776 735 790 6,339 6,482 6,000 Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr.

Adjusted Operating Expenses 2,755 2,797 2,750 2,536 2,706 22,195 22,683 21,223 Adjusted Operating Rev / Visit 257 217 132 154 180 177 205 224

Actual Oper. Margin + Ancillaries 931 266 (400) 68 51 493 2,183 5,096 Adjusted Operating Exp / Visit 226 243 211 196 228 216 226 212

% of Net Revenue 32.3% 11.9% (25.4%) 3.6% 2.6% 3.0% 11.9% 25.1%

Adjusted Oper Margin / Visit 31 (26) (79) (42) (47) (38) (21) 12

Adjusted Operating Margin 382 (299) (1,025) (543) (560) (3,954) (2,146) 1,181

% of Net Revenue 12.2% (12.0%) (59.5%) (27.2%) (26.1%) (21.7%) (10.5%) 5.3% Actual Labor / Visit 63 79 66 57 67 67 69 65



Payroll FTEs 203 213 205 206 211 210 211 198





Medicare 6.2% 5.1% 5.4% 5.6% 6.2% 5.6% 6.2% 6.2%


HMO/PPO 7.0% 6.7% 6.9% 6.8% 7.2% 6.7% 7.2% 7.4%


Self pay 38.5% 43.9% 40.1% 38.3% 36.0% 42.1% 36.0% 37.0%



($ 000'S)





Comprehensive Health Center Dashboard

February 2014





FTE INFORMATION








Page 22

($ 000'S)


Gross Patient Revenue 2,163 828 988 1,039 787 7,186 6,880 13,861

Net Patient Revenue 171 (42) (38) (95) 47 446 1,001 518 Visits 2,711 2,183 2,386 2,303 1,960 17,727 17,127 16,901

Other Revenue (Operating) 143 145 154 140 127 1,017 1,113 879

Actual Operating Revenue 314 103 116 45 175 1,463 2,114 1,398

plus: Allocated Ancillary Rev 248 226 322 363 210 2,064 1,838 1,827

plus: Allocated Overhead Rev 43 31 42 27 35 373 417 277 Average Visits / Working Day 143 104 114 121 103 107 103 102

Adjusted Operating Revenue 605 360 480 435 420 3,900 4,369 3,501

Actual Operating Expenses 309 341 321 292 271 2,621 2,572 2,445

plus: Allocated Ancillary Exp 19 17 21 24 17 147 150 150

plus: Allocated Overhead Exp 135 152 134 129 119 1,107 1,089 1,023 Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr.

Adjusted Operating Expenses 463 511 476 444 408 3,875 3,811 3,618 Adjusted Operating Rev / Visit 223 165 201 189 214 220 255 207

Actual Oper. Margin + Ancillaries 235 (30) 97 92 96 759 1,230 629 Adjusted Operating Exp / Visit 171 234 199 193 208 219 223 214

% of Net Revenue 41.8% (9.0%) 22.1% 22.7% 25.0% 21.5% 31.1% 19.5%

Adjusted Oper Margin / Visit 53 (69) 2 (4) 6 1 33 (7)

Adjusted Operating Margin 142 (150) 5 (9) 12 25 558 (117)

% of Net Revenue 23.5% (41.8%) 1.0% (2.1%) 2.9% 0.6% 12.8% (3.3%) Actual Labor / Visit 40 56 55 50 52 54 52 53



Payroll FTEs 22 22 24 22 21 22 21 21





Medicare 2.5% 2.6% 1.3% 2.8% 2.1% 2.0% 2.1% 2.2%


HMO/PPO 6.0% 6.0% 4.7% 5.0% 6.9% 5.0% 6.9% 7.3%


Self pay 48.7% 49.7% 51.3% 48.8% 42.6% 52.4% 42.6% 45.9%



($ 000'S)





7th Avenue Walk-In Clinic Dashboard

February 2014





FTE INFORMATION








Page 23

($ 000'S)


Gross Patient Revenue 502 494 471 736 464 4,265 4,050 3,840

Net Patient Revenue 286 251 140 252 147 2,042 1,956 1,918 Visits 1,894 1,854 1,877 2,693 1,818 16,746 15,876 14,684

Other Revenue (Operating) 68 71 76 72 81 554 710 587

Actual Operating Revenue 354 322 217 324 228 2,596 2,666 2,505 Avg Visits / 8-Hour Provider Day 10.7 10.9 10.8 11.6 12.0 10.7 12.0 10.6

plus: Allocated Ancillary Rev 0 0 0 0 0 0 0 0

plus: Allocated Overhead Rev 24 30 21 22 21 252 247 186 Average Visits / Working Day 100 88 89 142 96 101 96 89


Actual Operating Expenses 350 315 322 327 351 2,636 3,024 2,511


plus: Allocated Overhead Exp 145 134 127 133 145 1,054 1,210 990 Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr.

Adjusted Operating Expenses 495 449 449 460 496 3,689 4,233 3,500 Adjusted Operating Rev / Visit 200 190 127 128 137 170 183 183

Actual Oper. Margin + Ancillaries 4 7 (105) (3) (123) (40) (357) (6) Adjusted Operating Exp / Visit 261 242 239 171 273 220 267 238

% of Net Revenue 1.2% 2.0% (48.6%) (0.8%) (54.1%) (1.5%) (13.4%) (0.2%)

Adjusted Oper Margin / Visit (61) (53) (113) (42) (136) (50) (83) (55)

Adjusted Operating Margin (116) (97) (211) (114) (247) (842) (1,320) (809)

% of Net Revenue (30.7%) (27.7%) (88.9%) (33.1%) (99.5%) (29.6%) (45.3%) (30.1%) Actual Labor / Visit 119 130 127 80 134 110 133 117

Actual Supplies / Visit 17 9 12 9 14 12 14 15


Payroll FTEs 39 36 35 37 45 36 45 38





Medicare 0.2% 0.1% -0.1% 0.1% 0.0% 0.0% 0.0% 0.7%


HMO/PPO 8.3% 9.4% 9.9% 8.8% 9.4% 8.7% 9.4% 10.1%


Self pay 57.6% 61.1% 57.5% 56.3% 57.4% 58.6% 57.3% 55.1%

Actual Worked Hours / Visit 2.91 3.07 2.76 2.02 3.45 2.60 3.41 3.17 Grants 8.2% 5.7% 6.0% 8.9% 6.8% 7.2% 7.0% 6.9%

Other 0.6% 1.5% 0.9% 0.9% 0.7% 1.0% 0.6% 0.4%


($ 000'S)





Dental Clinics Dashboard

February 2014





FTE INFORMATION






PAYOR MIX - BY VISITS


Page 24

($ 000'S)



Net Patient Revenue 663 1,084 1,328 522 810 6,659 6,860 7,139 Attendant Care Hours 59,195 65,902 66,745 60,152 60,922 511,155 516,174 516,513

Other Revenue (Operating) 0 0 0 0 0 0 0 0

Actual Operating Revenue 663 1,084 1,328 522 810 6,659 6,860 7,139

plus: Allocated Ancillary Rev 0 0 0 0 0 0 0 0

plus: Allocated Overhead Rev 0 0 0 0 0 0 0 0

Adjusted Operating Revenue 663 1,084 1,328 522 810 6,659 6,860 7,139 Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr.

Adjust Operating Rev / Care Hour 11.2 16.4 19.9 8.7 13.3 13.0 13.3 13.8

Actual Operating Expenses 917 1,002 1,283 975 981 8,245 8,328 7,881

plus: Allocated Ancillary Exp 0 0 0 0 0 0 0 0 Adjust Operating Exp / Care Hour 15.5 15.2 19.2 16.2 16.1 16.1 16.1 15.3

plus: Allocated Overhead Exp 0 0 0 0 0 0 0 0

Adjusted Operating Expenses 917 1,002 1,283 975 981 8,245 8,328 7,881 Adjust Oper Margin / Care Hour (4.3) 1.2 0.7 (7.5) (2.8) (3.1) (2.8) (1.4)

Actual Oper. Margin + Ancillaries (254) 82 45 (453) (171) (1,586) (1,468) (742) Actual Labor / Care Hour 12.6 12.4 12.9 12.6 12.6 12.6 12.6 12.4

% of Net Revenue (38.3%) 7.6% 3.4% (86.7%) (21.1%) (23.8%) (21.4%) (10.4%)

Actual Supplies / Care Hour 0.0 0.0 0.0 0.1 0.0 0.0 0.0 0.0

Adjusted Operating Margin (254) 82 45 (453) (171) (1,586) (1,468) (742)

% of Net Revenue (38.3%) 7.6% 3.4% (86.7%) (21.1%) (23.8%) (21.4%) (10.4%)

($ 000'S)


Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr. Non-Operating Revenue 0 0 0 0 0 0 0 0

Payroll FTEs 396 398 401 402 406 394 397 397 Non-Operating Expense 0 0 0 0 0 0 0 0

Contract FTEs 0 0 0 0 0 0 0 0

Actual Total Paid FTEs 396 398 401 402 406 394 397 397

plus: Allocated Overhead FTEs 0 0 0 0 0 0 0 0

Adjusted Total Paid FTEs 396 398 401 402 406 394 397 397

OT % of Productive Worked Hrs 0.5% 0.4% 0.4% 0.4% 0.4% 0.4% 0.4% 0.5%


Actual Worked Hours / Care Hour 1.05 1.06 1.04 1.05 1.05 1.05 1.05 1.05

Adjusted Worked Hrs / Care Hour 1.05 1.06 1.04 1.05 1.05 1.05 1.05 1.05


Complete Comfort Care Dashboard

February 2014



FTE INFORMATION








Page 25

($ 000'S)


Gross Patient Revenue 566 614 629 634 515 4,714 4,240 4,473 Scripts Processed

Net Patient Revenue 566 614 629 634 515 4,714 4,240 4,473 FHC 23,090 23,877 25,342 23,618 20,495 191,138 181,281 179,445

Other Revenue (Operating) 0 2 1 4 0 10 0 0 CHC 6,306 6,492 6,955 6,164 6,259 52,777 50,731 51,113

Actual Operating Revenue 566 616 630 638 515 4,724 4,240 4,473 Discharge Pharmacy 4,000 4,216 4,882 4,391 4,533 34,651 32,222 31,565

plus: Allocated Ancillary Rev 0 0 0 0 0 0 0 0 Total Scripts Processed 33,396 34,585 37,179 34,173 31,287 278,566 264,234 262,123

plus: Allocated Overhead Rev 0 0 0 0 0 0 0 0


Actual Operating Expenses 453 1,274 754 661 614 5,881 5,240 4,803


plus: Allocated Overhead Exp 0 0 0 0 0 0 0 0 Prior Yr. Dec 2013 Jan 2014 Feb Actual Budget Feb Actual Budget Prior Yr.

Adjusted Operating Expenses 453 1,274 754 661 614 5,881 5,240 4,803 Adjust Operating Rev / Script 17.0 17.8 16.9 18.7 16.5 17.0 16.0 17.1

Actual Oper. Margin + Ancillaries 114 (658) (124) (23) (99) (1,157) (1,000) (331) Adjust Operating Exp / Script 13.6 36.8 20.3 19.3 19.6 21.1 19.8 18.3

% of Net Revenue 20.0% (106.9%) (19.6%) (3.5%) (19.1%) (24.5%) (23.6%) (7.4%)

Adjust Oper Margin / Script 3.4 (19.0) (3.3) (0.7) (3.1) (4.2) (3.8) (1.3)

Adjusted Operating Margin 114 (658) (124) (23) (99) (1,157) (1,000) (331)

% of Net Revenue 20.0% (106.9%) (19.6%) (3.5%) (19.1%) (24.5%) (23.6%) (7.4%) Actual Labor / Script 7.2 7.9 6.8 7.3 8.1 7.3 8.3 7.6

Actual Supplies / Script 3.8 26.8 11.2 8.5 8.9 11.4 8.8 8.5


Payroll FTEs 37 39 38 39 42 38 42 37 ($ 000'S)



plus: Allocated Overhead FTEs 0 0 0 0 0 0 0 0 Non-Operating Revenue 0 0 0 0 0 0 0 0

Adjusted Total Paid FTEs 37 39 38 39 42 38 42 37 Non-Operating Expense 0 0 0 0 0 0 0 0

OT % of Productive Worked Hrs 4.7% 4.5% 4.1% 6.0% 2.7% 5.0% 2.7% 4.1%


Actual Worked Hours / Script 0.16 0.17 0.16 0.16 0.19 0.17 0.19 0.17

Adjusted Worked Hours / Script 0.16 0.17 0.16 0.16 0.19 0.17 0.19 0.17





Outpatient Retail Pharmacy Dashboard

February 2014



FTE INFORMATION





Page 26

($ 000'S)


Operating & NonOperating Revenue 646 707 490 530 545 4,748 4,722 4,700

Operating & NonOperating Expense 708 705 556 603 616 5,166 5,269 5,056

Net Income Margin (62) 2 (66) (72) (72) (418) (547) (356)

% of Revenue (0.10) 0.00 (0.14) (0.14) (0.13) (0.09) (0.12) (0.08)


Payroll FTEs 26 37 34 35 39 35 38 29



OT % of Productive Worked Hrs (0.0%) 0.0% 0.0% (0.0%) 0.0% 0.0% 0.0% 0.0%


FTE INFORMATION



Grant Programs Dashboard

February 2014



Page 27

($ 000'S)


Operating & NonOperating Revenue 100 58 65 164 72 812 579 649

Operating & NonOperating Expense 170 124 125 126 142 1,127 1,200 1,223

Net Income Margin (70) (66) (60) 38 (70) (315) (621) (574)

% of Revenue (0.70) (114.7%) (93.4%) 23.0% (97.0%) (38.8%) (107.1%) (88.5%)


Payroll FTEs 12 12 12 12 13 11 13 12



OT % of Productive Worked Hrs 0.1% 0.2% 0.2% (0.1%) 0.0% 0.3% 0.0% 0.1%


FTE INFORMATION



Research Programs Dashboard

February 2014



Page 28

MARICOPA COUNTY SPECIAL HEALTH CARE DISTRICT

CONSOLIDATED SYSTEMStatement of Revenues, Expenses, and Changes in Net Assets


Current Month YTD

Feb 2014 Feb 2014 Feb 2013 Feb 2014 Feb 2014 Feb 2013

Actual Budget Variance Actual Actual Budget Variance Actual

Operating Revenues

Gross patient revenue 163,460,093$ 156,518,685$ 6,941,408$ 169,573,872$ 1,294,778,743$ 1,348,596,251$ (53,817,508)$ 1,492,113,829$

Total deductions 103,403,105 93,749,590 (9,653,516) 101,312,983 754,780,764 816,927,172 62,146,407 866,364,039

Patient service revenue 60,056,988 62,769,096 (2,712,108) 68,260,888 539,997,978 531,669,079 8,328,899 625,749,790

Safety net care pool revenue 0 0 0 4,635,287 28,943,175 27,708,592 1,234,583 37,082,296

Self-pay and bad debt deductions 25,826,105 35,092,410 9,266,305 41,354,892 319,340,771 305,632,532 (13,708,238) 410,525,053

Net patient service revenue 34,230,883 27,676,686 6,554,197 31,541,283 249,600,383 253,745,139 (4,144,757) 252,307,033

Other revenue 26,019,916 18,943,616 7,076,300 16,063,927 158,000,100 148,662,138 9,337,962 138,141,823

Total operating revenues 60,250,799 46,620,302 13,630,497 47,605,211 407,600,483 402,407,277 5,193,206 390,448,856

Operating Expenses

Salaries and wages 18,107,224 18,302,344 195,120 17,522,410 155,026,150 156,334,047 1,307,896 147,451,831

Contract labor 237,503 395,116 157,613 494,294 2,978,924 3,390,564 411,641 5,679,924

Employee benefits 6,097,159 5,978,206 (118,953) 5,771,721 43,922,502 47,390,812 3,468,310 43,392,940

Medical service fees 5,911,918 6,122,653 210,735 6,052,685 48,727,989 49,045,431 317,442 44,816,227

Supplies 5,371,069 4,709,520 (661,549) 4,715,133 45,117,258 40,932,379 (4,184,880) 41,416,537

Purchased services 23,794,430 16,221,814 (7,572,616) 13,158,696 123,789,275 114,935,083 (8,854,191) 108,831,037

Other expenses 2,599,659 2,765,695 166,036 3,134,466 23,462,975 24,420,015 957,039 22,227,895

Premium taxes and assessments 1,143,800 301,386 (842,413) 229,759 2,882,571 2,079,230 (803,340) 1,983,081

Depreciation 1,807,086 2,096,901 289,814 2,085,004 14,340,776 15,991,531 1,650,755 14,103,347

Total operating expenses 65,069,848 56,893,635 (8,176,213) 53,164,169 460,248,420 454,519,092 (5,729,328) 429,902,817

Operating Income (4,819,049) (10,273,333) 5,454,284 (5,558,958) (52,647,937) (52,111,815) (536,123) (39,453,962)

Nonoperating Revenues (Expenses)

Noncapital grants 1,276,428 985,106 291,322 645,305 5,446,977 5,270,444 176,532 4,558,301

Noncapital transfers from County 295,658 295,658 0 295,658 2,365,264 2,365,264 0 2,365,264

Investment income 24,038 53,555 (29,517) 44,978 252,651 415,323 (162,672) 325,502

Other nonoperating revenue (expenses) (169,093) 3,941 (173,034) 8,047 (778,234) 33,927 (812,161) (16,945)

Noncapital grants related expenses (208,139) (219,604) 11,465 (257,144) (1,805,305) (1,905,848) 100,543 (1,727,711)

Interest expense (48,594) (44,825) (3,769) (28,029) (369,365) (373,926) 4,562 (254,417)

Kidscare expense 0 0 0 0 (1,950,490) (1,640,000) (310,490) (1,918,332)

Tax levy 5,208,262 5,208,262 0 4,824,623 41,666,096 41,666,096 0 38,596,980

Total nonoperating revenues (expenses) 6,378,560 6,282,092 96,468 5,533,438 44,827,594 45,831,280 (1,003,685) 41,928,643

Excess of Revenues Over Expenses

Before Extraordinary Items 1,559,512 (3,991,240) 5,550,752 (25,520) (7,820,343) (6,280,535) (1,539,808) 2,474,682

Extraordinary Item 0 0 0 0 0 0 0 0

Increase in Net Assets 1,559,512 (3,991,240) 5,550,752 (25,520) (7,820,343) (6,280,535) (1,539,808) 2,474,682

Net Assets, Beginning of the Period 262,269,382 271,649,237

Net Assets, End of the Period 263,828,894$ 263,828,894$

Page 29

MARICOPA COUNTY SPECIAL HEALTH CARE DISTRICTCONSOLIDATED SYSTEM

Balance Sheet

February 28, 2014

February 28, 2014 June 30, 2013

Assets

Current Assets

Cash and cash equivalents

General funds

Delivery system 50,230,630$ 103,557,526$

Health Plans 19,748,714 19,356,070

Total cash and cash equivalents - general funds 69,979,344 122,913,596

Board designated for future obligations

Delivery system 20,550,731 20,968,375

Health Plans 28,370,401 5,137,232

Total cash and cash equivalents - board designated 48,921,132 26,105,607

Patient A/R, net of allowances 75,501,843 53,393,900

Other receivables and prepaid items 15,490,297 15,578,243

Estimated amounts due from third-party payors 70,314,768 44,483,790

Due from related parties 5,273,943 182,647



Other Assets 4,386,429 5,000,000

Total assets 423,624,805$ 393,102,037$


Current Liabilities

Current maturities of long-term debt 3,201,361$ 2,549,372$

Accounts payable 47,796,402 41,310,305

Accrued payroll and expenses 21,392,511 20,074,547

Medical claims payable 28,157,196 13,444,990

Other current liabilities 37,432,578 23,695,418


Long-term Debt 21,515,724 20,378,170


Net Assets

Invested in capital assets, net of related debt 112,241,325 105,066,084

Unrestricted 151,887,707 166,583,151

Total net assets 264,129,032 271,649,236


Page 30


d/b/a CONSOLIDATED SYSTEM

Cash Flow Statement

February 28, 2014

($ in 000's)

Current Year to

Month Date

Operating Income (Loss) ($4,819) ($52,648)

Non-Operating Income 6,379 44,827

Net Income (Loss) 1,560 (7,821)

Add: Depreciation 1,807 14,340

Less: Changes in Assets and Liabilities (10,902) (13,984)

Net cash from operations (7,535) (7,465)

Cash spent on capital (4,919) (22,654)

Cash - All Other - -

Net increase (decrease) in cash ($12,454) ($30,119)

Beginning Cash Balance 131,354 149,019

Ending Cash Balance - February 28, 2014 $118,900 $118,900

Page 31


d/b/a MARICOPA MEDICAL CENTERStatement of Revenues, Expenses, and Changes in Net Assets


Current Month YTD



Operating Revenues

Gross patient revenue 163,460,093$ 156,518,685$ 6,941,408$ 169,573,872$ 1,294,778,743$ 1,348,596,251$ (53,817,508)$ 1,492,113,829$

Total deductions 103,403,105 93,749,590 (9,653,516) 101,312,983 754,780,764 816,927,172 62,146,407 866,364,039

Patient service revenue 60,056,988 62,769,096 (2,712,108) 68,260,888 539,997,978 531,669,079 8,328,899 625,749,790

Safety net care pool revenue 0 0 0 4,635,287 28,943,175 27,708,592 1,234,583 37,082,296

Self-pay and bad debt deductions 25,826,105 35,092,410 9,266,305 41,354,892 319,340,771 305,632,532 (13,708,238) 410,525,053

Net patient service revenue 34,230,883 27,676,686 6,554,197 31,541,283 249,600,383 253,745,139 (4,144,757) 252,307,033

Other revenue 4,228,882 4,470,240 (241,358) 4,677,157 49,637,680 50,332,777 (695,097) 41,889,739

Total operating revenues 38,459,765 32,146,926 6,312,839 36,218,441 299,238,063 304,077,916 (4,839,853) 294,196,772

Operating Expenses

Salaries and wages 18,107,224 18,302,344 195,120 17,522,410 155,026,150 156,334,047 1,307,896 147,451,831

