Extract to table

which AHT acquired through an asset purchase transaction on August 15, 2022, are subject to this Policy and must be brought into full compliance within the timeframes specified in Section 11

1 Key Terms For purposes of this Policy, the following terms shall have the meanings set forth below: "Anti-Kickback Statute" or "AKS" means the federal Anti-Kickback Statute, codified at 42 U

Failure to satisfy all elements of an applicable safe harbor does not necessarily mean that the arrangement violates the AKS, but it does mean that the arrangement is not entitled to safe harbor protection and must be evaluated on its facts and circumstances

2 Fair Market Value and Commercial Reasonableness All vendor arrangements entered into by AHT must reflect fair market value for the goods or services provided

FMV must be established through objective, documented means, as set forth in the AHT Fair Market Value Determination Procedures (AHT-COMP-2023-006)

In addition to the FMV requirement, all vendor arrangements must be commercially reasonable