Explanation:
OLICY SUMMARY
CVS Health® (the “Company”) entered into a Corporate Integrity Agreement (“CIA”) with the
Office of Inspector General, Department of Health and Human Services (“OIG”) in October
2016 to resolve allegations concerning certain business practices of the Company’s Omnicare®
business unit. The CIA requires that CVS Health develop and implement a Policy regarding
certain federal healthcare program requirements and make this Policy available to “Covered
Persons”, which is a defined term under the CIA, and includes certain colleagues, vendors,
subcontractors, customers and other third parties.
This Policy outlines the requirements for Covered Persons as required by the CIA. Specifically,
this Policy is designed to ensure that Covered Persons understand the elements of the Anti-
Kickback Statute and Stark Law and the obligation to report violations and/or seek guidance
when necessary. The Company is committed to complying with all Federal health care program
It reinforces strong commitment to compliance with the law.
Corporate Integrity Agreements are those agreements that exists between the the department of health of the United States and the CVS which is a health provider.
These Corporate Integrity Agreements reinforces the willingness to comply with the law and to stay strongly committed to high ethical standards.
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