Contract labor 237,503 395,116 157,613 494,294 2,978,924 3,390,564 411,641 5,679,924

Employee benefits 6,097,159 5,978,206 (118,953) 5,771,721 43,922,502 47,390,812 3,468,310 43,392,940

Medical service fees 5,911,918 6,122,653 210,735 6,052,685 48,727,989 49,045,431 317,442 44,816,227

Supplies 5,371,069 4,709,520 (661,549) 4,715,133 45,117,258 40,932,379 (4,184,880) 41,416,537

Purchased services 1,731,439 1,869,029 137,590 2,016,197 17,254,668 19,002,668 1,748,001 15,095,957

Other expenses 2,599,659 2,765,695 166,036 3,134,466 23,462,975 24,420,015 957,039 22,227,895

Premium taxes and assessments 716,462 4,396 (712,065) 0 727,685 38,155 (689,529) 11,477

Depreciation 1,807,086 2,096,901 289,814 2,085,004 14,340,776 15,991,531 1,650,755 14,103,347

Total operating expenses 42,579,519 42,243,860 (335,659) 41,791,911 351,558,927 356,545,602 4,986,675 334,196,133

Operating Income (4,119,754) (10,096,934) 5,977,180 (5,573,470) (52,320,864) (52,467,686) 146,821 (39,999,362)


Noncapital grants 1,276,428 985,106 291,322 645,305 5,446,977 5,270,444 176,532 4,558,301

Noncapital transfers from County 295,658 295,658 0 295,658 2,365,264 2,365,264 0 2,365,264

Investment income 24,038 39,996 (15,958) 34,778 180,651 320,972 (140,321) 243,948

Other nonoperating revenue (expenses) (169,093) 3,941 (173,034) 8,047 (778,234) 33,927 (812,161) (16,945)

Noncapital grants related expenses (208,139) (219,604) 11,465 (257,144) (1,805,305) (1,905,848) 100,543 (1,727,711)

Interest expense (48,594) (44,825) (3,769) (28,029) (369,365) (373,926) 4,562 (254,417)

Kidscare expense 0 0 0 0 (1,950,490) (1,640,000) (310,490) (1,918,332)

Tax levy 5,208,262 5,208,262 0 4,824,623 41,666,096 41,666,096 0 38,596,980

Total nonoperating revenues (expenses) 6,378,560 6,268,533 110,027 5,523,238 44,755,594 45,736,929 (981,334) 41,847,089


Before Extraordinary Items 2,258,807 (3,828,400) 6,087,207 (50,232) (7,565,270) (6,730,757) (834,513) 1,847,728


Increase in Net Assets 2,258,807 (3,828,400) 6,087,207 (50,232) (7,565,270) (6,730,757) (834,513) 1,847,728



Page 32


Balance Sheet

February 28, 2014

February 28, 2014 June 30, 2013

Assets

Current Assets


General funds

Delivery system 50,728,347$ 103,557,526$

Health Plans 0 0



Delivery system 20,550,731 20,968,375

Health Plans 0 0


Patient A/R, net of allowances 75,501,843 53,393,900

Other receivables and prepaid items 15,490,297 15,578,243


Due from related parties 5,273,943 182,647



Other Assets 4,386,429 5,000,000

Total assets 367,792,361$ 358,732,971$


Current Liabilities

Current maturities of long-term debt 3,201,361$ 2,549,372$


Accrued payroll and expenses 21,392,511 20,074,547

Medical claims payable 0 0

Other current liabilities 33,178,281 23,191,665


Long-term Debt 21,515,724 20,378,170


Net Assets

Invested in capital assets, net of related debt 112,241,325 105,066,084

Unrestricted 132,636,711 147,377,082

Total net assets 244,878,036 252,443,167


Page 33


d/b/a MARICOPA MEDICAL CENTER

Cash Flow Statement

February 28, 2014

($ in 000's)

Current Year to

Month Date

Operating Income (Loss) ($4,120) ($52,320)

Non-Operating Income 6,379 44,755

Net Income (Loss) 2,259 (7,565)

Add: Depreciation 1,807 14,340

Less: Changes in Assets and Liabilities (23,020) (37,368)

Net cash from operations (18,954) (30,593)

Cash spent on capital (4,919) (22,654)


Net increase (decrease) in cash ($23,873) ($53,247)



Page 34


d/b/a MARICOPA HEALTH PLANStatement of Revenues, Expenses, and Changes in Net Assets


Current Month YTD



Operating Revenues

Gross patient revenue 0$ 0$ 0$ 0$ 0$ 0$ 0$ 0$

Total deductions 0 0 0 0 0 0 0 0

Safety net care pool revenue 0 0 0 0 0 0 0 0

Net Patient Service Revenue 0 0 0 0 0 0 0 0

Other revenue 20,822,497 14,209,376 6,613,121 11,386,770 106,564,066 97,825,361 8,738,705 96,252,084

Total operating revenues 20,822,497 14,209,376 6,613,121 11,386,770 106,564,066 97,825,361 8,738,705 96,252,084

Operating Expenses

Purchased services 20,686,526 13,860,883 (6,825,643) 11,142,499 103,938,536 94,972,875 (8,965,661) 93,735,080

Premium taxes and assessments 427,338 296,990 (130,348) 229,759 2,154,886 2,041,075 (113,811) 1,971,604

Total operating expenses 21,113,864 14,157,873 (6,955,991) 11,372,258 106,093,422 97,013,950 (9,079,472) 95,706,684

Operating Income (291,367) 51,503 (342,870) 14,512 470,644 811,411 (340,767) 545,400


Investment income 0 13,559 (13,559) 10,200 72,000 94,351 (22,351) 81,554

Kidscare expense 0 0 0 0 0 0 0 0

Total nonoperating revenues (expenses) 0 13,559 (13,559) 10,200 72,000 94,351 (22,351) 81,554


Before Extraordinary Items (291,367) 65,062 (356,429) 24,712 542,644 905,762 (363,118) 626,954

Increase in Net Assets (291,367) 65,062 (356,429) 24,712 542,644 905,762 (363,118) 626,954



Page 35

MARICOPA COUNTY SPECIAL HEALTH CARE DISTRICTd/b/a MARICOPA HEALTH PLAN

Balance Sheet

February 28, 2014

February 28, 2014 June 30, 2013

Assets

Current Assets


General funds

Delivery system 0$ 0$

Health Plans 19,748,714 19,356,070



Delivery system 0 0

Health Plans 25,351,656 5,137,232


Patient A/R, net of allowances 0 0

Other receivables and prepaid items 0 0


Due from related parties 0 0


Capital Assets, Net 0 0

Other Assets 0 0

Total assets 53,424,477$ 34,369,066$


Current Liabilities

Current maturities of long-term debt 0$ 0$


Accrued payroll and expenses 0 0

Medical claims payable 27,076,641 13,444,990

Other current liabilities 3,242,540 503,753


Long-term Debt 0 0


Net Assets

Invested in capital assets, net of related debt 0 0

Unrestricted 19,748,713 19,206,069

Total net assets 19,748,713 19,206,069


Page 36


d/b/a MARICOPA HEALTH PLAN

Cash Flow Statement

February 28, 2014

($ in 000's)

Current Year to

Month Date

Operating Income (Loss) ($291) $471

Non-Operating Income - 72

Net Income (Loss) (291) 543

Add: Depreciation - -

Less: Changes in Assets and Liabilities 11,262 20,064

Net cash from operations 10,971 20,607

Cash spent on capital - -


Net increase (decrease) in cash $10,971 $20,607



Page 37


d/b/a MARICOPA CARE ADVANTAGEStatement of Revenues, Expenses, and Changes in Net Assets


Current Month YTD



Operating Revenues

Gross patient revenue 0$ 0$ 0$ 0$ 0$ 0$ 0$ 0$

Total deductions 0 0 0 0 0 0 0 0Patient service revenue 0 0 0 0 0 0 0 0

Safety net care pool revenue 0 0 0 0 0 0 0 0Self-pay and bad debt deductions 0 0 0 0 0 0 0 0Net patient service revenue 0 0 0 0 0 0 0 0

Net Patient Service Revenue 0 0 0 0 0 0 0 0

Other revenue 968,537 264,000 704,537 0 1,798,354 504,000 1,294,354 0

Total operating revenues 968,537 264,000 704,537 0 1,798,354 504,000 1,294,354 0

Operating ExpensesSalaries and wages 0 0 0 0 0 0 0 0Contract labor 0 0 0 0 0 0 0 0Employee benefits 0 0 0 0 0 0 0 0Medical service fees 0 0 0 0 0 0 0 0Supplies 0 0 0 0 0 0 0 0

Purchased services 1,376,465 491,902 (884,563) 0 2,596,071 959,540 (1,636,531) 0Other expenses 0 0 0 0 0 0 0 0

Premium taxes and assessments 0 0 0 0 0 0 0 0Depreciation 0 0 0 0 0 0 0 0

Total operating expenses 1,376,465 491,902 (884,563) 0 2,596,071 959,540 (1,636,531) 0

Operating Income (407,928) (227,902) (180,026) 0 (797,717) (455,540) (342,177) 0

Nonoperating Revenues (Expenses)Noncapital grants 0 0 0 0 0 0 0 0Noncapital transfers from County 0 0 0 0 0 0 0 0

Investment income 0 0 0 0 0 0 0 0Other nonoperating revenue (expenses) 0 0 0 0 0 0 0 0Noncapital grants related expenses 0 0 0 0 0 0 0 0Interest expense 0 0 0 0 0 0 0 0

Kidscare expense 0 0 0 0 0 0 0 0Tax levy 0 0 0 0 0 0 0 0

Total nonoperating revenues (expenses) 0 0 0 0 0 0 0 0


Before Extraordinary Items (407,928) (227,902) (180,026) 0 (797,717) (455,540) (342,177) 0


Increase in Net Assets (407,928) (227,902) (180,026) 0 (797,717) (455,540) (342,177) 0

Net Assets, Beginning of the Period (389,789) 0

Net Assets, End of the Period (797,717)$ (797,717)$

Page 38

MARICOPA COUNTY SPECIAL HEALTH CARE DISTRICTd/b/a MARICOPA CARE ADVANTAGE

Balance Sheet

February 28, 2014

February 28, 2014 June 30, 2013

Assets

Current Assets


General funds

Delivery system (497,717)$ 0$

Health Plans 0 0

Total cash and cash equivalents - general funds (497,717) 0


Delivery system 0 0

Health Plans 3,018,745 0

Total cash and cash equivalents - board designated 3,018,745 0

Patient A/R, net of allowances 0 0

Other receivables and prepaid items 0 0

Estimated amounts due from third-party payors (113,061) 0

Due from related parties 0 0

Total current assets 2,407,967 0

Capital Assets, Net 0 0

Other Assets 0 0

Total assets 2,407,967$ -$


Current Liabilities

Current maturities of long-term debt 0$ 0$

Accounts payable 813,372 0

Accrued payroll and expenses 0 0

Medical claims payable 1,080,555 0

Other current liabilities 1,011,757 0

Total current liabilities 2,905,684 0

Long-term Debt 0 0

Total liabilities 2,905,684 0

Net Assets

Invested in capital assets, net of related debt 0 0

Unrestricted (497,717) 0

Total net assets (497,717) 0

Total liabilities and net assets 2,407,967$ -$

Page 39


d/b/a MARICOPA CARE ADVANTAGE

Cash Flow Statement

February 28, 2014

($ in 000's)

Current Year to

Month Date

Operating Income (Loss) ($408) ($798)

Non-Operating Income - -

Net Income (Loss) (408) (798)

Add: Depreciation - -

Less: Changes in Assets and Liabilities 857 3,319

Net cash from operations 449 2,521

Cash spent on capital - -


Net increase (decrease) in cash $449 $2,521

Beginning Cash Balance 2,072 -


Page 40

Actual Budget Actual Target Raw Score Percentile

Admissions 1,352 1,368 Operating Room Utilization 72% 70% Inpatient (Acute) 85% 51st

Adjusted Patient Days 18,113 17,555 OR Percent on Time Starts (Cut Time) 53% 85% Nursing 87% 45th

Average Length of Stay - Acute 5.0 4.9 OR Percent on Time Starts (In Room Time) 84% 85% Physicians 84% 32nd

Surgery Cases 579 642 Cath Lab Utilization 29% 75% Emergency Dept. 80% 38th

Inpatient 58.5% 62.4% Percent of Inpts on Pathways N/A N/A Ambulatory 90% 16th

Outpatient 41.5% 37.6% FTE/Adj Pt Day w/o residents 5.8 6.2

Occupancy 96% 95% Timely Discharge 48% <120

Average Daily Census 367 366

IP/OP Gross Charge Mix

Inpatient 56.7% 58.4%

Outpatient 43.3% 41.6%

Actual Budget Actual Budget Actual Budget

Total Visits 5,626 5,495 Total Opr Revenue/Adjusted $2,123 $1,831 MHP Revenue PMPM $278 $231

Adult 3,803 3,781 Patient Day MHP Medical Expenses PMPM $255 $207

Peds 1,823 1,713 Supply Cost/Total Operating 12.6% 11.1%

% Converting to Inpatient 12.9% 14.6% Expenses

LWOT 4.1% <3% Labor Cost/Total Operating 43.1% 44.3%

% of IP Sourced in ED 66.9% 72.1% Expenses

ALOS (minutes) 341 <180 Total Cost/Adjusted $2,351 $2,406

Avg Time to Treatment (mins) 35 30 Patient Day

7 Ave Walk-In- Clinic Visits 2,303 1,960

Referred to ED 33 56

Direct Admits 20 21

ED to IP - -

Emergency Department Indicators Financial Indicators (DELIVERY SYSTEM) Financial Indicator (HEALTH PLAN)

Operational Performance Dashboard

Month of Feb 2014

Volume Indicators Efficiency Indicators Patient Satisfaction Indicators

Page 41


Summary of Accounts Receivable Write-offs

Write-offs or Reclass to Bad Debt requiring CEO approval (Greater than $250,000 to $499,999) Approval Required

Month Payer Total Charges Admit Date Discharge Date Moved to Bad Debt Diagnosis CEO Board

Feb-14 None no No

Write-offs or Reclass to Bad Debt requiring Board approval (Greater than $500,000) Approval Required

Month Payer Total charges Admit Date Discharge Date Moved to Bad Debt Diagnosis CEO Board

Feb-14 None no No

Page 42


Collection Agency Results

Quarter ended December 2013

Total Recoveries Collection Expense Net Collection Percentage

Quarter 1 2013 10,901,440$ 1,203,532$ 11.0%

Quarter 2 2013 8,615,227$ 1,026,147$ 11.9%

Quarter 3 2013 7,108,999$ 838,695$ 11.8%

Quarter 4 2013 7,786,866$ 960,514$ 12.3%

Quarter 1 2014 6,920,456$ 847,515$ 12.2%

Quarter 2 2014 7,132,058$ 761,782$ 10.7%

Page 43

Project Description Amount ApprovedDate of Board

Approval

Date of Project

CompletionFirst Review 2nd Review 3rd Review Final Review

Adult Emergency Department 1,200,000 June, 2008 April, 2009 January, 2014

Campus Refresh Projects 5,500,000 June, 2010 2010 - 2011 January, 2014

Labor & Delivery Room Renovations Included in Campus Refresh June, 2010 2010 - 2011 January, 2014

Pediatric Emergency Department 4,890,000 August, 2010 March, 2012 January, 2014

Electronic Medical Record 66,800,000 August, 2008 multi year March, 2014 March, 2015 March, 2016

McDowell Clinic Relocation 900,000 August, 2012 September, 2013 January, 2014 October, 2014 October, 2015

MRI Imaging Facility 5,162,000 January, 2013 March, 2014 July, 2014 July, 2015 July, 2016

Nursing 4 East and 5 West Remodel 2,050,000 January, 2013 2014 July, 2014 July, 2015 July, 2016

Wound Clinic 2,111,000 January, 2013 2014

Enterprise Application Suite 12,870,000 June, 2013 2014

ICD - 10 Implementation 5,081,687 June, 2013 October, 2014 January, 2015 November, 2015 November, 2016


dba Maricopa Integrated Health System

Project - Post Implementation Review and Update Schedule

February, 2014

Key Dates

Page 44

Maricopa County



March 26, 2014

Item 9. Maricopa Care Advantage

Compliance Program

Date: March 18, 2014

To: Mary A. Harden, R.N., Chairman, Board of Directors, District 1 Mark Dewane, Vice Chairman, Board of Directors, District 2 Susan Gerard, Board of Directors, District 3 Elbert Bicknell, Board of Directors, District 4 Terence McMahon, Board of Directors, District 5

From: Wilma Acosta, Interim Chief Compliance Officer

Cc: Steve Purves, President & Chief Executive Officer Louis B. Gorman, District Counsel

Re: Maricopa Integrated Health System: Code of Conduct and Ethics

Maricopa County Special Health Care District: Corporate Compliance Program Maricopa Care Advantage Plan and Education: Compliance Program

The Maricopa County Special Health Care District (“District”) was awarded a contract by the federal government to operate a Medicare Advantage Plan that operates under the name Maricopa Care Advantage Plan. The day to day operations of the District’s Maricopa Care Advantage Plan is conducted by the University of Arizona Health Network (“UAHN”).

The District and UAHN Compliance Officers reviewed and revised the above listed three compliance related documents (Attached hereto in both Redlined and Clean copy format). In addition, federal regulations require that each of these documents are reviewed annually and presented to the Governing Body of the awarded entity.

The Code of Conduct and Ethics: the District’s Code of Conduct and Ethics was last revised in December of 2012. The edits reflected in this March 2014 draft do not change the substantive provisions of the Code of Ethics but do reflect grammatical revisions, the removal of redundant provisions and the editing of various provisions to make them more easily understood.

The Maricopa County Special Health Care District: Corporate Compliance Program: this District Compliance Program has not been reviewed or revised since 2008; consequently, the Interim Chief Compliance Officer took the opportunity to bring the document current. Substantively, the provisions within the District’s Corporate Compliance Program have by and large remained unaltered; however, there have been revisions to the composition of the District’s Compliance Committee.

Maricopa Care Advantage Plan and Education: Compliance Program: attached for your review and understanding is the Maricopa Care Advantage (Medicare Advantage) Compliance Program and Education that was prepared by UAHN. Since this is the first award to the District of a Medicare Advantage Plan, this is the first opportunity that the District has had to design, approve, and implement a compliance program for this Medicare awarded contract.

Federal regulatory authorities require that the District, as the Medicare Advantage Plan awardee, and its Board of Directors, be presented with the Compliance Program and Education. This presentation is being accomplished via the attached Plan as well as the attached PowerPoint presentation entitled “Compliance Program & Fraud, Waste & Abuse Plan”.

Should you have any questions concerning the above or the attached documents, as the Interim Compliance Officer, I will be available to assist in addressing the questions.

Page 2

Compliance Program & Fraud, Waste & Abuse Plan March 2014

Provided to: MIHS Board of Directors

Applicable To: Maricopa Care Advantage

1

OBJECTIVE & GOAL

GOAL: Provide governance & oversight that ensures compliance with laws, rules, regulations & requirements while improving quality & efficient care to Maricopa Care Advantage (MCA) members.

• Explain Medicare compliance program requirements • Provide an overview of the updated compliance program

• Have an awareness of the compliance program elements

for Fraud Waste & Abuse (FWA)

• Incorporate as part of the Board’s governance and oversight responsibilities the MIHS compliance program

2

Compliance Program (CP) Basics

• A Compliance program/plan is a requirement

— Must Address both Traditional Compliance Elements (7 Elements Outlined in the Federal Sentencing Guidelines) and Ensure CMS Contractual Compliance through a Strong Foundation and Ongoing Internal Oversight and Monitoring

• A Fraud, Waste and Abuse plan is a component of an effective compliance program

• CMS (Medicare/Medicaid) Conducts Significant Oversight of Managed Care Plans

3


• MIHS offers Maricopa Care Advantage (MCA) a Medicare product and must comply with laws, regulations, rules and guidance of these Programs (i.e., ‘Exchange‘ in future)

• If CMS Determines MIHS is non-compliant, it may issue MIHS

with a: — Compliance Letter — Corrective Plan Requirement — Government Audit — Enforcement Action (Sanction or Civil Monetary Penalty) — Exclusion or Capped Enrollment — Termination and Non-Renewal

4


• The Compliance Program and FWA Plan must be updated yearly. All MIHS staff, members, and/or business partners that work with Maricopa Care Advantage and the Board are required to annually review and attest to having read & understood the compliance program

• The Code/Standard of Conduct is an integral component of a

compliance program — MCA contracted providers and their staff are also required

to annually review and attest to having read & understood MIHS’s Code of Conduct

5

Compliance Program (CP) Basics CMS Requires that MIHS’s Board of Directors:

• Conduct reasonable governance and oversight of the implementation & effectiveness of the health plan’s compliance program

• Must receive training and education on the structure & operation of the compliance program

• Must be knowledgeable about compliance risks and strategies, understand the measurements of outcome and is able to gauge effectiveness

• When compliance issues are presented, the Board is expected to make further inquiry & ensure that appropriate actions are executed to resolve the issues

6

Compliance Program Purpose

• Demonstrate MIHS’s ongoing commitment to compliant

business practices & ethical behaviors • Prevent, identify, investigate, correct & report, illegal conduct

and/or FWA • Ensure effective internal controls & processes are in place • Establish a culture of compliance which encourages staff,

members and/or business partners to operate ethically & openly communicate concerns regarding non-compliance

• Ensure a consistent disciplinary approach to identified non-compliant behavior or practice.

7

Components in MCA’s CP 1. Written policies & procedures and code of conduct

2. Compliance officer, compliance committee & high level oversight

3. Effective training & education

4. Effective lines of communication

5. Well publicized disciplinary standards

6. Effective system for routine monitoring and identification of compliance risks

7. Procedures & system for prompt response to compliance issues

8. Fraud, Waste & Abuse plan

8

1. Standards of Conduct The Standards of Conduct (aka Code of Conduct) states MIHS’s overarching principles and defines the underlying framework for the compliance policies & procedures.

