COMPLIANCE OFFICER DUTIES

Ÿ Overseeing and monitoring the implementation of the compliance program.

Ÿ Reporting on a regular basis to the appropriate internal person or group on the progress of implementation, and assisting in establishing methods to improve the supplier’s efficiency and quality of services, and to reduce the supplier’s vulnerability to fraud, abuse, and waste;

Ÿ Periodically revising the program in light of changes in the Keene Medical Products needs, and in requirements of federal, state, and private payor health care plans;

Ÿ Revising employees’ certifications that they have received, read, and understand the standards of conduct;

Ÿ Coordinating a multifaceted compliance education and training program;

Ÿ Ensuring that independent contractors and agents who provide services to Keene Medical Products, Inc., are aware of the requirements of the supplier’s compliance program;

Ÿ Assisting Keene Medical Products, Inc. financial management in coordinating internal compliance review and monitoring activities;

Ÿ Independently investigating and acting on matter’s related to compliance;Ÿ Developing policies and programs that encourage managers and employees to report

suspected fraud and other improprieties without fear of retaliation, andŸ Continuing the momentum of the compliance program and the accomplishment of its

objective long after the initial years of implementation.Ÿ Review all contracts with employees and contract people, perform audits periodically to

ensure compliance.