2024-001 Corrective Action Plan NADAP’s Vendor Screening Policy has been updated with additional information regarding screening procedure, assigning specific ownership and documentation practices to each step of the procedure to ensure compliance. The updated policy is included below and will be incorporated into the Corporate Compliance Manual. Gary Stankowski, Chief Operating Officer and Corporate Compliance Officer, is responsible for oversight of this corrective action. Vendor Screening Policy Purpose of Policy The purpose of this policy is to establish safeguards to prevent NADAP from contracting with individuals or entities that have been excluded from receiving Medicaid or federal funds. Definitions SAM Exclusion List means the Exclusions List available in the U.S. General Services Administration System for Award Management system. LEIE means the U.S. Department of Health and Human Services Office of Inspector General List of Excluded Individuals/Entities. OFAC SDN means the US Department of Treasury’s Office of Foreign Assets Control Specially Designated National & Blocked Persons List. OMIG Exclusion List means the List of Restricted, Terminated or Excluded Individuals or Entities maintained by the New York State Office of Medicaid Inspector General. Statement of Policy NADAP is prohibited from entering into a contract unless the contractor has been subject to screening in accordance with this policy. Exclusion Screening Prior to Contract Execution The employee responsible for negotiating the contract will forward the contractor’s name, address, social security or tax identification number and other appropriate information to the Corporate Compliance Officer (CCO), copying the Executive Assistant to Administration (EA). If the contractor is an entity rather than an individual, the employee will provide the same information for any individuals or entities that own an interest of 10% or more in the contractor. The CCO will promptly screen all potential contractors (and any individuals who own 10% or more of a corporate contractor) against the SAM Exclusion List, LEIE, OFAC SDN, and the OMIG Exclusion List. The exclusions databases are available to search online at the following addresses: SAM Exclusion List - https://sam.gov/EIE - https://exclusions.oig.hhs.gov/OFAC SDN - https://sanctionssearch.ofac.treas.gov/OMIG Exclusion List - https://apps.omig.ny.gov/exclusions/ex_search.aspx The EA will complete the screening and notify the employee responsible for negotiating the contract and the CCO in writing that the screenings were completed. NADAP may choose to retain a vendor to perform this screening on behalf of the Compliance Officer. New vendor screenings will be reported in the appropriate Corporate Compliance Monthly Activity Report. NADAP is prohibited from contracting with any individual or entity that is included on the SAM Exclusions List, LEIE, OFAC SDN, or OMIG Exclusion List at the time the contract is being executed. Ongoing Screening The CCO and EA will screen all existing vendors on a quarterly basis. The EA will export a list of current vendors from NADAP’s accounting system to forward to the Director of Data Services, who will screen the exported list against the SAM Exclusion List, LEIE, OFAC SDN, and OMIG Exclusion list. Results of the screenings will be included in the appropriate Corporate Compliance Monthly Activity Report. If this screening reveals that a contractor is included on the SAM Exclusion List, LEIE, OFAC SDN, or OMIG Exclusion List, NADAP will immediately terminate the contractor’s contract. Upon receipt of notification from the U.S. Department of Health and Human Services Office of Inspector General (the “OIG”) that a contractor has been excluded from a federal health care program, NADAP will terminate the contractor’s contract as soon as is practicable. If any employee notifies the CCO that a contractor is subject to such an exclusion, the CCO, will investigate the matter. Subcontractors A contractor may enter into a subcontract only with the prior approval of the NADAP employee responsible for overseeing the contract. No subcontract will be approved unless (i) the CCO screens the subcontractor against the SAM Exclusions, LEIE, OFAC SDN, and OMIG Exclusion List and determines that the subcontractor is not an excluded person or (ii) obtains a representation in writing from the contractor that it has conducted such screening of the subcontractor and determined that the subcontractor is not an excluded person.