Standards of Conduct state that: • All staff, members and/or business partners conduct themselves in an

ethical manner • Issues of noncompliance and potential FWA are reported through

appropriate mechanisms • Reported issues will be addressed and corrected

Standards of Conduct should be: • Approved by the governing body • Updated to incorporate changes in laws, regulations, and other

program requirements such as Title XVIII of Social Security Act, HIPAA, Stark Statute, etc.

9

1. SOCs Elements (Continued)

• Avoid conflicts of interest • Protect patient

confidentiality • Retention of records • Safeguard electronic

information • Prohibit insider trading • Enforcement of corrective

action and/or discipline.

• Provide quality healthcare services

• Support patient rights • Commitment to patient

safety • Establish and maintain

appropriate physician relationship

• Promote diversity across all MIHS environment

10

1. Policies & Procedures (Continued)

Written P&Ps list the steps to ensure compliance with laws, CMS Requirements & are practical guidelines that support the Code of Conduct, HIPAA Privacy Program & FWA Plan

• Staff, members, and/or business partners are expected to make every reasonable effort to ensure compliance

• Should a staff, member, and/or business partner suspect a violation, report suspicion to the Compliance Officer or Compliance Hotline at 1-866-333-6447

• MIHS maintains a library of P&Ps for staff to access and understand administrative and operational responsibilities. MIHS P&Ps should be reviewed & updated at least annually

11

2. Compliance Officer

MIHS must employ a Compliance Officer. The Compliance Officer: • Has primary responsibility for overseeing & monitoring the

compliance program • Defines the compliance program structure, educational

requirements, reporting, complaint mechanisms & response to correction procedures

• Ensures MIHS P&Ps are accurate & integrated into MIHS operations • Provides periodic reports to the Board • Cannot be delegated or subcontracted • Should have authority to provide unfiltered, in-person reports to

senior-most leader and/or governing body(s)

12

2. Compliance Committee (Continued)

• May be chaired by MIHS’s Compliance Officer

• Responsible for providing oversight and direction to the Compliance Officer assists in implementing the compliance program

• Accountable to MIHS’s Board and top management, meets periodically to ensure compliance across MIHS

• Members should include MIHS’s Chief Financial Officer, and members of senior management as well as auditors, pharmacists, registered nurses, personnel experience in legal issues, statistical analysts, and staff/managers from various departments

• Assist in monitoring, reviewing & assessing the effectiveness of the compliance program and timeliness of reporting

13

2. High Level Oversight (Continued)

CMS requires that MIHS’s Board of Directors:

• Approve MIHS’s Code/Standard of Conduct

• Understand the compliance program structure

• Remain informed about compliance program outcomes, including results of internal and external audits

• Remain informed about governmental compliance enforcement activity such as Notices of Non-Compliance, Warning Letters and/or more formal sanctions

• Receive regularly scheduled, periodic updates from the compliance officer and compliance committee

• Review the results of performance and effectiveness assessments of the compliance program

• Maintain validation (meeting minutes) of the Board’s active engagement in the oversight of MIHS’s compliance program

14

3. Effective Training & Education

• Compliance training is required of all new staff, members, business partners and/or governing body members within 90 days of hire and annually thereafter — Some Business Partners may meet requirements through

enrollment in Medicare Programs or Accreditation by CMS (Deemed)

• MIHS Managers are Responsible to Ensure Staff & Business Partners Complete all Required Training

• Must demonstrate that staff, members, business partners and/or governing bodies have fulfilled training requirements

15

4. Effective Lines of Communication

• MIHS has systems to receive, record and respond to compliance questions or reports from staff, members and/or business partners

• Reported violations are documented and investigated promptly. A log is maintained of all reports & outcomes

• MIHS has P&Ps of non-retaliation for anyone who reports a violation. Staff, members, and/or business partners are made aware of these P&Ps and encouraged to report.

• Communication includes accessing the compliance officer or management; the Compliance Department; or calling the Compliance Hotline at 1-866-333-6447

• Any staff, member and/or business partner aware of any violation of the Code of Conduct has a duty to report the violation. 16

5. Well Publicized Disciplinary Guidelines

• Any person who suspects a violation is required to report. • MIHS provides guidance about disciplinary action and will enforce

disciplinary P&Ps consistently • Staff, members, and/or business partners are aware that failure to

report violations may result in disciplinary action • Sanctions may range from warnings to immediate termination of

employment, or contract termination • P&Ps prohibit hiring or contracting with individuals who have been

excluded from health care programs or convicted of crimes related to health care. MIHS screens for these individuals monthly

17

6. Effective System for Routine Monitoring & Risk ID

• The compliance program incorporates internal monitoring & auditing; regular reporting of audit outcomes; and implementing correction to improve compliance

• An annual risk assessment must be conducted to identify areas of risk within MIHS

• From the risk assessment, the audit program is developed • General auditing & monitoring is done utilizing established

metrics • The metrics are drawn from MIHS’s contracts with CMS • Auditing & monitoring also include oversight of delegated

business partners • MIHS is also subject to recurring auditing & monitoring

18

6. Effective System for Routine Monitoring & Risk ID (Continued)

• Self-Monitoring: Health plan departments are required to conduct self-audits to measure performance against CMS requirements.

• Internal Audit: MIHS contracts with The University of Arizona Health Plans (UAHP) and its Compliance Department acts as external auditors and conducts audits of all health plan operational areas

• External Auditors: UAHP contracts with external auditors to audit UAHP processes. UAHP is also regularly audited by CMS.

19

6. Effective System for Routine Monitoring & Risk ID (Continued)

• Monitoring and Auditing of FDRs: UAHP contracts with vendors to administer benefits on MIHS’s behalf. UAHP ensures they comply with all requirements. Methods to monitor & audit include ongoing oversight, on-site audits, desk reviews and monitoring of self-audit reports

• Outcomes: When noncompliance is identified it is reported & documented & a corrective action plan (CAP) is implemented. Audit activities are reported to senior management, the compliance officer and compliance committee. When a CAP is completed, the return to compliance is validated

20

7. Procedure & System for Prompt Response to Issues

• UAHP and MIHS P&Ps outline how to promptly respond to any detected offenses. — Includes, but not limited to, investigations, inquiries,

revising/updating polices, retraining staff, implementing corrective action plans, etc.

— Timely documents inquiries, potential violations and misconduct related to contractual requirements including payment, delivery of services, prescription drug Items and FWA

21

7. Procedure & System for Prompt Response to Issues (Continued)

• UAHP and MIHS or its vendors must implement corrective action plans (CAP) whenever there is a confirmed incident of non-compliance. — CAPs may include revising processes, updating P&Ps,

retraining staff & other root causes. The outcome must achieve sustained compliance

— CAPs are reported to the compliance officer & compliance committee. The compliance department monitors CAPs implementation.

— Compliance validates the CAP by monitoring over a period of time to demonstrate sustained compliance

— Significant noncompliance is self-reported to CMS

22

8. Fraud, Waste & Abuse Plan

• Health care fraud is a crime that has a significant effect on the private and public health care payment system.

• Taxpayers pay higher taxes because of FWA in public programs such as Medicare.

• Employers and individuals pay higher private health insurance premiums because of FWA in the private sector health care system.

• Because of the profound impact FWA has on health care financing, CMS requires MIHS and other Medicare plans to actively pursue the prevention, detection, investigation, reporting and correction of FWA.

23

Examples of Fraud Include:

• Billing for services not rendered; • Misrepresenting non-covered services as covered; • Signing blank records, forms, falsifying information on records or

on cost reports for the sole purpose of obtaining payment; • Up-coding or consistently using procedure/revenue codes that

describe more extensive services than actually performed; • Using incorrect or invalid provider number to be paid • Selling or sharing Medicare health insurance identification number

so false claims can be filed

24

Laws/Regulations 3 Types of conduct generally prohibited by health care fraud laws are: • False Claims • Kickbacks • Self-Referrals

Consequences for violating these laws can include: • Imprisonment and fines • Civil monetary penalties • Loss of licensure • Loss of staff privileges • Exclusion from participation in Federal health care programs

25

Compliance Program and FWA Plan takes a layered approach which includes prevention, detection,

investigation, correction & reporting • Prevention includes: FWA P&Ps, FWA awareness/training, FWA

screening, annual risk assessment, FWA committee • Detection includes: monitoring & auditing, implementing

automated solutions to detect unusual billing patterns, • Investigation includes: analyzing data collected via FWA analytics

& data mining, reviewing medical records, record searches, interviewing providers, members, employees, others

• Correction includes: provider/member education, member case management referral, prospective review, recovery, restriction, termination, administrative remedy, change in policy, close case

• Reporting includes: reporting suspected FWA to compliance. MIHS must report suspected FWA to the designated State and Federal agencies and/or law enforcement

26

Thank you!

MIHS Compliance Officer UAHP Compliance Officer

27

The University of Arizona Health Plans

Compliance Program and Fraud, Waste and Abuse Plan

April 2013 through March 2014

Letter from the CEO Dear University of Arizona Health Plan Staff and Business Partners, The University of Arizona Health Plans (UAHP) is committed to the ethical and legal conduct of our business operations. This includes the delivery of health care services and participation in government health care programs. A key component of our commitment to legal and ethical conduct and professional business practices includes adopting standards that uphold these principles, which form the basis for the UAHP Compliance Program. The Compliance Program is outlined and described in several documents including the Code of Conduct, policies and procedures, as well as the Fraud, Waste and Abuse Plan. As a Medicare, Medicaid and Health Insurance Exchange (HIX) participant, this Compliance Program endorses our commitment to enforce the highest standards of ethics, professional standards and compliance for employees and the Board of Directors (Staff) as well as first tier, downstream and related entities, subcontractors and agents (Business Partners). All Staff and Business Partners must make a personal commitment to adhere to the Code of Conduct. UAHP does not condone unethical, non-compliant or criminal conduct by any UAHP Staff and Business Partners. In conjunction with The University of Arizona Health Network (UAHN), CMS, the Federal Coordinated Health Care Office and AHCCCS; this Compliance Program is structured to address the Medicare, Medicaid and HIX programs as well as overall UAHP activities. By integrating the Compliance Program, UAHP links Medicare, Medicaid and HIX program rules and reconciles potential conflict between the programs. Reducing duplication of effort and conflict is important, as the rules governing the healthcare industry are unusually complex. Activities that may be perfectly legal in other industries may be crimes in a Medicare, Medicaid and HIX program. UAHP Staff and Business Partners could face penalties--including jail time--for violations of the law. Thus, UAHP has implemented this Compliance Program to help all of our Staff and Business Partners deal with the complexities of Federal and State programs. Your knowledge of, and dedication to, these standards allows us to serve our customers in a professional, caring and compliant manner while maintaining the standards of legal and ethical conduct that we have adopted. On behalf of The University of Arizona Health Plans, thank you. Sincerely,

James Stover Chief Executive Officer University of Arizona Health Plans.

1

The University of Arizona Health Plan Compliance Program Table of Contents

Topic / Component Page Number Definitions 3-5 Staff and Business Partner Guidance on Implementation and Operation of this Program 6-8 1: Written Policies, Procedures and Standard of Conduct 8-20 2: Compliance Officer, Compliance Committee and High Level Oversight 20-24 3: Effective Training and Education 24-25 4: Effective Lines of Communication 25-28 5: Well Publicized Disciplinary Standards 28-29 6: Effective System for Routine Monitoring and Identification of Compliance Risks 29-33 7: Procedures and System for Prompt Response to Compliance Issues 33-35 8: Fraud, Waste and Abuse Plan 35-43

2

Definitions

Abuse – Includes actions that may, directly or indirectly, result in: unnecessary costs to the Medicare or Medicaid programs or other government programs, improper payment, payment for services that fail to meet professionally recognized standards of care, or services that are medically unnecessary. Abuse involves payment for items or services when there is no legal entitlement to that payment and the provider has not knowingly and/or intentionally misrepresented facts to obtain payment. Abuse cannot be differentiated categorically from fraud, because the distinction between “fraud” and “abuse” depends on specific facts and circumstances, intent and prior knowledge, and available evidence, among other factors Abuse of a member includes the intentional infliction of physical harm, injury caused by negligent acts or omissions, unreasonable confinement, sexual or emotional abuse or sexual assault. Agents - Agents refers to independent agents/brokers used to sell Medicare Advantage Prescription Drug plans. AHCCCS - Arizona’s Medicaid program, designed to deliver quality health care with cutting-edge managed care concepts. AHCCCS stands for the Arizona Health Care Cost Containment System. Beneficiary/Member – A member of a Medicare or Medicaid program. Audit – A formal review of compliance with a particular set of standards (e.g., policies and procedures, laws and regulations) used as a base measure. CMS - Federal Agency which administers Medicare and Medicaid. CMS is an acronym for Centers for Medicare and Medicaid Services. Business Partners – The collective grouping of all UAHP first tier, downstream and related entities, subcontractors and agents. Cost Avoidance - The process of identifying and utilizing all sources of first or third-party benefits before services are rendered or before payment is made by an AHCCCS contractor. Deemed Provider, Supplier or Business Partner – means a provider or supplier that has been accredited by a national accreditation program (approved by CMS) as demonstrating compliance with certain conditions. First Tier, Downstream and Related Entities - A First Tier Entity is a party that enters into a written arrangement with UAHP to provide administrative or health care services. A Downstream Entity is a party that enters into a written arrangement with UAHP below the level between UAHP and a first tier entity. These written arrangements continue down to the level of provider of both health and administrative services (e.g., mail order pharmacies, firms providing agent/broker services, agents, brokers, marketing firms, call center firms). A Related Entity may be one of the following: 1) Performs some UAHP management functions under contract or delegation; 2) Furnishes services to members under an oral or written agreement; or 3) Leases real property or sells materials to UAHP at a cost of more than $2,500 during a contract period. Fraud – Knowingly and willfully executing, or attempting to execute, a scheme or artifice to defraud any health care benefit program or to obtain (by means of false or fraudulent pretenses, representations, or promises) any of the money or property owned by, or under the custody or control of, any health care benefit program. Misconduct - Any action or behavior that does not conform to the organization’s stated or intended standards, guidelines or procedures; or is a violation of any federal/state law or regulation. Monitoring Activities – Regular reviews performed as part of UAHP’s normal operations to confirm ongoing compliance and to ensure that corrective actions are undertaken and effective. Non-Compliance - Failure or refusal to act in accordance with the organization’s Compliance Program; or other standards or procedures; or with federal or state laws or regulations. Staff - Refers to all of the University of Arizona Health Plan employees including members of the University of Arizona Health Network Board of Directors. Subcontractor – See first tier, downstream and related entities.

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Waste - Overutilization of services or other practices that, directly or indirectly, result in unnecessary costs to federal and state government programs. Waste is generally not considered to be criminally negligent but rather the misuse of resources.

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Defining the University of Arizona Health Plans

UAHP is a subsidiary company of The University of Arizona Health Network (UAHN), an academic health system comprised of award-winning hospitals, The University of Arizona Medical Centers and UAHP, a high-performing health plan. UAHP’s Board of Directors and the UAHN delivery system are dedicated to improving health outcomes through education, research and clinical care innovation. Through relationships with the Centers for Medicare and Medicaid Services (CMS) and the Arizona Health Care Cost Containment System (AHCCCS), UAHP manages various contracts that facilitate health care services in an HMO model. Current managed care products are described below and shown in the illustration. University Family Care (UFC) UAHP is a contractor with AHCCCS to provide health services through a Medicaid HMO Model University Healthcare Group (HCG) UAHP is a contractor with AHCCCS for Healthcare Group to offer an insurance product to small businesses with 2-50 employees and political subdivisions. Healthcare Group is an HMO Model. Maricopa Health Plan (MHP) Through an administrative contract with Maricopa Integrated Health System (MIHS) which is a contractor with AHCCCS, UAHP manages Maricopa Health Plan (AHCCCS) a Medicaid HMO Model. UAHP handles all aspects of plan operations. University Care Advantage, Inc. (UCA) UCA is the name UAHP uses to market its Medicare Advantage Part D (MAPD) plan. University Care Advantage, Inc. is the Legal Entity that contracts with CMS to provide MAPD products to Medicare beneficiaries. UAHP is the organizational umbrella under which UCA, Inc. is managed. University Healthcare Marketplace (UHM) UAHP is licensed as a Commercial Health Care Service Organization with the Arizona Department of Insurance as University Healthcare, Inc. to offer insurance products to the individual and small group markets. These plans may be offered either directly to the consumer or through the Federally Facilitated Marketplace (Exchange). UHM is an HMO model.

Maricopa Health Plan

University Care Advantage

University

Health Care

Group

University Family Care

The University of Arizona Health Plans

Compliance Program

University Healthcare

Marketplace

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Staff and Business Partner Guidance on the Implementation and Operation of the UAHP Compliance Program

This Compliance Program applies to, has been implemented and put into operation across all lines of business, including the Arizona Health Care Cost Containment System (AHCCCS), Medicare Part C, Medicare Part D and Healthcare Group. The Compliance Program is updated annually and approved and adopted by the Board of Directors for UAHP. To ensure adoption of the Compliance Program, UAHP requires that all UAHP employees (including managers and directors) and the UAHP Board of Directors (Board) (these individuals are collectively referred to as “Staff” throughout this document); subcontractors; vendors; first-tier, downstream and related entities (FDRs); and agents (these entities and vendors are collectively referred to as “Business Partners” throughout this document) adopt and operate in accordance with this Compliance Program. Therefore, all UAHP Staff and Business Partners must read, understand and agree to comply with this Compliance Program. This mandatory Compliance Program provides guidelines to help each Staff and Business Partner understand how UAHP conducts business. It also serves to govern the conduct of all Staff and Business Partners who support UAHP operations. UAHP applies the principles outlined in AHCCCS, Medicare Part C and D and HIX guidelines to operate an effective Compliance Program that meets regulatory requirements. This Compliance Program has been implemented to meet regulatory requirements outlined by AHCCCS, CMS, Healthcare Group and HIX programs. For CMS, these requirements can be found in the Code of Federal Regulations (C.F.R.), chapter 42, parts 422 and 423 at: 42 C.F.R. § § 422.502(b)(4)(vi) and 423.504(b)(4)(vi). CMS publishes compliance program guidelines in publication 100-18, Medicare Prescription Drug Benefit Manual, chapter 9 and in publication 100-16, Medicare Managed Care Manual, chapter 21. For AHCCCS, the requirements can be found at 42 C.F.R. 438.608, 455.17, 455.101, 455.104, 455.105 and 455.1(a)(1) as well as in Arizona Revised Statutes (A.R.S.), section 13-2310. AHCCCS includes requirements in paragraph 62 of its contract with UFC and MHP as well as in the AHCCCS Contractor Operations Manual (ACOM), Chapter 100, policy 104. For the Health Insurance Exchange, the final rule can be found at 45 C.F.R, 156, subpart C. For all operations, Staff and Business Partners must apply the principles outlined in these guidelines and as contained in this Compliance Program to all relevant decisions, situations, communications and developments. Any new governmental rule-making or interpretive guidance may require an update to the Compliance Program. UAHP will submit any significant changes to the Compliance program to the appropriate governmental entity for review. Once approved, UAHP will provide Staff and Business Partners with any Compliance Program updates. We know this Compliance Program can be complex so, please do not hesitate to contact the UAHP Compliance Department or Compliance Officer listed below if you have any questions regarding information contained in this Compliance Program: Mary Consie, Compliance Officer 520-874-5075 (Tucson Office) / 602-344-8389 (Phoenix Office) / 602-908-6860 (Cell) 520-874-3462 (Fax) / [email protected] Tucson Office: 2701 E. Elvira, Tucson AZ 85756 (In the Southeast Corner of Building 2731) Phoenix Office: 2502 E. University Drive, Suite 125, Phoenix AZ 85034 Governance of the Compliance Program One of the key elements in the Compliance Program is the creation of Compliance Committees (Committee) for the AHCCCS and Medicare lines of business. This Committee is responsible for the support the Compliance Officer and to review, approve and ensure implementation of the Compliance Program. They evaluate Compliance Program effectiveness through self-auditing;

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monitoring of metrics and key indicators; and ensure prompt and effective corrective actions are taken where deficiencies are noted. The Compliance Committee is responsible to UAHP’s senior management, the Chief Executive Officer and the Board of Directors. The Compliance Officer reports to the UAHP CEO and has express authority to meet with the Board of Directors for UAHP. The Compliance Officer and Committee are responsible for escalating compliance deficiencies and ongoing issues of non-compliance to senior management, the CEO and the Board of Directors. The Compliance Officer reserves the right to amend and update components of this Compliance Program at any time and to make changes based on regulatory guidance or to enhance the program to improve effectiveness. UAHP Board Compliance Oversight and Senior Management Engagement The UAHP Board is ultimately responsible for the Compliance Program, including ensuring adherence to all compliance policies and procedures. The Board’s oversight includes the following: 1) Review and approve the Compliance Program, 2) Review and recommend Compliance Program monitoring and auditing activities, and 3) Assist with development strategies to promote compliance with the Compliance Program. UAHP’s CEO and senior management are highly engaged in the Compliance Program. The Executive Team recognizes the importance of the Compliance Program in UAHP’s success and all are active members of the Compliance Committee. Goal of the Compliance Program The primary goal of the UAHP Compliance Program is to provide the guidance and oversight that ensures UAHP’s compliance with state and federal law, rules, regulations and requirements while facilitating improving quality of care and the efficiency of the delivery of care to UAHP’s members. This includes identifying and correcting inappropriate or illegal conduct; this includes reducing fraud, waste and abuse. This primary goal is accomplished by: 1) The ongoing demonstration of UAHP’s commitment to compliant business practices and ethical behaviors; 2) Preventing, identifying, investigating, reporting and correcting fraud, waste and abuse; 3) Ensuring effective internal controls and processes are in place that ensure compliance with state and federal laws and regulations; 4) Establishing a culture of compliance which encourages Staff and Business Partners to operate in a compliant manner and to openly communicate any concerns they may have regarding any non-compliant practices, and; 5) Ensuring a consistent disciplinary approach to any identified non-compliant behavior or practice. Components of the Compliance Program UAHP is required to adopt and implement an effective Compliance Program which must include measures to prevent, detect, and correct Medicare, Medicaid and HIX program noncompliance as well as Fraud, Waste and Abuse (FWA).UAHP’s Compliance Program--which incorporates the AHCCCS, Medicare and HIX lines of business--includes the following components: Component 1: Written Policies, Procedures and Standards of Conduct Component 2: Compliance Officer, Compliance Committee and High Level Oversight Component 3: Effective Training and Education Component 4: Effective Lines of Communication Component 5: Well-Publicized Disciplinary Standards Component 6: Effective System for Routine Monitoring and Identification of Compliance Risks Component 7: Procedures and System for Prompt Response to Compliance Issues Component 8: Fraud, Waste and Abuse Plan In order for this Compliance Program to be effective it must be fully implemented, include a written document which outlines all aspects of the Compliance Program, explain how each component above will be carried out and be tailored to UAHP’s unique organization, operations and

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circumstances. UAHP may enter into contracts with FDRs to provide administrative or health care services for members on behalf of UAHP. UAHP does not delegate Compliance Program administrative functions (e.g., Compliance Officer, Compliance Committee, compliance reporting to senior management, etc.) to FDRs, however, UAHP may use FDRs for compliance activities such as monitoring, auditing and training. Because UAHP maintains the ultimate responsibility for fulfilling terms and conditions of UAHP’s contract with AHCCCS, CMS, HCG and HIX, and for meeting government program requirements, CMS, AHCCCS and other government agencies may hold UAHP accountable for the failure of its FDRs to comply with government program requirements. UAHP dedicates adequate resources within UAHP to do the following Compliance Program activities: 1) Promote and enforce the Code of Conduct, 2) Promote and enforce The Compliance Program, 3) Effectively train and educate UAHP’s Staff and Business Partners, 4) Effectively establish lines of communication within UAHP and between UAHP and its Business Partners, 5) Oversee Business Partner compliance with Medicare, Medicaid and HIX requirements, 6) Establish and implement an effective system for routine auditing and monitoring, and 7) Identify and promptly respond to risks and findings. Component 1: Written Policies, Procedures and Standards of Conduct UAHP has written policies, procedures and standards of conduct that:

• Articulate UAHP’s commitment to comply with all applicable Federal and State standards; • Describe compliance expectations as embodied in the Standards of Conduct; • Implement the operations of the Compliance Program; • Provide guidance to Staff and Business Partners on dealing with suspected, detected or

reported compliance issues; • Identify how to communicate compliance issues to appropriate compliance personnel; • Describe how suspected, detected or reported compliance issues are investigated and

resolved by UAHP; and • Include a policy of non-intimidation and non-retaliation for good faith participating in the

Compliance Program, including, but not limited to reporting potential issues, investigating issues, conducting self-evaluations, audits and remedial actions, and reporting to appropriate officials.

