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federal health care programs (as defined in u.s.c. § a- b(f)). contemporaneously with this cia, drayer is entering into a settlement agreement with the united states. drayer represents that, prior to this cia, it established a comprehensive corporate compliance program that includes, among other things
than shareholders who have an ownership interest of less than %), officers, directors, and employees of drayer; and ( ) all contractors, subcontractors, agents, and other persons who furnish patient care items or services or who perform billing or coding functions on behalf of drayer, excluding vendors...
https://www.oig.hhs.gov/fraud/cia/agreements/Drayer_Physical_Therapy_Institute_LlC_06302016.pdf