FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / lakeview-legacy-compliance-gap-memo.docx
lakeview-legacy-compliance-gap-memo.docx · 1010-00003

Parties

Arbor Health Technologies Inc
Harkness LLP
Summary Arbor Health Technologies Inc
Westbrook Hale LLP
Associates LLP
Diligence Context Westbrook Hale LLP
Halsted Accounting Group LLP
Northbridge Valuation Advisors LLC

Dates

April 10, 2023
August 15, 2022
January 24, 2023
December 12, 2022
June 3, 2022
January 19, 2021

Amounts

$11.4
$45,000
$60,000
$72,000
$177,000
$18.2
$10.9
$100,000
$278,000
$412,000

Obligations

If a financial relationship exists that does not satisfy an applicable exception, all claims for DHS arising from the prohibited referral are non-payable and, if already paid, must be refunded
Among its requirements, the employment exception mandates that compensation paid to the employed physician must be "consistent with fair market value" and must not be "determined in a manner that takes into account the volume or value of referrals by the referring physician
The holdover must be on the same terms and conditions as the expired agreement
Under the regulatory framework, any modification to the terms of a holdover arrangement — including compensation adjustments — must be reflected in a writing that satisfies the applicable exception's requirements
All compensation terms must be documented in writing, and the amended agreements must be supported by FMV opinions from Northbridge
All ancillary service revenue-sharing components must be eliminated