Code of Conduct The Code of Conduct states UAHP’s over-arching principles and values by which UAHP operates and defines the underlying framework for the compliance policies and procedures. Staff and Business Partners, from the top to the bottom of UAHP’s organization, have the responsibility to perform their duties in an ethical manner in compliance with laws, regulations and UAHP’s policies. As a subsidiary of UAHN, this extends to complying with applicable UAHN policies. The Code of Conduct provides the standards by which Staff and Business Partners will conduct themselves, in order to protect and promote organization-wide integrity, ensure adherence to UAHP values and enhance UAHP’s ability to achieve the organization’s mission. These standards are intended to provide guidance to UAHP Staff and Business Partners. These standards are neither exclusive nor complete. Staff and Business Partners are required to comply with all applicable laws, whether or not specifically addressed. All UAHP Staff and Business Partners must read the Code of Conduct annually and sign an acknowledgement that they agree to abide by the Code of Conduct. A copy is provided to all new Staff hires and is available to review on the UAHP intranet and UAHP websites by Staff. Each UAHP manager, director and officer is responsible for reinforcing the Code of Conduct.

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UAHP requires that all FDRs supporting the Medicare Advantage and Part D Prescription Drug Program adopt and abide by the UAHP Code of Conduct or implement a Code of Conduct that incorporates standards of conduct and requirements consistent with UAHP’s Code of Conduct. This Compliance Program sets forth a Code of Conduct which includes components specific to the Medicare Advantage Prescription Drug Plan program. The Code of Conduct standards are listed below and are followed by detailed explanations. A. Exercise Due Care B. Adhere to Legal and Regulatory Requirements C. Ensure Accurate Records and Financial Information D. Maintain Confidentiality E. Avoid Conflicts of Interest F. Cooperate with All Investigations G. Retention of Records H. Accessing Electronic Information I. Prohibited Insider Trading J. Commitment to Employment Relationships K. Seeking Guidance and Reporting Violations L. Enforcement of Corrective Action and/or Discipline A. Exercise Due Care Staff and Business Partners must conduct themselves in an ethical manner, act in good faith, responsibly, with due care, competence and diligence by conducting all business activities with the highest level of integrity. To accomplish this Staff and Business Partners must observe professional standards with regard to licensure and scope of service, continually evaluate existing procedures to identify potential noncompliance and FWA, process improvements and to ensure that appropriate standards are met, be knowledgeable of and exercise diligence with applicable laws, regulations, corporate and departmental policies, and address deficiencies by reporting them to UAHP management, the Compliance Officer via phone call, email, in-person report, mail or fax (see page 6 for contact information) or by calling the Compliance Hotline at 1-800-726-0713. Any issues reported, will be documented by the Compliance Department. All reported issues will be promptly and fully investigated. If noncompliance is identified, a corrective action will be implemented. Implementation of the Corrective Action Plan (CAP) will be overseen by the Compliance Department to ensure the issue is addressed and corrected in a timely, thorough and compliant manner. Upon completion of a CAP, the Compliance Department will review the results and ensure the CAP is compliantly implemented and the issue is fully resolved. B. Adhere to Legal and Regulatory Requirements UAHP is committed to complying with all applicable laws and regulations including:

• Title XVIII of the Social Security Act • Medicare Regulations Governing Parts C and D found at 42 CFR § § 422 and 423

respectively • Patient Protection and Affordable Care Act (Pub. L. No 111-148, 124 Stat. 119) • Health Insurance Portability and Accountability Act (HIPAA) (public Law 104-191) • False Claims Acts (31 USC § § 3729-3733) • Federal Criminal False Claims Statutes (18 USC § § 287.1001) • Anti-Kickback Statute (42 USC § 1320a-7b(b)) • The Beneficiary Inducement Statute (42 USC § 1320a-7a(a)(5)) • Civil Monetary Penalties of the Social Security Act (42 USC § 1395w-27(g)) • Physician Self-Referral (Stark) Statute (42 USC § 1395nn)

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• Fraud and Abuse, Privacy and Security Provisions of the Health Insurance Portability and Accountability Act, as modified by HITECH Act

• Prohibitions against employing or contracting with persons or entities that have been excluded from doing business with the Federal Government (42 USC § 1395w-27(g)(1))(G)

• Fraud Enforcement and Recovery Act of 2009 • All sub-regulatory guidance produced by CMS and HHS such as manuals, training

materials, HPMS memos and guides If these laws and regulations are ignored; it could lead to allegations of fraud, waste and abuse as defined by Federal statute1. “Fraud, waste and abuse” is an umbrella term that applies to a series of statutes and regulations designed to prevent government health programs from paying excessive and/or inappropriate claims. Examples of fraud include, but are not limited to: Billing for services that were not rendered; Misrepresenting as medically necessary non-covered or screening services, by reporting

covered procedure or revenue codes; Signing blank records or certification forms, or falsifying information on records or certification

forms for the sole purpose of obtaining payment; Consistently using procedure/revenue codes that describe more extensive services than those

actually performed; Upcoding, unbundling, double billing or using an incorrect or invalid provider number in order

to be paid or to be paid at a higher rate of reimbursement; Selling or sharing Medicare health insurance identification numbers so false claims can be filed; Falsifying information on applications, medical records, billing statements, cost reports or on

any documents filed with the government. Misrepresenting or concealing facts that would cause UAHP to provide coverage to persons

who are otherwise not eligible

Examples of waste and abuse include, but are not limited to: Billing for services or items in excess of those needed by the patient; Adding inappropriate or incorrect information to cost reports; Collecting in excess of the deductible or co-insurance amounts; Requiring a deposit or other payment from patients as a condition for admission, continued

care or other provision of service; Unbundling charges when there is one specific code that describes and includes payment for

all components. UAHP is committed to working with AHCCCS, CMS, state and federal regulators to report potential fraud, waste and abuse. Staff and Business Partners are responsible for reporting any suspected or observed health care fraud, waste or abuse to their supervisor, manager, director, the Fraud and Abuse Analyst, the Compliance Officer or the Compliance Hotline at 1-800-726-0713 immediately and be prepared to provide a complete description of the suspected or observed activity. UAHP will make every effort to protect your identity and will not tolerate any form of retaliation against any person making such a report. The three types of conduct that are generally prohibited by health care fraud laws are false claims, kickbacks and self-referrals. The consequences for violating these laws can include, in addition to imprisonment and fines, civil monetary penalties, loss of licensure, loss of staff privileges and exclusion from participation in federal health care programs.

1 18 U.S.C. § 1347 10

False Claims Act2 A false claim is the knowing submission of a false or fraudulent claim for payment or approval or the use of a false record that is material to a false or fraudulent claim. False claims involve a pattern or practice of presenting claims in which the submitter knew, or should have known, would lead to greater payments than are appropriate or if they engage in a pattern or practice of submitting claims that they knew, or should have known, were for services that were not medically necessary. Additional behaviors likely to raise concern include reporting improper diagnosis or procedure codes to maximize reimbursement, double billing, claiming costs for non-covered services, providing questionable documentation for the medical necessity of professional services and misrepresenting information to obtain payments. Reckless disregard of the truth or falsity of the information on the claim filed or an attempt to remain ignorant of billing requirements are considered violations of the False Claims Act. Concerns regarding a potential violation of the False Claims Act must be reported to management, the Compliance Department or the Compliance Hotline at 1-800-726-0713. Staff and Business Partners may utilize other mechanisms of reporting to state or federal agencies through Whistleblower Provisions. Any person with actual knowledge of allegedly false claims may file a qui tam lawsuit on behalf of the government and can receive an award if, and after, the Government recovers money from the defendant as a result of the lawsuit. UAHP’s policies prohibit retaliation against those who, in good faith, report inappropriate activities.

Stark Self-Referral Law3 and Anti-Kickback Statute4 The Stark Self-Referral Law, also known as the physician self-referral law, prohibits a physician from making referrals for certain designated health services (DHS) payable by government health care programs to an entity with which the physician (or an immediate family member) has a financial relationship (ownership, investment or compensation), unless an exception applies. It also prohibits the entity from presenting or causing to be presented claims to government health care programs (or another individual, entity or third-party payer) for those referred services. The following are DHS: Clinical laboratory services. Physical therapy services. Occupational therapy services. Outpatient speech-language pathology services. Radiology and certain other imaging services. Radiation therapy services and supplies. Durable medical equipment and supplies. Parenteral and enteral nutrients, equipment and supplies. Prosthetics, orthotics and prosthetic devices and supplies. Home health services. Outpatient prescription drugs. Inpatient and outpatient hospital services. The Anti-Kickback Statute makes it illegal to solicit, pay, offer or receive any remuneration, in cash or in kind (money, goods, services), in return for the referral or to induce the referral of a patient, or for ordering, providing, recommending or arranging for the provision of any service reimbursable under government health care programs. In general, the statute prohibits anyone from offering anything of value that is likely to influence the person’s decision to select or receive care from a particular health care provider. The purchase or sale of goods and services must not lead to Staff or Business Partners or their immediate families receiving kickbacks. Kickbacks or rebates may take many forms and are not limited to direct cash payments or credits. If a Staff,

2 31 U.S.C. § 3729-3733 3 42 U.S.C. § 1395nn 4 42 U.S.C. § 1320-7b(b)

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Business Partner or member/beneficiary stands to gain personally through a transaction, it is prohibited. Gifts or Gratuities: Maintaining appropriate relationships with UAHP’s vendors is imperative to ensuring the selection of quality products at fair prices. UAHP Staff may not accept or encourage gifts of money under any circumstances, nor may they solicit non-monetary gifts, gratuities or any other personal benefit or favor of any kind from suppliers or customers. UAHP Staff and Business Partners and their immediate families may accept unsolicited, non-monetary gifts of modest value from a business firm or individual doing or seeking to do business with UAHP only if the gift is primarily of an advertising or promotional nature. UAHP Staff and Business Partners should contact their supervisors or the Compliance Officer if they are unsure if accepting a gift or gratuity is permitted. Federal law makes it a crime to give, offer or promise anything of value to any public official for or because of any official act performed or to be performed by such official. It is also a Federal crime to make any payments to public employees, made on account of or as compensation for public duties. UAHP Staff will not give/nor receive gifts or gratuities exceeding the value of $10 per gift or $50 per calendar year in the aggregate. UAHP Staff will contact their supervisors or the Compliance Officer if they are unsure if giving a gift or gratuity is acceptable. UAHP Staff are prohibited from giving any government employee or representative any gifts or gratuities. Entertainment: From time to time, UAHP Staff may offer or accept entertainment, as long as it is not excessive, provided it occurs infrequently and it does not involve lavish expenditures. Offering or accepting entertainment that is not a reasonable addition to a business relationship but is primarily intended to gain favor or influence must be avoided. Payments to Agents and Consultants: Agreements with Business Partners (including agents or FDRs) must be in writing. Such agreements must clearly and accurately set forth the services to be performed, the basis for earning the commission or fee involved and the applicable rate or fee. Any such payment must be reasonable in amount, not excessive in terms of industry practices, not exceed any applicable statutory or regulatory maximums and be commensurate with the value of the services rendered. Other Improper Payments (applicable to Medicare Advantage Prescription Drug Plan): The use of UAHP’s MAPD Plans’ funds or assets for any unlawful or unethical purpose is prohibited. Any improper payment made by a UAHP Staff or agent is likewise improper when made by a commissioned agent, or FDR on behalf of the MAPD plans. This is also true for a UAHP Staff who knows or has reason to know that a payment will be made. The making of any payment to a third party for any purpose other than that disclosed on the payment documentation is also prohibited. These guidelines are not all-inclusive, but provide a foundation for sound business judgment and the maintenance of appropriate vendor relationships. Questions regarding the Stark Self-Referral Law, Anti-Kickback Statute and appropriate vendor relationships should be directed to the Compliance Officer or the Compliance Hotline at 1-800-726-0713. Federal Procurement Integrity Act The UAHP Medicare line of business is subject to the Federal Procurement Integrity Act when bidding on Federal contracts. This law prohibits certain business conduct for companies seeking to obtain work from the federal government. During the bidding process UAHP Staff may not:

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Offer or discuss employment or business opportunities at UAHN with agency procurement officials.

Offer or give gratuities or anything of value to any agency procurement official. Seek or obtain any confidential information about the selection criteria before the contract is

awarded. In addition, other Federal provisions prohibit Federal officials from accepting anything of value, subject to reasonable exceptions such as modest items of food and refreshments. Because of these restrictions, no Staff shall either offer or make a gift to a federal employee. In addition to health care fraud laws, UAHN Staff are expected to comply with laws and regulations regarding antitrust, tax and non-discrimination laws as well as lobbying/political activities and regulatory requirements. Antitrust Laws All UAHN Staff must comply with applicable antitrust and similar laws that regulate competition. Examples of conduct prohibited by these laws include (1) agreements to fix prices, bid rigging, collusion (including price sharing) with competitors; (2) boycotts, certain exclusive dealing and price discrimination agreements; and (3) unfair trade practices including bribery, misappropriation of trade secrets, deception, intimidation and similar unfair practices. UAHN Staff are expected to seek advice from the UAHN General Counsel when confronted with business decisions involving a risk of violation of the antitrust laws. Tax Laws As a nonprofit entity, UAHN has a legal and ethical obligation to act in compliance with applicable laws, to engage in activities in furtherance of its charitable purpose, and to ensure that its resources are used in a manner which furthers the public good, rather than the private or personal interests of any individual. UAHN and Staff will avoid compensation arrangements in excess of fair market value, will accurately report payments to appropriate taxing authorities when applicable, and will file all tax and information returns in a manner consistent with applicable laws. Lobbying/Political Activity UAHN expects Staff to refrain from engaging in activity which may jeopardize the tax-exempt status of UAHN, including a variety of lobbying and political activities. No Staff may make any agreement to contribute any money, property, or services of any UAHN Staff at UAHN’s expense to any political candidate, party, organization, committee or individual, in violation of any applicable law. UAHN staff may personally participate in and contribute to political organizations or campaigns, but they must do so as individuals, not as representatives of UAHN, and they must use their own funds. Where its experience may be helpful, UAHN may publicly offer recommendations concerning legislation or regulations being considered. In addition, it may analyze and take public positions on issues that have a relationship to the operations of UAHN, when UAHN’s experience contributes to the understanding of such issues. UAHN has many contacts and dealings with governmental bodies and officials. All such contacts and transactions shall be conducted in an honest and ethical manner. Any attempt to influence the decision-making process of governmental bodies or officially by an improper offer of any benefit is absolutely prohibited. Any requests or demands by any governmental representative for any improper benefit should be immediately reported to the UAHN General Counsel. Non-Discrimination UAHN believes that the fair and equitable treatment of employees, patients and other persons is critical to fulfilling its vision and goals. It is the policy of UAHN to treat patients without regarding to the race, color, religion, sex, ethnic origin, age or disability of such person, or any other classification prohibited by law. It is the policy of UAHN to recruit, hire, train, promote, assign,

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transfer, layoff, recall and terminate employees based on their individual abilities, achievement, experience and conduct, without regard to race, color, religion, sex, ethnic origin, age or disability or any other classification prohibited by law. No form of harassment or discrimination on the basis of sex, race, color, disability, age, religion, ethnic origin, disability, or any other classification prohibited by law will be permitted. Each allegation of harassment or discrimination will be promptly investigated in accordance with applicable human resource policies. Regulatory Requirements UAHN staff must comply with applicable licensure, certification, permit and registration requirements as required by the business division they work in. This includes but is not limited to adherence to OSHA standards, compliance with Arizona state licensure and other applicable regulations, rules and laws.

C. Ensure Accurate Records and Financial Information UAHP endeavors to ensure that all documentation, including but not limited to medical records, claims, time sheets, production standards, quality control, expense reports, formal certifications and financial statements accurately reflect the true nature of a fact or event. Loss of data or incomplete or inaccurate records could lead to a challenge of the integrity of the Compliance Program and diminish UAHP’s reputation. Uniformity in retaining records is essential; therefore record retention policies must be followed to ensure proper retention and destruction of records. All documentation must be complete, accurate and recorded timely. It is against UAHP’s policy and a potential violation of law to cause documentation or financial records to be inaccurate or misleading in any way, for any reason or to make false or misleading oral or written statements. When completing expense reports or financial statements, it is important to allocate the appropriate costs and to give consideration to the allowable, allocation and reasonableness of incurred costs. Management must be notified of significant transactions, trends and other financial or non-financial information that may be material to UAHP. It is against UAHP’s policy to take any action to fraudulently influence, coerce, manipulate or mislead any independent public or certified accountant engaged in an audit of UAHP’s financial statements. D. Maintain Confidentiality Patient and/or UAHP’s Member Health Information Staff and Business Partners will comply with Health Insurance Portability and Accountability Act (HIPAA) legal requirements, as well as the HITECH and GINA Acts, regarding the disclosure of Protected Health Information (PHI). UAHP’s policies regarding health care information that is protected by this law will be adhered to by all Staff and Business Partners. These policies conform to federal and state laws and have been designed to safeguard member privacy. Confidential information is to be maintained and retained in accordance with written policies and applicable laws. The Compliance Officer is responsible for the development and implementation of appropriate policies and procedures regarding patient privacy information in accordance with federal and state laws Questions regarding the release or disclosure of patient and UAHP’s member information or violations of the federal or state privacy laws must be directed to the Compliance Officer.

UAHP’s Business Information Information obtained, developed or produced on behalf of UAHP by Staff and Business Partners is confidential and shall not be disclosed to anyone outside UAHP without proper authorization. Confidential information includes, but is not limited to patient or member lists, personnel data, fee

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schedules, clinical information, research data, financial data, legal advice/opinions and marketing strategies. Confidential information should be maintained in a secure location. Information expressly identified as “confidential” will be treated confidentially and access will be limited to those persons with a need to know. Staff who leave UAHP, as well as any other Business Partners who cease affiliation with UAHP may not take the originals or copies of any confidential and proprietary information and may not use this information for their own gain or that of another person or organization.

UAHP’s Staff Information UAHP Staff information, including social security numbers and personal identity data must be maintained in a confidential manner to protect the Staff from identity theft and to maintain the confidentiality of healthcare and benefits information. E. Avoid Conflicts of Interest A conflict of interest occurs when an individual’s personal interest interferes or appears to interfere with the interest of UAHP. Such conflicts can limit an individual’s ability to exercise due care, skill and judgment on behalf of UAHP. Because conflicts of interest may not always be clear cut, the Compliance Officer is available to answer questions that may arise. Staff and most Business Partners are screened for conflicts of interest at the time of hire and annually thereafter. Staff and Business Partners must review UAHP’s conflict of interest policy, read and sign UAHP’s conflict of interest attestation. Board Member and Key Staff Responsibilities All Board members and key Staff will recuse themselves from any discussion or decision affecting their business or personal interests. If an actual or potential conflict of interest should arise for a Board member, the Board member shall promptly inform the Chairman of the Board. F. Cooperate With All Investigations UAHP expects truthful and honest responses when participating in internal investigations or external agency reviews, audits or investigations. UAHP is prepared to demonstrate its program upon request by AHCCCS, CMS, the state or federal government, or its designee. Internal Investigations It may be necessary to conduct internal investigations to determine whether or not non-compliant activities have occurred. Cooperation and timely responses, without fear of retaliation, are required to ensure the prompt investigation and resolution of ethical and compliance issues. Concerns about retaliation should be reported to the Compliance Officer. Retaliation is prohibited against those who, in good faith, report inappropriate activities. Anyone who intentionally makes a false report or who has knowledge of or suspects a possible violation of laws or regulations and does not report it will be subject to disciplinary action up to and including termination.

