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the above, this term "covered persons" does not include – (a) part‐time or per diem employees, contractors, subcontractors, agents, and other persons who are not reasonably expected to work more than hours during a reporting period, except that any such individuals shall become "covered persons" at
(c) the compliance officer is not, and will not be subordinate to, the health director, the reservation attorney or the tribes' comptroller, nor does the compliance officer have any responsibilities that involve acting in any capacity as legal counsel or supervising legal counsel functions for the tribes...
https://oig.hhs.gov/fraud/cia/agreements/The_Confederated_Tribes_of_the_Colville_Reservation.pdf