Contract analysis

1. Employed Physicians. All one hundred forty-seven (147) W-2 employed physicians of AHT, regardless of specialty, clinic location, or date of hire.

2. Independent Contractor and Medical Director Physicians. All thirty-eight (38) physicians engaged under independent contractor or medical director arrangements with AHT, including those providing services at AHT clinic locations and those providing administrative or oversight services on a part-time basis.

3. Lakeview Legacy Physicians. All fourteen (14) physicians integrated from the Lakeview Medical Associates, P.C. acquisition (twelve employed and two independent contractors), who are subject to this Policy in the same manner as all other AHT-affiliated physicians.

4. Clinical and Administrative Staff. All clinical and administrative staff involved in ordering, processing, scheduling, or billing DHS, including but not limited to clinic administrators, nursing staff who process referral orders, scheduling coordinators, and billing and coding personnel.

5. External Referral Entities. This Policy governs AHT's referral relationships with external entities including but not limited to Meridian Diagnostics LLC (mobile MRI and advanced diagnostic imaging provider at four AHT clinic locations), Pinnacle Laboratory Services Inc. (clinical laboratory testing provider for Rhode Island and southeastern Massachusetts clinics), and physician practices managed through ConnectiC

6. All AHT Clinic Locations. This Policy extends to all twenty-three (23) AHT clinic locations across Massachusetts, Connecticut, Rhode Island, and New Hampshire, including the two legacy Lakeview clinic locations in Worcester and Shrewsbury, Massachusetts.

7. All Payers. This Policy applies to referrals for services reimbursed by Medicare, Medicaid, and — to the extent required by applicable state law (including, without limitation, the Massachusetts anti-kickback law, M.G.L. c. 175H, § 3, which extends to all payers) — commercial payers. 1.4 Relationship to Other AHT Policies This Policy is one component of AHT's comprehensive compliance framework, as revised through

1. Referrals Involving Ownership Interests. Referring patients to entities in which the physician or an immediate family member holds an ownership or investment interest, unless a Stark Law exception specifically applies to the ownership arrangement (e.g., the ownership/investment exception requirements of 42 C.F.R. § 411.356 are fully satisfied). Any physician who holds, or whose immediate family member holds, such

2. Free or Below-Market-Value Items or Services. Receiving or providing free or below-market-value items or services (e.g., electronic interfaces, equipment, office supplies, software, or staffing support) from or to referral sources where the value exceeds the non-monetary remuneration exception threshold. For CY2023, the Stark Law non-monetary compensation exception permits items with an aggregate value of no more

3. CME Sponsorship Conditioned on Referrals. Accepting continuing medical education ("CME") sponsorship, educational grants, or other benefits from entities that receive referrals from AHT physicians, where such benefits are conditioned upon, correlated with, or provided in a manner that appears to reward referral volume. Legitimate, arm's-length CME sponsorship by industry participants may be permissible under certa

4. Referrals Influenced by Financial Incentives. Making referrals that are influenced by financial incentives tied to the volume or value of referrals under any compensation arrangement. This includes, but is not limited to, bonus structures, profit-sharing formulas, productivity incentives, or any other compensation mechanism that directly or indirectly rewards a physician for generating DHS referrals.

5. Indirect Compensation Arrangements Without Exception Coverage. Referring patients to entities providing management services to or through AHT where the financial relationship creates an unbroken chain of compensation linked to referrals, and the indirect compensation arrangement does not meet the requirements of the applicable Stark exception (42 C.F.R. § 411.357(p)) and AKS safe harbor. 4.3 Illustrative Examples

1. Referral Order Entry. All in-office ancillary referral orders must be entered through the ArborConnect system. Each order must include order-specific documentation of the referring physician, the supervising physician (if different from the referring physician), the DHS category, the clinical indication for the service, and the clinic location where the service will be furnished.

2. Ancillary Services Inventory. Clinic administrators at each AHT clinic location must maintain a current inventory of ancillary services available at their location. This inventory must include the specific types of laboratory tests, imaging studies, and physical therapy services available on-site, as well as the equipment used to furnish those services. The inventory must be updated semi-annually and submitted to

3. New Service Line Approval. Any new ancillary service line or new clinic location at which ancillary services will be offered must be vetted through the Compliance Department (Derek Huang) before AHT begins accepting referrals for services at that location. The Compliance Department must confirm IOASE eligibility — including the same-building requirement, supervision requirements, billing pathway configuration, and

4. Quarterly IOASE Audit. The Compliance Department must conduct a quarterly audit of claims billed under the IOASE. The audit must verify that: (a) the services were furnished at an AHT clinic location with on-site ancillary capabilities; (b) appropriate supervision was documented; (c) the services were billed under AHT's NPI and PTAN; (d) the same-building requirement was met; and (e) no services were improperly cl