Reviews by External Agencies UAHP cooperates with all reviews by authorized external agencies in a direct, open and honest manner. No action may ever be taken that would mislead the reviewer or the survey team. Government Investigations UAHP agrees to permit and will fully cooperate with any authorized federal or state officials who conduct an onsite review as well as all legal demands made in any government investigation of UAHP. AHCCCS or CMS officials may also audit UAHP records and inspect UAHP facilities. UAHP will allow reasonable access to UAHP Staff and Business Partners, members and records.

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Individuals approached by someone stating that they are a government agent, should confirm the representative’s authority by requesting identification and obtaining the person’s name, office, address, telephone number and identification number. Individuals must immediately notify their managers who will immediately notify the Compliance Officer who will determine the legitimacy and scope and establish the proper procedures for cooperating with the investigation.

Individuals may agree or refuse to talk with a government investigator and recognize that they have the right to seek legal counsel before responding to any questions. In all cases, it is imperative to tell the truth. It is against UAHP’s policy and a violation of the law to prevent, obstruct, mislead, delay or attempt to prevent, obstruct, mislead or delay the communication of information or records to a government investigator5. Staff and Business Partners that knowingly and willingly falsify, conceal, or cover up by a trick, scheme or device a material fact or make any false statements or fraudulent representations to a Federal agency may be subject to fines, imprisonment or both6. During a government investigation, all policies enabling the destruction of documents shall be suspended until the investigation has been completed and the Compliance Officer has reinstated the policies. If a subpoena or other legal document (such as a Civil Investigative Demand) from any government agency is received, the manager shall contact the Compliance Officer. G. Retention of Records Disposal or destruction of UAHP’s records is not discretionary. The retention and disposal or destruction of records will be in accordance with legal and regulatory requirements and UAHP policy. Records pertaining to litigation or a government investigation or audit will not be destroyed. Records that are subject to audit or current/threatened litigation may not be destroyed unless there is written notification of expiration of the litigation and record destruction is approved by Senior Management and the Compliance Officer. Records will be maintained in appropriate format (paper, microfilm, microfiche, electronic, and imaged) and available within the timeframes required by Federal and State regulations. The Compliance Officer or designee will oversee destruction of any records, which will comply with written policies and procedures. H. Accessing Electronic Information Staff and Business Partners are responsible for properly using information stored and produced by all information systems. Staff and Business Partners will comply with HIPAA and HITECH policies that reflect the legal requirements for protecting electronically submitted Protected Health Information (PHI). System users are responsible for preventing unauthorized access to the systems. Passwords and other security codes may not be shared. Accessing UAHP system records for any reason or adjusting UAHP policy file or claims or those of other Staff and/or Business Partners without proper authority is a violation of the Compliance Program and an offense that may subject an offending Staff and/or Business Partner to disciplinary action up to and including termination. Microcomputers, personal computers, internet access, e-mail or other communication systems are intended for business-related purposes only and not for use that may be considered disruptive, offensive, harassing or harmful to others. Each software package, unless specifically licensed for Local Area Network (LAN) use or site-licensed, may only be used on a single

5 18 U.S.C. § 1518 6 18 U.S.C. § 1518

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personal computer or microcomputer. Unless expressly permitted by the software license agreement, software cannot be copied for use on more than one UAHP or personal computer or microcomputer. I. Prohibited Insider Trading If any UAHP Staff becomes aware of non-public information about the Medicare line of business or another related company as a result of their affiliation, law prohibits disclosing this information to anyone. As a UAHP Staff member, you are prohibited from buying or selling securities based on this information. This also includes using insider trading to make investment decisions relative to UAHP’s competitors. If you have any questions regarding adhering to trading laws, or are aware of others who may be in violation, notify the Compliance Officer immediately. J. Commitment to Employment Relationship UAHP believes that Staff should be able to work in a professional atmosphere without fear of retribution. Retaliation is prohibited against those who, in good faith, report inappropriate activities. Good faith is defined as a full, fair, accurate and timely disclosure.

In addition, UAHP is committed to providing a work environment that is free of harassment and discrimination in all aspects of the employment relationship, including recruitment and employment, work assignment, promotion, transfer, salary administration, selection for training, corrective action and termination. All UAHP Staff are required to observe our commitment and extend to each other appropriate behavior in the workplace. All UAHP Staff should be familiar with UAHP’s policies and procedures. Any questions on these policies should be directed to your supervisor or the Compliance Officer. K. Seeking Guidance and Reporting Violations Staff and Business Partners must report any actual or suspected violation of this Compliance Program by completing an incident form; speaking to their supervisors; UAHP management; reporting the matter to the Compliance Officer via phone call, email, in-person report, mail or fax (see page 6 for contact information); or by calling the toll free Compliance Hotline at 1-800-726-0713. All inquiries are confidential subject to the limitations imposed by law. Retaliation is prohibited against those who, in good faith, report inappropriate activities. Good faith is defined as a full, fair, accurate and timely disclosure. Anyone who intentionally makes a false report or who has knowledge of a possible violation of a law or regulation and does not appropriately report it will be subject to disciplinary action up to and including termination. L. Enforcement of Corrective Action and/or Discipline Individuals who violate any of the Compliance Program requirements or violate related UAHP policies and procedures and anyone who knowingly fails to report violations or any supervisor, officer or agent who fails to oversee compliance by those he or she supervises is subject to corrective action and/or disciplinary action up to and including termination. Violations may also result in criminal referral and reports to law enforcement and government agencies. Any individual who harasses or threatens a UAHP Staff and/or Business Partner for reporting violations will be terminated. Written Policies and Procedures UAHP expects Staff and Business Partners to behave in a manner that demonstrates a strong commitment to comply with all Federal and State regulations, standards and sub-regulatory guidance. UAHP’s policies and procedures list the steps that Staff and Business Partners are required to follow. Staff and Business Partners are expected to make every reasonable effort to

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ensure that other Staff and Business Partners comply with these laws and regulations. Should a Staff or Business Partner suspect a violation of any law, regulation or policy, the Staff and/or Business Partner must report their suspicion to the Compliance Officer or Compliance Hotline at 1-800-726-0713. UAHP maintains a repository of policies and procedures so that Staff and Business Partners can know and understand their individual responsibility for compliant and ethical business practices. UAHP policies and procedures are reviewed and revised at least annually or more frequently if there are changes in regulatory requirements or business needs. UAHP policies & procedures are the infrastructure which supports UAHP Core Standards described above and demonstrate to Staff and Business Partners a commitment to operating in an appropriate and compliant manner. In addition, UAHP policies & procedures provide Staff and Business Partners with needed direction to comply with federal, state and UAHP laws, regulations, rules and requirements and to reduce potential fraud, waste and abuse in daily operations. UAHP policy & procedures must be followed by Staff or Business Partners to conduct operations in a compliant manner; to respond to potential risks and to help reduce the prospect of fraud, waste or abuse UAHP policies & procedures are created within departments or department units to address contractual elements of UAHP’s contracts with AHCCCS and CMS. In addition, UAHP utilizes UAHN corporate policies & procedures to address over-arching protocols, processes or activities, such as in the area of compliance, human resources and information services. The UAHP Compliance Department has a dedicated employee who manages the development, writing, approval, storage and retrieval of UAHP policies & procedures. UAHP has created a set of tools and templates that the policy authors must use to create and revise policies & procedures. Upon completion of a review and/or revision of a policy & procedure by a policy & procedure author, the policy & procedure is subject to a formalized review process. After review and approval by the department or department unit’s Director, UAHP has a standing Policy & Procedure Committee that reviews and approves all policies & procedures in order to ensure consistency in formatting and design; to ensure that required elements are included; to reduce potential conflict with other policies & procedures; to ensure appropriate authority and sound business and operational practice. Upon receiving Policy & Procedure Committee approval, policies & procedures are reviewed and approved by the department or department unit’s Executive sponsor. UAHP Staff are expected to access UAHP policies & procedures which are housed in UAHP’s Sharepoint site “Policies & Procedures” on the UAHP intranet by selecting the “Policies & Procedures” hyperlink on UAHP’s intranet home page. Additionally, UAHP staff may also access UAHN corporate policies & procedures which are housed on the corporate intranet. In addition, UAHP Business Partners are provided with access to key policies & procedures in provider manuals, on UAHP websites and upon request. UAHN Compliance Program Policies & Procedures The following UAHN Corporate policies & procedures support this Compliance Program and work in conjunction with UAHP policies & procedures and daily practices: A103 Conflict of Interest A108 Disaster Recovery Policy A120 Custodian of Records A121 Records, Retention, Archiving, Disposal A130 Security Policy – Computer Systems A135 Security Identification – Access Badges A400 Corporate Ethics and Compliance Program

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CC001 Business Associates Agreement Policy CC003 The Federal False Claims Act A403 HIPAA Privacy and Security Program HIPAA 01 Breach Notifications HIPAA 03 Privacy Complaints HIPAA 05 Family or Other Persons Involved in Care HIPAA 07 Individual Privacy Rights HIPAA 08 Marketing HIPAA 10 Minimum Necessary HIPAA 11 Notice of Privacy Practices HIPAA 12 Disclosures to Avert a Serious Threat HIPAA 13 Treatment, Payment and Health Care Operations HIPAA 14 Valid Authorization and Release of PHI HR102 Standards of Conduct and Corrective Action HR103 Termination of Employment UAHP Over-Arching Compliance Program Policies & Procedures The following over-arching UAHP policies & procedures support this Compliance Program and apply to all UAHP lines of business: CP 604 Reporting Compliance Issues CP 605 Compliance Investigation Process AD 101 Annual Review AD 106 New Employee Orientation and Training AD 115 Telecommuting UAHP AHCCCS Compliance Program Policies & Procedures The following UAHP policies & procedures support this Compliance Program and apply to all AHCCCS lines of business: AD 114 Cultural Competency AD 219 Administrative Contracts and Consultant Agreements CP 100 Fraud and Abuse CP 101 Disclosure of Ownership Information and Control CP 102 Disclosure of Information on Persons Convicted of Crimes CP 108 Corrective Action CP 116 Policy Format and Review CP 204 Maintenance and Retention of Documents, Member Records and All Related Business

Documents CP 215 Disaster Recovery Plan CP 216 Business Continuity Plan CP 217 Compliance Program CP 218 Code of Conduct CP 221 Compliance Officer Responsibilities CP 226 Regular and Periodic Compliance Audit of Subcontracted Vendors CP 227 Monitoring and Auditing CP 228 FWA Provider Awareness CP 229 FWA Employee Awareness CP 230 Custodian of Records CP 240 Training Material Preparation, Documentation and Tracking CS 204 Prior Authorization CS 212 Over and Under Utilization ND 123 Delegated Administrative Service Agreements

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UAHP Medicare Compliance Program Policies & Procedures The following UAHP policies & procedures support this Compliance Program and apply to all Medicare lines of business: AD 114 SNP Cultural Competency AD 219 SNP Administrative Contracts and Consultant Agreements CP 100 SNP Fraud, Waste and Abuse CP 101 SNP Disclosure of Ownership Information and Control CP 102 SNP Disclosure of Information on Persons Convicted of Crimes CP 108 SNP Corrective Action CP 116 SNP Policy Format and Review CP 204 SNP Maintenance and Retention of the University of Arizona Health Plans’ Documents,

Member Records and All Related Business Documents CP 215 SNP Disaster Recovery Plan CP 217 SNP Compliance Program CP 218 SNP Code of Conduct CP 221 SNP Compliance Officer Responsibilities CP 227 SNP Monitoring and Auditing CP 228 SNP FWA Provider Awareness CP 229 SNP FWA Employee Awareness CP 240 SNP Training Material Preparation, Documentation and Tracking CP 800 Marketing and Sales Ethics CP 801 Employee and Committee Member Confidentiality and Non-Disclosure CP 802 Conflict of Interest CP 806 Sales Allegation CP 807 Complaint Tracking Module (CTM) CP 831 CMS Annual Risk Assessment CP 832 Offshore Outsourcing CS 204 SNP Prior Authorization CS 212 SNP Over and Under Utilization ND 123 Delegated Administrative Service Agreements UAHP requires that a delegated Business Partners maintain policies & procedures that meet or exceed UAHP policies & procedures and are compliant with AHCCCS and CMS rules, regulations or requirements. UAHP will audit delegated Business Partner’s policies & procedures to ensure compliance as outlined in Component 7: Auditing and Monitoring Component 2: Compliance Officer, Compliance Committee and High Level Oversight The Compliance Officer shall serves in an independent role as the primary focal point for UAHP compliance activities. The Compliance Officer has primary responsibility for overseeing and monitoring the Compliance Program implementation as well as ensuring that all policies and procedures are accurate and integrated into UAHP’s operations. Coordination and communication of compliance activities are key functions of the Compliance Officer. The Compliance Officer must reside in the State of Arizona and report directly to UAHP’s CEO and has express authority to provide unfiltered, in-person reports to the UAHN Board of Directors (Board) at the Compliance Officer’s discretion. The Compliance Officer need not await approval of UAHP’s Board to implement needed compliance actions and activities. UAHP does not delegate compliance program administrative functions, including the Compliance Officer, Compliance Committee, compliance reporting to senior management, etc. UAHP may use FDRs for

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compliance activities such as monitoring, auditing and training. UAHP maintains ultimate responsibility for fulfilling the terms and conditions of its contract with CMS, AHCCCS, and other state and federal entities. The Compliance Officer and Compliance Committee must periodically report directly to UAHP’s Board on the activities and status of the Compliance Program, including issues identified, investigated and resolved by the Compliance Program. UAHP’s Board must be knowledgeable about the content and operation of UAHP’s Compliance Program and must exercise reasonable oversight with respect to the implementation and effectiveness of the Compliance Program. Compliance Officer Responsibilities UAHP has written criteria for selecting a Compliance Officer. The Compliance Officer has a job description that clearly outlines the responsibilities and authority of the position, which includes: Is vested with the day-to-day operations of the compliance program and is an employee of

UAHP. Defines the Compliance Program structure, educational requirements, reporting and complaint

mechanisms, response and correction procedures and compliance expectations for all Staff and Business Partners

Oversee and monitor the implementation of the Compliance Program. Ensure Staff and Business Partners receive, review and fully understand the Compliance

Program. Answer Staff and Business Partners questions concerning compliance issues that are not

readily answered in this Compliance Program. To ensure that the most current government policies and procedures are reflected,

periodically review and revise the Compliance Program and Code of Conduct. Verify that all UAHP policies reflect current coverage determinations, payment alerts and

applicable regulations, statute and guidance. Ensure the annual Compliance Program is reviewed and approved by the Compliance

Committee and Board. Once approved, ensure distribution to all Staff and Business Partners. Hold periodic meetings with UAHP’s management team to review the Compliance Program

and ensure that compliance reports are provided regularly to UAHP’s CEO, Board and Compliance Committee. Reports should include the status of UAHP’s Compliance Program implementation, the identification and resolution of suspected, detected or reported instances of noncompliance, and UAHP’s compliance oversight and audit activities.

Ensure procedures are in place to screen monthly for ineligible providers, Staff and Business Partners. These individuals must not appear in the Social Security Administration Death Master File, The National Plan and Provider Enumeration System (NPPES), List of Excluded Individuals (LEIE),The Excluded Parties List (EPLS), the General Service Administration (GSA) list of debarred individuals/contractors, and any other databases directed by AHCCCS or CMS. Coordinate any resulting personnel issues with UAHP’s Human Resources, Security, Legal or other departments as appropriate.

Develop and participate in educational and training programs that focus on compliance issues. Ensure that Staff and Business Partners, including Quality Management/Performance Improvement Committee members, are informed and comply with applicable federal and state regulations, standards and sub-regulatory guidance and UAHP’s Code of Conduct. Ensure Compliance Program educational and training programs are provided to Staff and Business Partners providing health and administrative services to UAHP.

Objectively and independently investigate and act on compliance issues and direct internal investigations and any subsequent corrective measures with all departments, Staff and Business Partners providing health and administrative services on behalf of UAHP.

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Create policies, reporting procedures, programs and communication materials that are well defined and published which encourage all Staff and Business Partners to report program noncompliance and suspected fraud, waste and abuse and other improprieties. This responsibility includes communication of non-retaliation policies and employee protection measures.

Create, periodically review and revise UAHP fraud, waste and abuse policies and procedures to meet changing regulations and trends.

Respond to reports of potential and observed instances of fraud, waste or abuse; coordinate internal investigations and oversee the development and monitoring of the implementation of appropriate corrective or disciplinary actions as necessary.

Ensure that all government and operational materials and manuals that Staff and Business Partners use are current and are updated on a regular basis.

Being aware of daily business activity by interacting with the operational units of UAHP. Maintaining the compliance reporting mechanism and closely coordinating with the internal

audit and FWA Staff. Maintaining documentation for each report of potential noncompliance or potential FWA

received from any source, through any reporting method (e.g., hotline, mail, or in-person). Collaborate with other programs, commercial payers and other organizations where

appropriate, when a potential FWA issue is discovered that involves multiple parties. The Compliance Officer has the authority to interview employees and other relevant

individuals regarding compliance issues. Review company contracts and other documents pertinent to the Medicare program. Review or delegate the responsibility to review the submission of data to CMS or AHCCCS to

ensure that it is accurate and in compliance with CMS or AHCCCS reporting requirements. Independently seek advice from legal counsel. Report potential FWA to CMS, AHCCCS, its designee or law enforcement. Conduct and/or direct audits and investigations of any FDRs. Conduct and/or direct audits of any area or function involved with Medicare Part C or D plans. Recommend policy, procedure and process changes. .Compliance Committee Oversight The Compliance Officer chairs the Compliance Committee. The Compliance Committee oversees the Medicare and Medicaid Compliance Program and is responsible for reviewing the development, documentation, periodic audit/review of internal controls, and training on risk areas which are annually determined via UAHP’s risk assessment. This Compliance Committee is accountable to UAHP’s senior-most leader and Board and will meet at least quarterly to ensure that compliance and compliance-related activity is consistent across the company. The Compliance Officer will provide quarterly compliance reports to the Board. The Compliance Committee will advise the Compliance Officer and assist in implementing the Compliance Program. Compliance Committee members should include individuals with a variety of backgrounds, and reflect the size and scope of UAHP. Members should have decision-making authority in their respective areas of expertise. It must include the Compliance Officer, UAHP’s Chief Financial Officer, members of senior management, as well as auditors, pharmacists, and registered nurses and other members with the authority to commit resources and are best positioned to understand compliance vulnerabilities within their respective areas of expertise. The Compliance Committee will assist the Compliance Officer in monitoring, reviewing and assessing the effectiveness of the Compliance Program and timeliness of reporting has the following responsibilities with respect to compliance activities:

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Ensures that UAHP has established and effective processes to detect, correct and prevent non-compliance.

Ensures that UAHP has a system for Staff and Business Partners to ask compliance questions and raise concerns in a timely manner confidentially or anonymously (if desired), without fear of retaliation.

Ensures that UAHP has appropriate, up-to-date compliance policies and procedures which address Compliance Program components.

Periodically reviews of the training plan and ensuring that training and education are effective and appropriately completed.

Works with the appropriate departments to develop standards of conduct and policies in order to promote adherence to the Compliance Program.

Recommends, monitors and reviews the effectiveness, in conjunction with appropriate departments, of the development of internal systems and controls designed to ensure compliance with UAHP’s standards, policies and procedures as a part of daily operations.

Developing strategies to promote compliance with the Compliance Program and detect any potential violations.

Approves a system to solicit, evaluate and respond to complaints and problems. Reviews and addresses reports of monitoring and auditing in areas that UAHP is at risk for

program noncompliance or potential FWA and ensuring that corrective action plans are implemented and monitored for effectiveness.

Assists in the creation, implementation and monitoring of effective corrective and preventive action plans.

Develops innovative ways to implement appropriate corrective and preventative action. Complies with applicable regulations regarding self-reporting of identified compliance issues

to appropriate state and federal authorities. Assists with the creation and implementation of the compliance risk assessment and of the

compliance monitoring and auditing work plan. Supports the Compliance Officer’s needs for sufficient Staff and resources to carry out the

Compliance Officer’s duties. Ensures that UAHP has a method for members to report potential FWA. Provides regular and ad hoc reports on the status of compliance with recommendations to

UAHP’s Board. High Level Oversight UAHP’s Board conducts reasonable oversight with respect to the implementation and effectiveness of UAHP’s Compliance Program. When compliance issues are presented to UAHP’s Board, it makes further inquiry and takes appropriate action to ensure the issues are resolved. UAHP’s Board receives training and education as to the structure and operation of the Compliance Program. The Board is knowledgeable about compliance risks and strategies, understands the measurements of outcome, and is able to gauge effectiveness of the Compliance Program. Board oversight includes: Approving the Standards of Conduct. Understanding the Compliance Program Structure. Remaining informed about the Compliance Program outcomes, including results of internal

and external audits. Remaining informed abut governmental compliance enforcement activity such as Notices of

Non-Compliance, Warning Letters and/or more formal sanctions. Receiving regularly scheduled, periodic updates from the Compliance Officer and Compliance

Committee.

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Reviewing the results of performance and effectiveness assessments of the Compliance Program.

The Board collects and reviews measurable evidence that the Compliance Program is detecting and correcting Medicare and Medicaid program noncompliance on a timely basis. UAHP takes steps to ensure that CMS is able to validate, through review of Board meeting minutes or other documentation the active engagement of the Board in the oversight of the Compliance Program. UAHP’s CEO and senior management are highly engaged in the Compliance Program. The Executive Team recognizes the importance of the Compliance Program in UAHP’s success. The CEO and Executive Team ensures that the Compliance Officer is integrated into the organization and is given the credibility, authority and resources necessary to operate a robust and effective Compliance Program. UAHP’s CEO receives periodic reports from the Compliance Officer of risk areas facing the organization, the strategies being implemented to address them and the results of those strategies. The CEO is also advised of all governmental compliance enforcement activity, from Notices of Non-compliance to formal enforcement actions. Component 3: Effective Training and Education Training and education of Staff (which includes all employees, managers and directors) and Business Partners (which includes all UAHP FDRs) is an important component of UAHP’s Compliance Program, especially training related to compliance. Compliance training and education is required of all new Staff hires within 90 days of initial hiring and annually thereafter. Staff and Business Partners are required to participate in training sessions and will be required to attest that they have received, read, understood and will apply the written materials describing various laws, regulations and policies. UAHP managers are responsible for ensuring that Staff and Business Partners have completed all required compliance training. Required training courses are delivered via classroom sessions or electronically via HealthStream (a web-based training program) for Staff; and via online training modules, UAHP websites or paper documents for all other Staff and Business Partners. HealthStream tracks training completion rates and alerts managers to any overdue training requirements. The Network Development Department tracks completion of all FDR training and supplies completion reports to the Compliance Department. FDRs who have met the fraud, waste and abuse certification requirements through enrollment into the Medicare program or accreditation as a Durable Medical Equipment, Prosthetics, Orthotics, and supplies (DMEPOS) are deemed to have met the training and educational requirements for fraud, waste and abuse. Staff and Business Partners receive regular reminders of training requirements. Completion of mandatory training is tied to each employee’s annual performance goals. Failure to complete required training will result in performance actions, possibly including termination of employment. Formal Standardized Training Programs Staff and Business Partners will receive standard training regarding the organization and its adherence to Federal and State statutes and requirements. Corporate Compliance, Corporate Training, UAHP Compliance and UAHP Quality Management are responsible for developing the curriculum and organizing the trainings All training materials and curricula will be designed to address the various skills, knowledge and experience of Staff and Business Partners. Standard trainings will include the following: Compliance Program (Staff only) Code of Conduct

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Conflict of Interest Fraud, Waste and Abuse Corporate Compliance (Staff only) Quality Management Training (Staff only) HIPAA and Privacy (Staff only) Customer Service (Staff only)

Formal Specialized Training Programs Staff and Business Partners will receive specialized training based on their roles and responsibilities within UAHP. Specialized training will be relevant to the Staff or Business Partner’s role in the organization. The specialized training will include adherence to Federal and State statutes and requirements. UAHP Departments are responsible for developing the curriculum and organizing the trainings. All training materials and curricula will be designed to address the various skills, knowledge and experience of Staff and Business Partners Specialized trainings will include the following: Staff and Business Partners are provided with written copies of relevant laws, regulations and

guidelines regarding activities conducted by that Staff or Business Partner or that Staff or Business Partner’s department. Training materials will include the relevant policies & procedures; relevant government requirements, rules, regulations and/or guidance specific to that Staff or Business Partner or that Staff or Business Partner’s department as well as access to AHCCCS or CMS resources.

Specialized trainings that are topical to daily work performance and responsibilities may be based on a new or changing regulation or business requirement, or to enhance an area that has been identified as a potential risk for non-compliance or operational inefficiency, or for which a corrective action plan has been issued.

Staff and Business Partners are required to complete all assigned training modules and/or read the assigned materials and must sign (attest) that they have received, read and understand the training. Many training modules include a test that Staff are required to pass. The Compliance Department retains the signed/electronic attestations and will monitor to ensure that 100% of Staff and Business Partners complete all required training. UAHP has a training document library on Sharepoint which will house all training documentation. UAHP will maintain ongoing communication and distribute information to Staff and Business Partners regarding compliance issues in order to reflect the most recent and accurate information available regarding applicable federal and state laws and regulations. Component 4: Effective Lines of Communication Creating a culture of compliance throughout the organization is an important strategic goal for UAHP. This is accomplished by establishing and implementing effective lines of communication, ensuring confidentiality between the Compliance Officer, members of the Compliance Committee, UAHP Staff and Business Partners (especially First Tier, Downstream and Related Entities). UAHP regularly communicates the importance of complying with regulatory requirements and reinforcing UAHP expectations of ethical and lawful behavior. Information communicated includes the Compliance Officer’s name, office location and contact information (see page 6 for contact information); laws, regulations and guidance for UAHP and Business Partners (such as statutory, regulatory and sub-regulatory changes (e.g., HPMS memos) and changes to policies and procedures and the Code of Conduct. Staff and Business Partners are free to communicate their concerns to the Compliance Officer via phone call, email, in-person report, mail or fax (see page 6 for contact information) or to any member of the Compliance Committee. The methods available for reporting compliance or FWA concerns and the non-retaliation policy are publicized via posters, the Compliance Program,

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Compliance Week, training programs, UAHP’s intranet and websites for all lines of business. To support this regular communication, UAHP has established systems to receive, record and respond to compliance questions or reports of potential or actual non-compliance from Staff or Business Partners or members/beneficiaries. UAHP educates Staff, Business Partners and enrollees about identifying and reporting potential FWA. Education is published on UAHP websites, and in UAHP’s provider manual and member handbook. To further ensure effective lines of communication between UAHP and FDRs, employees of UAHP’s Compliance Department are members of recurring Joint Operations Committee (JOC) meetings between UAHP and delegated FDR’s. JOC meetings are designed to ensure ongoing oversight of a delegated FDR’s performance and to also encourage the regular exchange of information related to routine operations. JOCs meeting are documented with formal minutes. Any issue of noncompliance identified at a JOC must be reported to the Compliance Officer or to members of the Compliance Committee for investigation and action. Any reports from Staff, Business Partners and enrollees received through any channel of communication of a potential or observed violation of compliance policies, federal and state requirements, regulations or statues will be documented and investigated promptly by the UAHP Compliance Department and Compliance Officer to determine authenticity and significance. This includes any reports of suspected fraud, waste and abuse. A log is maintained to record all reports, including the nature of any investigation and its results, and the identification of patterns and opportunities for additional training or corrective action. This information is reviewed by the Compliance Officer and reported to the Compliance Committee and UAHP Board. These reports are documented in Compliance Committee and Board minutes. UAHP has written policies of non-retaliation toward any person who reports a potential or observed violation. Staff and Business Partners are made aware of these policies and encouraged to report incidents of potential or observed fraud, waste or abuse or other concerns. All involved are made aware that the identity of any anonymous reporter may have to be revealed. Effective communication can occur via multiple avenues including accessing the Compliance Officer via phone call, email, in-person report, mail or fax (see page 6 for contact information); accessing any member of the Compliance Committee; contacting the Compliance Department; communicating with a UAHP supervisor, manager, director or chief; or calling the Compliance hotline at 1-800-726-0713. Any Staff or Business Partner aware of any violation of the Code of Conduct has a duty to report the violation. UAHP Communication Options An open line of communication between the Compliance Officer and Staff or Business Partners is critical to the success of the Compliance Program and these lines of communication are accessible to all. Staff or Business Partners are expected and encouraged to report any actual or suspected violation of the laws or regulations relating to Medicare, AHCCCS or any other State or Federal law. Staff or Business Partners are required to report any compliance concerns to a supervisor, the Compliance Officer via phone call, email, in-person report, mail or fax (see page 6 for contact information), the Compliance Hotline at 1-800-726-0713 or to UAHP’s CEO. Any Staff or Business Partner who is aware of a violation of the law or regulation and does not report it, or who is not aware of a violation of a law or regulation that should have been detected, is subject to disciplinary action, up to and including termination of employment or relationship with UAHP. The following are the guidelines Staff and Business Partners follow for communication of a compliance question or concern: When appropriate, Staff or Business Partners are encouraged to first discuss compliance

questions or concerns with a supervisor or UAHP contact. If the Staff or Business Partner feels uncomfortable discussing the issue with a supervisor or UAHP contact or believes the

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supervisor or UAHP contact has not properly addressed concerns, they can contact the Compliance Officer or UAHP’s CEO.

Staff or Business Partners seeking advice from the Compliance Officer have the option to remain anonymous and all inquiries are confidential subject to the limitations imposed by law.

Staff or Business Partners may make a report without fear of retaliation. Retaliation is prohibited against those who, in good faith, report inappropriate activities. Good faith is defined as a full, fair, accurate and timely disclosure. If a Staff member or Business Partner is unwilling to identify him/herself despite this protection, they may make an anonymous report. If a Staff member or Business Partner does not identify him or herself, the state and federal whistleblower laws may not apply.

The Compliance Officer maintains an “open door” policy and confidential voicemail mailbox for Staff or Business Partners seeking to report a suspected or observed violation.

Hotline for Reporting Potential Misconduct All calls to the UAHP hotline are investigated by Corporate Compliance or the UAHP Compliance Officer or designee. UAHP tracks calls to the hotline to ensure proper investigation and resolution and to identify patterns and opportunities for additional training or corrective action. Staff or Business Partners who want to report potential Misconduct can use the contracted

toll-free Compliance Hotline number at 1-800-726-0713 to confidentially and anonymously report potential or observed violations of UAHP’s compliance policies or federal or state requirements. UAHP will make every reasonable effort to maintain the anonymity of any Staff or Business Partner who reports suspected or observed Misconduct, but they will be informed that there may be some circumstances under which it is necessary to disclose the reporter’s identity during the investigation. Reports and questions can also be directed to UAHP management team, the Compliance Officer or UAHP’s CEO. If a Staff member or Business Partner makes an anonymous report, they will be provided with a reference number for future contact. Should the reporter request to receive confidential updates regarding to their reported concern, the reporter may confidentially re-contact the Compliance Hotline (1-800-726-0713) and use the reference number to obtain updates from Compliance Hotline representatives.

Enrollees, providers or other individuals who want to report potential or observed Misconduct, or potential FWA should contact the Customer Care Center at 1-800-582-8686, the toll-free Compliance Hotline number at 1-800-726-0713, the Compliance Officer or UAHP’s CEO. They can remain anonymous if they wish, but they will be informed that their identity may need to be revealed during the investigation.

Compliance Resources The Compliance Officer can be reached at: (520) 874-5075 or (602) 344-8389; via email at [email protected]; via fax at the fax number below; or via U.S. mail at the address below. The Compliance Officer has an open door policy and has offices for in-person reports at both the Elvira address below and at 2502 E. University Drive, Suite 125, Phoenix AZ 85034. UAHP’s CEO can be reached at: (520) 874-5531

If you are unsure about who to contact with a compliance-related question or issue, or if you receive a response you do not consider adequate, you may contact the Compliance & Audit Department in confidence using one of the following methods:

Confidential and Anonymous Compliance Hotline: 1-800-726-0713* 24 hours/day & 7 days/week. *Service provided by outside agency; no caller ID is used

Compliance & Audit Department: (520) 874-5075

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U.S. Mail: University of Arizona Health Plans, Compliance & Audit Dept. 2701 E. Elvira Road Tucson, AZ 85756

Interoffice Mail Compliance & Audit Dept. Elvira Road

Email [email protected]

Fax Secure Fax: (520) 874-7072

Component 5: Well-Publicized Disciplinary Standards As part of UAHP’s Compliance Program, UAHP has published the Code of Conduct, which articulates: 1) Expectations for reporting compliance issues and how Staff and Business Partners will be assisted in issue resolution; 2) The requirement that Staff and Business Partners identify non-compliance and unethical behavior, and; 3) Provides for timely, consistent and effective enforcement of the standards when noncompliance or unethical behavior is determined. Staff and Business Partners are required to comply with the Code of Conduct and to report any situation where a Staff member or Business Partner believes illegal, unethical or noncompliant conduct may have occurred. FDRs must comply with UAHP’s Code of Conduct or demonstrate that the FDR has implemented a similar Code of Conduct. UAHP takes the Code of Conduct seriously and will immediately investigate and take disciplinary action if anyone violates the Code of Conduct, UAHP policy or the law. Enforcing the Code of Conduct UAHP’s policies provide specific instructions for handling reports of potential violations of UAHP policies, rules, regulations or law. Any Staff or Business Partner who identifies a potential violation of policy or law, noncompliance or unethical behavior is required to report the matter to their supervisor, manager, director, Compliance Officer, the Compliance Hotline at 1-800-726-0713 or the CEO. See UAHP policy CP 604 Reporting Compliance Issues UAHP does not tolerate retaliation. No Staff or Business Partner may discriminate or retaliate against another Staff, Business Partner or member who has, in good faith, complied with the requirements of the Compliance Program by reporting his or her concerns to a supervisor, manager director, the Compliance Officer, the Compliance Hotline at 1-800-726-0713 or the CEO. Publicizing Disciplinary Guidelines UAHP provides guidance about disciplinary action against any Staff and Business Partners who fail to comply with UAHP’s Code of Conduct, policies and procedures, federal and state health care program requirements and laws, as well as those who have engaged in wrongdoing. This guidance is provided in this Compliance Program; in UAHN policy HR102 Standards of Conduct and Corrective Action, HR103 Termination of Employment; in UAHP policy CP604 Reporting Compliance Issues, CP108 and CP108SNP Corrective Action and CP217 and CP217 SNP Compliance Program. UAHP will enforce its disciplinary policies consistently. UAHP educates Staff and Business Partners about these standards through its Compliance Program, recurring training, policies & procedures, Business Partner contracts and reference manuals. Staff and Business Partners are made aware that failure to report violations due to negligence or reckless conduct may result in disciplinary action. Sanctions for Staff range from oral warnings to immediate termination of employment, or other sanctions as appropriate. Disciplinary actions for Business Partners range from contract sanctions to immediate contract termination, as appropriate. Disciplinary policies are made available to Staff via UAHP’s intranet and externally to Business Partners via UAHP websites.

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Employment of and Contracting with Ineligible Persons UAHP will not delegate substantial authority to make decisions to entities that it knows, or should have known, have a propensity to engage in inappropriate or improper conduct. UAHP’s organizational policies prohibit hiring or entering into contracts with individuals or entities who have been recently convicted of a criminal offense related to health care; or who are listed as debarred, suspended, and excluded; or are ineligible for participation in federal health care programs; or lawfully prohibited from participating in any public procurement activity; or from participating in non-procurement activities. UAHP will conduct monthly screenings of all Staff and Business Partners to verify if they appear in the following lists or databases: The Social Security Administration Death Master File; The National Plan and Provider Enumeration System (NPPES); the Department of Health and Human Services Office or Inspector General List of Excluded Individuals / Entities (http://oig.hhs.gov/fraud/ exclusions.html); The Excluded Parties List (EPLS); and any other databases directed by AHCCCS or CMS. UAHP requires that any FDR who is delegated to perform administrative functions on behalf of UAHP also conduct this sanction screening and prohibits hiring or entering into contracts as outlined above. Enforcing Disciplinary Standards UAHP enforces disciplinary standards in a timely, consistent and effective manner when noncompliance or unethical behavior is determined. UAHP policy CP604 Reporting Compliance Issues and CP605 Compliance Investigation Process provide a detailed outline of the reporting, timely investigation and enforcement of discipline standards. Records are maintained for a period of 10 years for all compliance violation disciplinary actions and UAHN periodically reviews records of discipline to ensure that disciplinary actions are appropriate to the seriousness of the violation fairly and consistently administered and imposed within a reasonable timeframe. The Compliance Program requires that the promotion of and adherence to all elements of its compliance program will be factors in evaluating the performance of all appropriate employees. Employees will be periodically trained in new and revised compliance policies and procedures as appropriate. The Compliance Program includes several key policies that impact Human Resources operations and activities. Component 6: Effective System for Routine Monitoring and Identification of Compliance Risks An ongoing evaluation process is critical to having a successful Compliance Program. The Compliance Program incorporates ongoing UAHP internal monitoring and auditing activities; regular reporting of audit outcomes to the Compliance Officer, UAHP executives, the Compliance Committee and Board; and implementing correction, as necessary to improve contract compliance and operational excellence. This process of UAHP self-identification and corrective action along with monitoring the effectiveness of the corrective action is a key component of the Compliance Program. Before monitoring and auditing begins, an annual risk assessment must be conducted to identify areas of risk within UAHP. From this risk assessment, the audit program is developed. General auditing and monitoring of UAHP operations is done utilizing UAHP’s established metrics. The metrics for evaluating UAHP’s compliance with regulatory standards are drawn from UAHP’s contracts with CMS and AHCCCS. These metrics become the basis for the monitoring and auditing program and allows UAHP to identify areas that require corrective action Auditing and monitoring activity also includes oversight of administrative activities that UAHP has delegated to an FDR to ensure FDR’s compliance with all federal and state laws and regulations.

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http://oig.hhs.gov/fraud/

General Auditing and Monitoring Process UAHP has developed procedures for internal auditing and monitoring that will assess compliance with federal and state regulations and all applicable laws as well as internal policies and procedures. UAHP’s general auditing and monitoring procedures include, but are not limited to, the following components: Risk Assessment While a risk assessment is required for the Medicare line of business, UAHP conducts a risk assessment for all lines of business. A formal risk assessment is completed once a year, however, UAHP’s Compliance Department continuously reviews the risk assessment to ensure that UAHP can respond to new issues that arise. The Risk assessment is ranked to determine areas within the organization at greatest risk for fraud, waste and abuse. The Compliance Officer and/or members of the Compliance Committee participate in the risk-assessment process. UAHP’s auditing and monitoring activities will focus on the areas identified as high risk. UAHP will document its annual risk assessment activities, findings and any corrective or preventive actions adopted. The annual risk assessment will utilize data and information from a variety of sources, including, but not limited to: Regulatory risks based on CMS or AHCCCS guidance Risks as identified in the OIG work plan or AHCCCS Program Integrity Guidance Audit findings from CMS or AHCCCS Notices of Non-Compliance from CMS or AHCCCS Complaints filed with CMS on its Complaint Tracking Module (CTM) or AHCCCS Pharmacy & Therapeutics Committee CMS or AHCCCS payment operations and bid preparation Complaints related to Medicare sales and marketing issues Secret shopper issues and findings identified by CMS Audit findings from business unit self-audits Identified high risk areas including but not limited to marketing and enrollment violations,

agent/broker misrepresentation, selective marketing, enrollment/disenrollment noncompliance, credentialing, quality assessment, appeals and grievance procedures, benefit/formulary administration, transition policy, protected classes policy, utilization management, accuracy of claims processing, detection of potentially fraudulent claims, and FDR oversight and monitoring.

Corrective Action Plan monitoring

The result of the risk assessment drives the development of the annual audit work plan for oversight audits. The annual audit work plan may be modified based on issues that arise within UAHP during the execution of the annual audit work plan. Compliance audits are based on regulatory guidance and, depending on the department being audited, may rely on CMS or AHCCCS guidance. For Medicare, the basis for specific audits may be outlined in the Medicare Managed Care Manual, the Medicare Prescription Drug Benefit Manual, the CMS Monitoring Guide and/or other applicable CMS guidance. For AHCCCS, the basis for specific audits may be outlined in the AHCCCS Contractor Operations Manual (ACOM), the AHCCCS Medical Practice Manual (AMPM), and/or other applicable AHCCCS guidance. The audit work plan includes: Audits to be performed Audit schedules, including start and end dates Audit methodology Type of audit: desk or onsite Person(s) responsible Follow-up activities from findings to determine if implemented corrective actions have fully

addressed the underlying problems

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Internal Audit The Compliance Department has an implemented audit function which includes adequate and dedicated audit staff who are responsible to perform quality audits as part of its overall program to identify and reduce risk and ensure compliance with Medicare and Medicaid regulations. Staff dedicated to the audit function are knowledgeable about operational requirements for the areas under review and are independent and do not engage in self-policing. UAHP’s audit process of all functional areas may include scheduled, unannounced or spot check audits, including, but not limited to, the following: Claims processing to attain a reasonable assurance that payments are being prepared

correctly, including edits that will identify potential fraud, waste and abuse at the point of sale Customer Care and Enrollment/Disenrollment to include analysis of disenrollment data to

identify any high or low percentages of member disenrollments within a 90 day timeframe Network Development to include a review of FDR contracts and communication with FDRs to

ensure adherence to anti-kickback and other applicable statutes and regulations Clinical Services to include prior authorizations (PAs)., utilization management (UM), notices

of action (NOAs), and case management Pharmacy to include formulary development, rebates, other price concessions, and P&T

Committee activities. Marketing, Outreach and Sales Operations to include random review of marketing materials

as well as periodic, unannounced in-person monitoring of sales calls Finance to include encounter data and pricing Information Systems to include validating system changes and encounter submissions Appeals and Grievances to include monitoring grievances files with UAHP CMS Program Operations and Bid Preparation Member medical records, as appropriate UAHP analyzes data to identify patterns of unusual and potentially abusive health care utilization and non-compliance. Analysis also extends to reviewing UAHP Department compliance with AHCCCS and CMS requirements. The auditor provides a summary report of audit results to UAHP Departments. The report will include any findings of non-compliance. If non-compliance is identified a corrective action is issued to the UAHP Department and the Department will be required to submit a Corrective Action Plan (CAP) that outlines how it will modify its operations in order to return to compliant performance. The Department’s CAP must identify the root cause, explain how correction will be implemented, how the solution will be verified as effective and how the Department will monitor its performance to ensure the deficiency is unlikely to recur. The Compliance Department also validates all completed CAPs to ensure the intended result was achieved. Overall reporting of audit activities and results are provided to the UAHP Compliance Committee, Corporate Compliance Committee and the Board of Directors. Department Self-Audits and Monitoring Departments are required to conduct self-audits to measure performance against CMS and AHCCCS requirements. Some self-audits are conducted monthly. Additionally, the Compliance Department may conduct focused monitoring of department performance. Non-compliance is to be self-reported to the Compliance Officer and the Department’s management and a Corrective Action Plan as described above will be developed by the Department to correct any identified deficiencies. The results of self-audits and monitoring are reported along with other compliance metrics to the Compliance Officer and Compliance Committee. External Auditors UAHP also contracts with external auditors to audit UAHP processes and operations. This includes the required annual audit of UAHP’s Compliance Program. The results of these external

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audits are reported to senior management, the Compliance Officer, the Compliance Committee and the Board. Monitoring and Auditing of First Tier, Downstream and Related Entities (FDR) UAHP contracts with vendors to administer and/or deliver benefits on UAHP’s behalf. These vendors are referred to as delegated FDRs and they must abide by UAHP contractual and regulatory requirements. UAHP is responsible for the lawful and compliant administration of Medicare and Medicaid benefits under our contracts with AHCCCS and CMS, regardless of delegation. UAHP has clearly defined processes and criteria to evaluate and categorize all vendors with which UAHP contracts and utilizes multiple methods to monitor and audit First Tier Entities to ensure that they are compliant with all applicable laws and regulations, and to ensure that the First Tier Entities are monitoring the compliance of the entities with which they contract. Methods include on-site audits, desk reviews and monitoring of self-audit reports. UAHP’s audit work plan of First Tier Entity oversight includes multiple components as follows: Regular reporting of FDR activities Auditing FDR operations at least annually Requiring contractual terms for all FDRs that: Mandate compliance with applicable federal and state laws Outline UAHP accountability and FDR delegation responsibilities Allow for inspections, provide beneficiary protection and require record retention Allow for cost-containment recovery for infractions or errors made by FDRs Provide for revocation of the delegation activities or other remedies when CMS, AHCCCS

or UAHP determine that the delegated FDR has not performed satisfactorily. Report the FDR to appropriate government agencies and/or law enforcement for any

applicable civil and criminal laws for fraud perpetrated in the delivery of the Part C and D benefits.

Stipulating that all FDRs certify the accuracy, completeness and truthfulness of any claims data submitted on behalf of UAHP and acknowledging that claims submitted on behalf of UAHP will be used for the purpose of obtaining federal reimbursement

Maintaining cost-containment recovery provisions for infractions UAHP’s Subcontractor’s Oversight (SO) Committee ensures regular and ongoing oversight of UAHP’s relationships with delegated FDRs. The Committee monitors delegated FDR activities and performance to ensure they fulfill contractual requirements and meet established standards. SO Committee members are from appropriate departments and department units throughout UAHP. Specific Departments are assigned as owners to oversee specific delegated FDRs, including, but not limited to: Credentialing Provider Relations/Network Development Pharmacy Benefit Manager Call Center Prior Authorization Claims Processing Compliance For delegated FDRs with responsibility in multiple functional areas, the owners are responsible for arranging recurring Joint Operations Committees (JOC). JOCs are composed of a cross-functional group of individuals from both UAHP and the delegated FDR. The JOCs work collaboratively to enhance operational efficiencies and address any areas of risk. The SO Committee ensures that the audit tools are up-to-date. The SO Committee’s work plan includes the number of First Tier Entities that will be audited each year and how the entities will be identified for auditing. UAHP ensures that First Tier Entities fulfill the Compliance Program

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requirements, including the First Tier Entity’s application of Compliance Program requirements to its downstream entities. In addition, the SO Committee ensures that the Compliance Department conducts routine audits to validate delegated FDR compliance. If UAHP identifies FDR non-compliance, corrective action plans are required to respond to detected offenses. UAHP ensures that corrective actions are taken. Reports on overall oversight activities are given to the SO Committee, to the Quality Management/Performance Improvement Committee and to the Compliance Committee. Fraud, Waste and Abuse Investigations The Compliance Department is responsible for coordinating investigations of potential fraud, waste and/or abuse. In addition, training and awareness programs are developed and implemented to promote UAHP’s commitment to ethical conduct for all Staff and Business Partners. The FWA Analyst works with the Medicare Drug Integrity Contractor (MEDIC) and law enforcement or other agencies, as required. Analytics employed include data mining to identify referral patterns, possible payment errors, utilization trends and other indicators of potential fraud, waste and abuse. Furthermore, data analysis of medical and prescription drug claims is conducted to detect outliers that may indicate potential member or provider fraud, waste and abuse. Results of FWA investigations may result in the FWA Analyst or Compliance Officer conducting provider education, making referrals to the Arizona Inspector General or MEDIC, or taking other actions. For AHCCCS members this may include limiting choice. For both AHCCCS and Medicare members this will result in case management referrals. For FDRs, this may result in formal contract actions, up to and including FDR termination. Results of FWA investigations are reported to the Compliance Officer and Compliance Committee. Auditing of UAHP by State or Federal Agencies or External Parties UAHP considers regulatory audits and reviews as an opportunity to confirm effectiveness of UAHP compliance efforts. Should the outcome of an audit indicate that UAHP has not met a regulatory requirement, UAHP will use the audit findings to perform root cause analyses and develop corrective action plans to address identified areas of non-compliance. UAHP may also contract with external vendors to perform audits and assist with operational/program changes to enhance UAHP compliance. UAHP cooperates with state and federal agencies or external vendors when audits are conducted and provides auditors access to information and records related to UAHP and delegated FDR operations. Tracking and Documenting Compliance and Compliance Program Effectiveness UAHP tracks and documents compliance efforts, including tracking through formal audits and monitoring, as well as through dashboards, scorecards, self-assessment tools and other mechanisms that show the extent to which operations areas and FDRs are meeting compliance goals. Issues of noncompliance identified in dashboards, scorecards, self-assessments, etc. are shared with UAHP senior management. Component 7: Procedures and System for Prompt Response to Compliance Issues UAHP has established and implemented procedures and a system for promptly responding to compliance issues as they are raised, investigating potential compliance problems as identified in the course of self-evaluations and audits, correcting such problems promptly and thoroughly to reduce the potential for recurrence and ensuring ongoing compliance with CMS and AHCCCS regulations. UAHP conducts appropriate corrective actions (e.g., repayment of overpayments and disciplinary actions against responsible individuals) in response to any potential violation. UAHP may detect the non-compliance through multiple avenues including self-reporting, AHCCCS or

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Medicare audits, internal audits, the Compliance Hotline calls, external audits or member complaints. When UAHP identifies an incident, it takes prompt action to investigate the matter, determine the root cause and implement an effective corrective action. UAHP maintains policies & procedures to outline how to promptly respond to any detected offenses and develop CAPs related to UAHP contracts. See UAHP policy CP108 and CP108 SNP Corrective Action. UAHP has procedures to voluntarily self-report potential fraud or misconduct related to the Medicare or Medicaid program to CMS, AHCCCS or its designee. Timely and Reasonable Inquiry UAHP will make a timely, well documented and reasonable inquiry into any situation where evidence suggests there has been Misconduct related to UAHP’s contractual requirements, including but not limited to payment, delivery of services, and/or prescription drug items. This includes any Misconduct by UAHP Staff or Business Partners. Regardless of where the Misconduct is identified, UAHP will initiate a timely and reasonable inquiry. Potential instances of fraud, waste and abuse may come to the attention of the Compliance Officer or members of senior management through Staff, Business Partner or beneficiary/member reports, audits or other sources. UAHP will conduct a reasonable inquiry as soon as possible, but no later than two weeks from the date the potential Misconduct was identified or reported. UAHP’s inquiry includes a preliminary investigation of the matter by the Compliance Officer. Because of the complex nature of some of Medicare cases, particularly fraud investigations, the Compliance Officer may also refer the matter to the Medicare Drug Integrity Contractor (MEDIC) within two weeks of the date the potential Misconduct is identified or reported so that investigations into suspected or observed fraudulent or abusive activity may be expedited. Corrective Action Any time an incident of non-compliance is discovered or a UAHP Department’s processes or systems results in non-compliance with AHCCCS or CMS requirements, the department is required to submit a corrective action plan (CAP) to the Compliance Department. The Department’s CAP must: 1) identify the root cause; 2) explain how correction will be implemented; 3) discuss how the solution will be verified as effective; and, 4) advise how the Department will monitor its performance to ensure the deficiency is unlikely to recur. CAPs represent a commitment from the department to correct the underlying problem of an identified issue in a timely manner and to prevent future noncompliance. CAPs may include revising processes, updating policies & procedures, retraining staff, reviewing systems edits and addressing other identified root causes. The CAP must achieve sustained compliance with the overall AHCCC or CMS requirements The status of open CAPs is reported to the Compliance Officer and the Compliance Committee. The Compliance Department monitors CAP implementation and requires that the department regularly report the completion of all action steps. Once the CAP is complete, the Compliance Department validates the CAP by monitoring individual action items over a period of time to demonstrate sustained compliance was achieved and the CAP was effective. The Compliance Committee is responsible for overseeing ongoing activity to ensure the CAPs are being implemented in a timely and effective manner and to report ongoing non-compliance risks to senior management. UAHP’s oversight of delegated FDRs includes a requirement that FDRs submit CAPs to address FDR non-compliance. Non-compliance may be identified through UAHP oversight, compliance audits, ongoing monitoring or self-reporting. UAHP takes appropriate action against any delegated

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vendor that does not comply with a CAP or does not meet its regulatory obligations. UAHP’s relationship with delegated FDRs includes a written agreement that includes penalties up to and including termination of the delegated FDR’s contract. UAHP’s Compliance Department is responsible for reviewing all sales allegations or complaints of marketing misrepresentation against a sales agent. Each allegation is investigated. Complaints may be received through multiple avenues including member/beneficiary complaints filed with CMS, the CMS regional office, Customer Care, the Compliance Department, the Compliance Hotline or the Grievance & Appeals Department. Should the investigation substantiate the sales allegation, UAHP will implement prompt disciplinary action to include additional training, ride-alongs, verbal or written warnings, suspension of sales production or termination of employment or termination of the external agent’s agreement. UAHP Self-Reporting Should UAHP discover an incident of significant Medicare or Medicaid program noncompliance, potential fraud or misconduct, UAHP will report the incident to CMS, AHCCCS, or government agency designees (e.g., MEDIC)_ as soon as possible after its discovery. Component 8: Fraud, Waste and Abuse Plan Health care fraud is a crime that has a significant effect on the private and public health care payment system. Program abuse results in unnecessary costs to AHCCCS and CMS. Taxpayers pay higher taxes because of FWA in public programs such as Medicare and AHCCCS. Employers and individuals pay higher private health insurance premiums because of FWA in the private sector health care system. Because of the profound impact FWA has on health care financing, CMS and AHCCCS require UAHP and other Medicare and AHCCCS plans to actively pursue the prevention, detection, investigation, reporting and correction of FWA. Examples of fraud include, but are not limited to: Billing for services that were not rendered; Misrepresenting as medically necessary non-covered or screening services by reporting them

as covered procedure or revenue codes; Signing blank records or certification forms, or falsifying information on records or certification

forms for the sole purpose of obtaining payment; Up-coding or consistently using procedure/revenue codes that describe more extensive

services than those actually performed; Using an incorrect or invalid provider number in order to be paid or to be paid at a higher rate

of reimbursement; Selling or sharing Medicare health insurance identification numbers so that false claims can be

filed; Falsifying information on applications, medical records, billing statements, cost reports or on

any documents filed with the government. Examples of waste and abuse include, but are not limited to: Billing for services or items in excess of those needed by the patient; Unbundling services the are to be bundled or double billing in order to receive increased

payment Adding inappropriate or incorrect information to cost reports; Collecting in excess of the deductible or co-insurance amounts; Requiring a deposit or other payment from patients as a condition for admission, continued

care or other provision of service; Examples of member fraud include, but are not limited to: Misrepresenting or concealing facts that would cause UAHP to provide coverage to persons

who are otherwise not eligible

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The three types of conduct that are generally prohibited by health care fraud laws are false claims, kickbacks and self-referrals. The consequences for violating these laws can include, in addition to imprisonment and fines, civil monetary penalties, loss of licensure, loss of staff privileges and exclusion from participation in federal health care programs. UAHP does not tolerate FWA of AHCCCS or Medicare Program resources and has implemented this FWA Plan to help prevent, detect, investigate, report and correct areas where FWA activity may occur. All Staff and Business Partners are prohibited from committing or participating in fraudulent, wasteful or abusive activity. UAHP’s FWA Plan is a component of the Compliance Program and the focus on reducing FWA is woven throughout this document. UAHP is taking a layered approach which includes considering multiple aspects of FWA: prevention, detection, investigation, reporting and correction. FWA Prevention FWA prevention is an important first step in the FWA plan and occurs via multiple avenues including policies & procedures, awareness/training, screening and risk assessment. Policies & Procedures UAHP’s Compliance Officer and Compliance Department reference state and federal policy and have developed FWA policies & procedures that are clear, concise, well defined and updated regularly. Further, UAHP references corporate policies & procedures that reinforce UAHP activities. Staff and Business Partners may reference these policies & procedures to better understand the overall fraud, waste and abuse process. These policies & procedures include: Corporate Policy: CC003 The Federal False Claims Act AHCCCS Policy: CP 100 Fraud, Waste and Abuse AHCCCS Policy: CP 102 Disclosure of Information on Persons Convicted of Crimes AHCCCS Policy: CP 228 FWA Provider Awareness AHCCCS Policy: CP 229 FWA Employee Awareness Medicare Policy: CP 100 SNP Fraud, Waste and Abuse Medicare Policy: CP 102 Disclosure of Information on Persons Convicted of Crimes Medicare Policy: CP 228 SNP FWA Provider Awareness Medicare Policy: CP 229 SNP FWA Employee Awareness Awareness UAHP ensures all Staff and Business Partners are made aware of the importance of preventing, detecting, investigating, reporting and correcting FWA. Staff and FDRs receive FWA training, including training provided as a new UAHP Staff member within 90 days or initial hiring (or contracting of Business Partners) as well as annually thereafter. All contracted providers are supplied with FWA materials in the provider manual and from their Provider Relations Representatives. Members receive FWA materials in the Member Handbook. FWA materials are available on the UAHP intranet and the UAHP websites. Completion of FWA training is documented for all Staff and Business Partners. UAHP managers are responsible for ensuring Staff training has been completed during a Staff member’s annual review. UAHP’s annual FWA work plan includes a minimum of four fraud, waste and abuse education activities per year for Staff, Business Partners and members. Screening A key element of he FWA Plan is ensuring Staff and Business Partners are fit for employment/contracting in the health care industry. For Staff, this includes conducting pre-employment background checks to review for felony convictions. For Staff and Business Partners this also includes reviewing the OIG or GSA sanctions or exclusions list. UAHP’s organizational

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policies prohibit hiring or entering into contracts with individuals or entities who have been recently convicted of a criminal offense related to health care, including those related to FWA, or who are listed as debarred, suspended, excluded, otherwise ineligible for participation in federal health care programs, or lawfully prohibited from participating in any public procurement activity or from participating in non-procurement activities. UAHP screens all Staff and Business Partners monthly to verify that they do not appear in the following lists or databases: The Social Security Administration Death Master File; The National Plan and Provider Enumeration System (NPPES); the Department of Health and Human Services Office or Inspector General List of Excluded Individuals / Entities (http://oig.hhs.gov/fraud/ exclusions.htmlin the Department of Health and Human Services Office or Inspector General List of Excluded Individuals / Entities (http://oig.hhs.gov/fraud/ exclusions.html) ); The Excluded Parties List (EPLS); and any other databases directed by AHCCCS or CMS. UAHP requires that any FDR who is delegated to perform administrative functions on behalf of UAHP also conduct the sanction screening and prohibit hiring or entering into contracts as outlined above. Risk Assessment To effectively deploy resources, risk must be assessed. UAHP’s Compliance Department conducts an annual risk assessment of UAHP operations for all programs. This integrated approach identifies risk across UAHP. The assessment identifies, measures and prioritizes risks that may materially impact UAHP, including fraud and abuse risk. The risk assessment is used to build the annual audit and monitoring program. The risk assessment is used to determine areas within the organization at greatest risk for fraud, waste and abuse. FWA elements considered may include: 1) Any internally reported findings on payment aberrancies; 2) Any self-identified payment system limitations; 3) Results from FWA Committee implemented interventions; 4) Outcomes of data analytic studies conducted by UAHP staff as well as UAHP FWA vendors; and 5) Comparing UAHP’s annual FWA savings to national FWA benchmarks to ensure UAHP savings are in alignment. FWA Committee UAHP has created a FWA Committee which is composed of UAHP management and other Staff from cross-functional areas throughout UAHP who are involved with detecting and correcting FWA. The FWA Committee is responsible for overseeing the coordination of UAHP’s FWA activities; developing FWA interventions; monitoring FWA activities including tracking & trending reports; and reporting results to the Compliance Department and Compliance Committee. FWA Detection UAHP has developed a multiple and layered operational process in an effort to detect potential fraud, waste and abuse. UAHP’s detection methods include the following elements: monitoring and auditing, publicizing communication channels; and regularly communicating to Staff and Business Partners. Monitoring and Auditing UAHP is required to perform effective monitoring in order to prevent and detect FWA. UAHP Staff and Business Partners are encouraged to monitor their work and interactions for any suspected FWA. UAHP’s Compliance Department receives FWA referrals from sources such as: Claims Department Referrals Customer Care Center calls Medical Management Department Referrals Case Manager Referrals Quality Department Referrals Finance Department Referrals Network Development Department Referrals

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Claims Educator Referrals Grievance and Appeal Trending Auditor Findings Contracted Providers Third-Party Referrals including former employees of UAHP or UAHP Business Partners Literature, such as news reports or industry newsletters like the Health Care Compliance

Association’s weekly report CMS Fraud Alerts. When received UAHP reviews past paid claims to identify whether

payments have been made to any entities identified in a fraud alert and remove them from their sets of prescription drug event data submissions.

Notices from the OIG In addition, specific system applications and departments conduct routine monitoring on an ongoing basis to proactively identify potential FWA. UAHP also conducts data analysis, which compares claim information against other data to identify unusual patterns, suggesting potential errors and/or potential fraud and abuse. Data analysis is factored into prescribing and dispensing practices of providers who serve a particular population. Use of data analysis includes monitoring pharmacy and medical billing to detect unusual patterns. Information Technology: UAHP employs multiple software solutions that allow it to efficiently prevent fraud and abuse. To support correct payment activities, UAHP’s core claims processing system, GE Centricity Business MCA (GE MCA) contains very flexible rule banks for identifying claims that should be pended for process or manager review. UAHP uses TriZzetto Medical Data Express software for outpatient hospital claims pricing, which was customized to eliminate potential overpayment due to manual processing. UAHP has also implemented OptumInsight’s claims editing application, iCES. iCES supplies all required claims editing and UAHP has added functionality for fraud and abuse prevention. UAHP has also implemented the Oracle Siebel Customer Relationship Management (Siebel) application, a state-of-the-art customer relationship management solution. Siebel employs a workflow engine that allows technology-based cross-departmental communication and task/activity assignment. When members and providers contact UAHP, their calls are uniformly logged. Employees operate within a workflow queue, completing their tasks in the appropriate sequence. Siebel then routes the tasks to the next accountable employee. Activities, timing and results are stored and tracked for review and analysis of trends. The FWA Analyst receives referrals from UAHP’s call center through Siebel. The Medical Management Department also uses Siebel for retrospective claims review. This process identifies claims that result in outliers, which are routed for review by certified coders for errors, fraud or abuse. The task is initiative from the Claims Department and routed to Medical Management. Upon completely, the results are routed back to Claims. Another technology solution is Cerecons, a prior authorization (PA) management system. This web-based system enables providers to send and receive PA requests and responses as well as communicate with UAHP. These communications are stored within Cerecons. A member’s medical and pharmacy claims, lab results and other statistics can be viewed on a single screen (face sheet). The provider can access this feature for a complete view of UAHP’s record of their patient, services provided and potentially identify unusual requests or patterns. UAHP also has a custom-developed provider portal, eServices. It supports the prevention of fraud and abuse activities. eServices supplies providers with online eligibility verifications, claims status inquiry and the ability to submit and electronic PA form. Providers who use eServices can easily validate their member in real-time and avoid identify theft. Claims Department: To ensure provider payments are appropriate, the Claims Department monitors for FWA via iCES, which applies pre-payment system edits, live payment edits and coordination of benefits. UAHP’s Pharmacy Benefit Manager (PBM) employs point-of-sale edit software and coordination of benefits. The edits ensure that governmental funds are not being

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improperly distributed and that payments are being prepared correctly for claims submitted from authorized providers for eligible members. The Claims Department also monitors for trends and provider patterns and reports any suspicious activities to the Compliance Department. The Claims Department also conducts quality audits of its individual Claims Processors; should the audit identify consistent or recurring errors, the Claims Department will provide additional training and/or discipline the processor, as appropriate. When suspicious billing is identified, Claims can place a provider on manual review status and require review of all claims prior to payment. Compliance Department: The Compliance Department employs a full-time FWA Analyst to conduct special investigations. The FWA Analyst along with the Compliance Officer conducts surveillance, interviews and other methods of investigation relating to potential FWA. The FWA Analyst coordinates all FWA monitoring and facilitates additional FWA steps including: reducing or eliminating Medicare and Medicaid benefit costs due to FWA; reducing or eliminating fraudulent or abusive claims paid for with federal or state dollars; preventing illegal activities; identifying members with overutilization issues; identifying and recommending providers for exclusion, including those who have defrauded or abused the system to the MEDIC and/or law enforcement; referring suspected, detected or reported cases of illegal drug activity, including drug diversion, to MEDIC and/or law enforcement and conducting case development and support activities for MEDIC and law enforcement investigations; and assisting law enforcement by providing information needed to develop successful prosecutions. The Compliance Department also deploys eight auditors, including a licensed R.N. and two Certified Professional Coders (CPCs), and a Medicare Advisor. All focus on areas of risk—including fraud and abuse identification and annual audits of UAHP subcontractors to ensure that fraud and abuse prevention programs are in place. Claims Auditors conduct monthly quality audits to review processed claims for financial and processing accuracy. They look for unusual claims payment patterns. Compliance also monitors sanction screening and exclusion databases to ensure employees and vendors are eligible to participate in federal and state programs. Customer Care Center / Call Center: The Customer Care Center monitors incoming member calls for any FWA activities. This includes identifying members who may have moved out of the area and no longer qualify for benefits, members who may be “doctor or prescription shopping” in an effort to obtain large quantities of pain/other illegal drugs or members and providers who are making Customer Care Representatives aware of other suspected FWA activity. Customer Care Center Representatives report suspected FWA activity voluntarily disclosed by members, providers or other callers to the Compliance Department. All Customer Care Center Representatives are encouraged to report suspicious activity to the Compliance Department. Furthermore, The Customer Care Center conducts outbound service verification calls on an ongoing basis. Based on paid claims, Customer Care calls members to verify the receipt of a paid service. The outcome of the call is documented and regularly reported to AHCCCS. Should a member indicate that the service was not provided; a referral is made to the FWA Analyst. Finance Department: The Finance Department contracts with Health Management Systems (HMS), which conducts retrospective third-party liability monitoring. On a monthly basis, UAHP reports claims to HMS that contain the “trigger” diagnostic codes that identify injuries that may have been prompted by a third party. This includes identifying other payers, such as private insurers, which have primary payment responsibility for the health care services rendered. This monitoring occurs after a medical claim has been processed and is often referred to as “pay and chase”. Should another payer be identified, monies already paid out are recovered. The savings is reported to AHCCCS and to the FWA Committee. UAHP’s Finance Department performs quarterly oversight audits to ensure HMS remains compliant in all areas required by AHCCCS and CMS.

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Network Development: In the course of servicing providers, UAHP Provider Relations Representatives (PRRs) make unannounced provider office visits. Sometimes the PRR is joined by other UAHP representatives, including the CMO, Medical Director, Quality Management Director or Director of Medical Management. If a provider is confirmed by the OIG, the Attorney General’s Office or MEDIC to be engaged in fraudulent activity, immediate action is taken to terminate the provider. Network Development also monitors the sanction screening and exclusion databases to ensure providers and subcontractors are eligible to participate in federal and state programs. Medical Management: The Medical Management Department includes a Medical Management Systems Unit which is staffed in part to retrospectively review specific claims including durable medical equipment, professional fees and facility claims. For retrospective review, medical records are examined to determine medical necessity and appropriate medical care. This type of review covers any services or treatment including medications that have already been administered or provided. The reviews conducted are based on AHCCCS criteria, CMS guidelines and business decisions that pertain to correct coding and associated reimbursements. Should fraud or abuse be suspected, a referral is made to the FWA Analyst. Pharmacy Department: The Pharmacy Department works to provide safe and appropriate medications, but it sometimes identifies members who misuse medications, the most common of which are prescribed opioids. UAHP’s Pharmacy team developed processes to address the misuse of opioids. These include: 1) Pharmacy and Therapeutics Committee oversight, including PA edits for most long-acting opioids and carisoprodol, a medication commonly associated with inappropriate opioid use, was removed from the formulary because there are safer alternatives to replace it; 2) Conducting a complete medication history review as part of the PA process for long-acting opioid prescription requests and any “refills too soon” or lost prescriptions are thoroughly researched; 3) Reviewing retrospective drug utilization reports from the PBM to identify members exhibiting drug-seeking behaviors, including multiple prescribers, multiple pharmacies and frequent prescriptions for small quantities of controlled substances; 4) Encouraging communication between PCPs, pain specialists and UAHP to better manage member care; 5) Researching and responding to drug-seeking member referrals from the FWA Analyst, Case Managers, pharmacy providers and medical providers. When substantiated, the FWA Analyst reports the member to AHCCCS OIG and/or MEDIC, and AHCCCS members can be locked to a specific pharmacy and/or prescriber to better monitor care Quality Management: The Quality Management Department (Quality) includes added steps to identify fraud and abuse. The Quality Manager supplies abuse of member reports to the FWA Committee and investigates member abuse allegations. When cases of suspected child or elder abuse are encountered by UAHP staff, these are referred to Quality to ensure appropriate reporting occurs. Subcontractors: UAHP collaborates with providers and subcontractors to identify fraud and abuse. UAHP’s PBM, MedImpact, provides fraud and abuse data-mining decision-support tools and services. The PBM evaluates claims data utilizing a prospective and retrospective process to detect patterns of deviant or abnormal dispensing behavior, MEDIC reported targets, areas of high incidence of fraud and other potential areas of abuse. The PBM reports suspicious activities to UAHP’s FWA Analyst and uses the analysis to increase proactive interventions such as pharmacist education. The PBM supplies UAHP with quarterly and annual reports that identify any prevented overpayments. PBM representatives are required to make unannounced pharmacy visits to confirm the location is a legitimate business. UAHP’s dental network subcontractor, DentaQuest (DQ), monitors its contracted providers via qualitative and quantitative utilization data management that compares dentists to identify aberrant practice or billing patterns. They analyze 100% of paid claim history and conduct medical record reviews on an average of 5%-10% of the

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network. Should aberrant patterns be identified, DQ may implement a provider education program to modify provider behavior and may report the provider to UAHP’s FWA Analyst or directly to AHCCCS OIG. DQ representatives are required to make unannounced dental office visits to confirm the location is a legitimate business. FWA Investigation UAHP will investigate in a timely and reasonable manner any potential Misconduct including but not limited to activities associated with payment, delivery of services, or prescription drug items. This includes any Misconduct by Staff or Business Partners. Should FWA be suspected, UAHP’s Compliance Department is responsible for coordinating investigations. The dedicated FWA Analyst will lead an internal investigation; utilize a contracted vendor; or collaborate with the Medicare Drug Integrity Contractor (MEDIC), law enforcement or other agencies, as required. UAHP has contracted with a vendor to analyze UAHP claims data and report any potential FWA to the FWA Analyst. The vendor provides decision-support tools and services to identify and prevent fraud and abuse. Searches are conducted by analyzing UAHP referrals and data mining of UAHP’s claims data. Data mining establishes baseline data to enable UAHP to recognize unusual trends, changes in utilization over time, potential overpayments, fraud or abuse by identifying patterns that are aberrant when compared to other like claims. These patterns are identified through techniques including visualization designed to reveal hidden relationships such as unbundling, upcoding, duplicate billing, services not rendered, and misrepresentation of services. The FWA Analyst then validates the vendor’s findings. UAHP’s PBM also analyzes UAHP pharmacy claims data and reports any potential FWA to the FWA Analyst. The FWA vendor and PBM employ investigation analytics including data mining to identify referral patterns, possible payment errors, utilization trends and other indicators of potential FWA. Data analysis of medical and prescription drug claims is conducted to detect any outliers. For providers, investigation methods include looking for patterns of fraud, waste and abuse such as billing patterns, medical documentation, prescribing or dispensing patterns, or past medical care. For members, this includes duplicative services and/or prescriptions from multiple providers or pharmacies. Generally there are three types of resolutions for these investigations; the first is a request for reimbursement, the second is recoupment from future payments, and the third is to educate providers on how they can improve billing practices. If it is determined a provider or group has suspicious claims activity, UAHP has directed the contracted vendor to also perform focused investigations. The comprehensive referral and investigation process includes conducting trend analysis, medical record audits, Department of Insurance (DOI) reporting, and/or other regulatory reporting, if appropriate. Because of the complex nature of some of Medicare cases that may be involved, particularly fraud investigations, the Compliance Officer may also refer the matter to the Medicare Drug Integrity Contractor (MEDIC) within two weeks of the date the potential Misconduct is identified or reported so that investigations into suspected or observed fraudulent or abusive activity may be expedited. FWA Correction Upon completing an investigation, UAHP will seek to correct the identified FWA, including, but not limited to the following actions for FDRs:

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Provider Education: If it is determined the claims contained unintentional billing errors and FWA is not suspected; the FWA Analyst collaborates with the Network Development Department to educate the provider regarding errors and appropriate billing techniques.

Prospective Review: When directed, the Claims Department may place a provider on a prospective flag status that requires investigation of all claims prior to payment.

Recovery: When UAHP determines there have been overpayments, either recoups or reimbursement requests will be made.

Administrative Remedy: If consistently inappropriate billing trends are noted, UAHP’s Compliance Department will collaborate with the Network Development Department to educate the provider. If provider education does not produce a positive result, a provider may be disciplined up to and including removal from the network and subjected to any applicable civil and criminal laws for fraud. This extends to FDRs.

Government Agency Referral: Certain circumstances may require UAHP to report findings to the appropriate government agencies, including the OIG, MEDICS or the Department of Justice. Depending on the nature of the issue, a referral can be made to local law enforcement agencies.

Change in Policy: UAHP may determine the need to modify a policy to ensure compliance with government regulation.

Close Case: When the evidence does not support findings of inappropriate benefits, payments, or the legal/medical merits of the cases do not indicate need for further pursuit.

For members, investigations may results in Member Education: Members may receive a call from the Customer Care Center or their

assigned Case Manager to educate the member regarding FWA. Case Management Referrals: Members may be assigned to a Case Manager to ensure the

member is receiving appropriate care. Increased Monitoring: The Customer Care Center can place a flag in its Customer Resource

Module (CRM) system of suspected FWA behavior. Should the member call in, the Customer Care Center will note the flag and route the call appropriately. The call can be routed to case management, compliance or law enforcement.

Network Restriction: AHCCCS members may be subject to limited provider or pharmacy choice.

Government Agency Referral: Certain circumstances may require UAHP to report findings to the appropriate government agencies including the OIG, MEDICS or the Department of Justice. Depending on the nature of the issue, a referral can be made to local law enforcement agencies, as deemed appropriate.

Close Case: Closing the case may be the best option when the evidence does not support the findings.

FWA Reporting and Tracking UAHP requires any Staff or Business Partner who suspects inappropriate FWA behavior to report the suspicion to the Compliance Department or the FWA Analyst. FWA reporting can be done by telephone, email, internet message submission and mail. UAHP Staff and Business Partners may also use the Compliance Hotline at 1-800-726-0713 for anonymous reporting of any suspected FWA. The Compliance Department also formally reports any suspected FWA to the designated state and federal agencies, the Medicare Drug Integrity Contractor (MEDIC) and law enforcement. Any reports received--through any channel of communication--of a potential or observed violation of compliance policies, federal and state requirements, regulations or statues will be documented. A log will be maintained to record all such reports, including the nature of any investigation and its results and to identify patterns and opportunities for additional training or corrective action. This information will be included in reports to the Compliance Committee.

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UAHP has written policies of non-retaliation toward any person who reports a potential or observed violation. Staff and Business Partners will be made aware of these policies and encouraged to report incidents of potential or observed fraud, waste or abuse or other compliance concerns. All involved will be made aware of the fact that the identity of any anonymous reporter may have to be revealed. Reporting FWA to AHCCCS If UAHP determines that potential fraud or Misconduct related to the AHCCCS program has occurred, UAHP’s Compliance Department will make a report to The Office of Program Integrity (OPI), in accordance with policy & procedure CP 100 Fraud, Waste and Abuse. Reporting FWA to Medicare If UAHP determines that potential fraud or Misconduct related to the Medicare Advantage Prescription Drug Plan Part D program has occurred, UAHP’s Compliance Department will report the potential fraud or misconduct to the MEDIC as soon as possible after its discovery, in accordance with policy & procedure CP 100 SNP Fraud, Waste and Abuse. UAHP may also consider reporting potentially fraudulent conduct to government authorities such as the Office of the Inspector General or the Department of Justice. FWA Tracking UAHP will maintain files for a period of 10 years on both in-network and out-of-network providers who have been the subject of complaints, investigations, violations and prosecutions. This includes enrollee/member complaints, MEDIC investigations, OIG and/or DOJ investigation, US Attorney prosecution, and any other civil, criminal or administrative action for violations of Federal health care program requirements. UAHP also maintains files that contain documented warnings (e.g., fraud alerts) and educational contacts, the results of previous investigations, and copies of complaints resulting in investigations. UAHP will comply with requests by law enforcement, CMS, AHCCCS or CMS designee regarding monitoring of providers within UAHP’s network that CMS or AHCCCS has identified as potentially abusive or fraudulent.

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Maricopa County



March 26, 2014

Item 10.a. Report to the Board

Project Description Amount ApprovedDate of Board

Approval

Date of Project

CompletionFirst Review 2nd Review 3rd Review Final Review

Adult Emergency Department 1,200,000 June, 2008 April, 2009 January, 2014

Campus Refresh Projects 5,500,000 June, 2010 2010 - 2011 January, 2014

Labor & Delivery Room Renovations Included in Campus

Refresh June, 2010 2010 - 2011 January, 2014

Pediatric Emergency Department 4,890,000 August, 2010 March, 2012 January, 2014

Electronic Medical Record 66,800,000 August, 2008 multi year March, 2014 March, 2015 March, 2016

McDowell Clinic Relocation 900,000 August, 2012 September, 2013 January, 2014 October, 2014 October, 2015

MRI Imaging Facility 5,162,000 January, 2013 March, 2014 July, 2014 July, 2015 July, 2016

Nursing 4 East and 5 West Remodel 2,050,000 January, 2013 2014 July, 2014 July, 2015 July, 2016

Wound Clinic 2,111,000 January, 2013 2014

Enterprise Application Suite EAS) 12,870,000 June, 2013 2014

ICD - 10 Implementation 5,081,687 June, 2013 October, 2014 January, 2015 November, 2015 November, 2016

Key Dates


dba Maricopa Integrated Health System

Project - Post Implementation Review and Update Schedule

March, 2014

Electronic Health Record Post implementation Review

March 26, 2014

Page 1

Project Name Electronic Health Record (EHR)

Date of Board Approval August, 2008

Date of Project Completion Multi Year

EHR Project Expenditure Budget $66.8 million

EHR Actual amount expended $63.5 million

Meaningful Use Payments Received $13.1 million

Review Type Final

I. Description of the Project

The ARK (representing New Beginnings) project was initiated in 2006 with an objective to replace and enhance clinical and financial applications to support the transformation of the District’s health care delivery processes. The mission statement of the project was “To enable MIHS Clinical and Business Partners with the technology (systems, applications, processes) to provide the highest degree of clinical care in the most cost effective and efficient manner possible.” ARK consists of two distinct parts:

Clinical Applications – Electronic Health Record (EHR) - Epic Financial Applications – Enterprise Application Suite (EAS)

This review document will focus on the clinical applications system - Epic. The EAS financial applications and budget (which include systems for finance, materials management, and human resources) are currently in process of implementation and will be addressed in a separate document at a future date as this project moves along in the implementation process.

II. Value to MIHS (Return on the Investment)

Improves Patient Safety Best Practice Alerts E-Prescribing, Medication Reconciliation, Closed Loop Medications, CPOM Health Maintenance Alerts

Improves Access to Health Information For the Patient, via the MyChart Patient Portal For the Care Giver, accessibility to patient documentation (consistent, legible,

searchable) For external providers, through automated faxing, Epic Link and Health Information

Exchange


March 26, 2014

Page 2

Positions MIHS for Future Healthcare Structures Improved Medical Education experience Medical Home Information Improved Referral Tracking and sharing information with strategic partners, such as

Magellan Preparing for Accountable Care Organizations Enables Research potential with discrete, searchable, reportable health information

III. Implementation and Timeline

The timeline to begin researching and evaluating MIHS system needs, products in the market, costs, etc., began in 2006. Board approval to proceed with the acquisition of Epic was received in August, 2008. The following summarizes the completion timeline and the key applications installed. Additionally, the last page of this document includes a listing of the specific Epic applications installed. Phase II included the Practice Management pilot in 2009 (Scheduling, OP EpicCare, and Hospital Billing) and the full deployment of Practice Management in the FHC and CHC clinics in 2010. The Phase II Project started in late 2010 with an implementation date of 2012.

MIHS Epic “ARK "Significant Milestones

6

2008 2009 2010-11

MIHS BOD Approves contract to initiate multi-year ARK Project (EMR)

ARK Phase I – Completed! Full ambulatory, Systems – Practice

Management and EpicCare

ARK Phase I - PILOTFor Core Systems

Ambulatory, OR, and ED

2013 2014…2012

MIHS ERP Project scheduled to complete Q3-Q4 ‘14

Significant ITInfrastructure Upgrades

ARK Phase II – Completed!

InPatient Doc and Registration, HIM, Professional Billing, Release of

Information, Patient Portal, Physician Portal, CPOE, Clinical Pathways, Lab, etc.

HIMSS Stage 6 Achieved

ARK Phase III

(MyChart)

ERP Project Initiated

ICD10 Project Initiated


March 26, 2014

Page 3

IV. Budget The EHR implementation costs have been included in the approved annual capital and operating expense budgets for fiscal years 2009 through 2013:

V. Examples of Value Received

Nursing: The EHR has allowed for improved communication, readily available information for timely patient care, and best practice alerts to assist in clinical decision making. Clinical leaders continue to make improvements to processes, identification of opportunities to reduce redundancy of documentation between the clinical teams, standardization across the organization on key elements related to patient care, and accessibility to reports to make real time changes to practice and or documentation within the EHR. Other opportunities to continue to standardize regulatory required reports for DNV and others continue to be identified and worked on. Ambulatory: The EHR application (EPIC CARE) has allowed for improved communication between staff and providers across the MIHS continuum of care. In addition to allowing real time information to be visible to the entire care team, it has streamlined work flows, improved documentation, increased patient engagement thru the rollout of My Chart, and has improved quality of care thru best practice alerts and reports. On the operational side, Cadence and Prelude (scheduling and registration) have provided the ability to track and trend appointment availability, no shows, provider productivity and promote standardization of appointment scheduling across the clinics. Operating Room: Positive impacts of the Epic application (OpTime) in the operating room include: the integration of the entire patient chart, streamlining workflow to align documentation to meet the needs of the perioperative teams, reporting dashboards for Perioperative Managers, better online display of scheduled cases, display of relevant patient medications, integration of devices for

Fiscal Year Budget Actual

FY09 10.6$ 7.6$

FY10 20.3 16.6

FY11 14.0 15.7

FY12 18.7 22.2

FY13 3.1 1.4

Total 66.8$ 63.5$

$ (in millions)


March 26, 2014

Page 4

anesthesia, pre-built surgeon order sets, improved documentation, system alerts and workflows related to many areas such as medication and blood administration, patient diabetes, antibiotic orders, specimen workflows, etc. Quality and Safety: The implementation of the EHR has allowed for real time access to patient health information across the system. This has increased quality staff efficiency related to chart reviews and evaluation of practices. Documentation related to patient safety concerns can be immediately investigated. As MIHS moves forward with the system and applications, we continue to identify and improve workflow design, specifically related to core measures and meaningful use point of care data capture.

Medical Education: The EHR has allowed for improved medical education by supplying best practice alerts to guide novice providers in clinical decision making. It has made sharing of clinical information from the hospital to the clinics seamless. It provides exposure for medical trainees to the growing world of medical informatics. The EHR has improved the organization and tracking of procedures, facilitated information exchange during resident change over, and improved the clarity of the patient’s health record. VI. Meaningful Use Financial Incentive Program

MIHS has made annual submissions to CMS for meaningful use revenues totaling $17.1 million and to date has received payments of $13.1 million. The Medicare and Medicaid EHR Incentive Programs provide a financial incentive for the "meaningful use" of certified EHR technology to achieve health and efficiency goals such as reduction in errors, availability of records and data, reminders and alerts, clinical decision support, and e-prescribing/refill automation. Meaningful Use means providers need to show they are using certified EHR technology in ways that can be measured significantly in quality and in quantity. The American Recovery and Reinvestment Act of 2009 specify three main components of Meaningful Use:

The use of a certified EHR in a meaningful manner, such as e-prescribing.

The use of certified EHR technology for electronic exchange of health information to improve quality of health care.

The use of certified EHR technology to submit clinical quality and other measures. VII. Summary In summary, MIHS has acquired the Epic applications as intended, implemented on time and below budget. The values anticipated as related to quality, patient safety, access to information, improved processes and positioning for the future for healthcare are being realized. As more experience is gained in using the new systems and applications, MIHS continues to identify new opportunities for reporting of information and ways to make process improvements.


March 26, 2014

Page 5

Applications Installed

ASAP Emergency Department Components

EpicCare Ambulatory EMR Components

OpTime Operating Room Management System Components: Core, Perioperative Charting

Anesthesia1 Components

Resolute Hospital Billing and Patient Accounting

Anesthesia Billing Components:

Cadence Enterprise Scheduling System Components: Includes Referral Tracking

Cadence – Advanced Rules-Based Scheduling Components

Clarity and Analyst Reporting Package Components

EpicCare Inpatient – Epicenter EDR

EpicCare Inpatient – EMR

EpicCare Inpatient – Order Entry / CPOE

EpicCare Inpatient – Core Clinical Documentation

EpicCare Inpatient – Extended Clinical Documentation

EpicCare Inpatient – Medication Administration Record

EpicCare Inpatient – Interdisciplinary Care Plan

EpicCare Inpatient – ICU / CCU

EpicRx Inpatient Pharmacy

Radiant Radiology Information System

Beacon Oncology

Stork OB / Labor and Delivery

EpicLab Clinical Laboratory System

Resolute Professional Billing System Components: Includes Prelude Ambulatory Registration System, Residency Documentation, Electronic Remittance and includes two electronic claims modules, the ANSI 837 v4010 Professional and ANSI 837 v4010 Institutional; extensions to the format are priced separately.

Admission/Discharge/Transfer System

Prelude Inpatient Registration System

Health Information Management – Chart Tracking

Health Information Management – Chart Deficiency Tracking

Health Information Management – Release of Information

EpicCare Link

Bridges EDI Developer’s License

Charge Router

Identity Embedded Master Person Index

Maricopa County



March 26, 2014

Item 11.

iProtean

Welcome to Making Difficult Decisions About Services And Programs: A Portfolio Approach. This is Part One of a two-part course. In this course, experts will cover: tackling the issues, programs that cover their own direct costs, the portfolio approach: four core questions, adding or subsidizing programs and services and an objective process for the board and management. Marian Jennings is a consultant specializing in strategic and financial planning, and system planning and development. Marian Jennings: As financial pressures increase, it's going to be important for boards and their management team to ensure the financial integrity of the organization. So the first step of course is just to look to make sure you're efficient. The second step is to say, well we need to redesign our care model to ensure that it's meeting the needs of the future. But often organizations find that doing those two things alone will not be enough to ensure financial success. And then they're faced with the really difficult decision of what scope of services, what programs should we be offering to our community. Finance: Making Difficult Decisions About Services And Programs: A Portfolio Approach, Part One Description (Goal/Purpose): This is a foundational course that that addresses the board’s responsibility for evaluating services and programs using an objective, portfolio approach. Upon completion of this course you will:

o Understand the issues involved in evaluating existing programs and services to determine whether they should be continued or discontinued

o Understand the core questions boards should ask when using a portfolio approach to

evaluate programs o Identify the issues surrounding adding or subsidizing programs and services

Maricopa County



March 26, 2014

Item 12. – No Handout Concluding Items

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