Compliance for Transplant Performance Centers Standardized Process

If a transplant program does not meet the Evaluation Process Standards criteria in the section below or is under investigation by Organ Procurement and Transplantation Network (OPTN), Centers for Medicare & Medicaid Services (CMS), or other industry-accepted oversight organizations, The Health Net Specialty Network Committee (SNC) determines whether the actions in the standard process are appropriate for the transplant program in question. Health Net requests all Transplant Performance Centers share any external oversight organization's findings and recommendations. Transplant Performance Centers that fail to submit this information or meet Health Net's defined evaluation criteria may be subject to removal from the network, per SNC discretion.

Letter of Deficiency

If a participating Transplant Performance Center does not comply with evaluation requirement (volume, graft survival, and/or patient survival outcomes), the following may apply:

1. Health Net will send a letter of deficiency, and will indicate if a response is needed from the Transplant Performance Center.
2. The Transplant Performance Center is given 21 days from the requested date to provide a response.
3. If the Transplant Performance Center does not answer by the deadline, Health Net will mail a certified letter, giving a two-week extension.
4. If the Transplant Performance Center does not answer after the second deadline, Health Net will send a third and final letter.

1. This notice informs the Transplant Performance Center of SNC's decision, including possible termination of the Transplant Performance Center and corresponding transplant program due to non-response.

Corrective Action Plan Submission and Implementation

If the Transplant Performance Center is non-compliant for the transplant volume and/or survival criteria, they may be subject to completing a corrective action plan (CAP). If requested, the Transplant Performance Center must submit the CAP within 21 calendar days of the requested date. Health Net reviews the CAP for appropriateness and completeness, notifying the Transplant Performance Center if the CAP is approved or more information is needed. If Health Net does not approve the CAP, the Transplant Performance Center is notified and granted an additional 15 calendar days for revision and subsequent resubmission of their CAP to Health Net.

Health Net will send a second notice of deficiency to Transplant Performance Centers that have not responded to the first notice of deficiency. The Transplant Performance Center will have an additional 15 days from the date of receipt to respond to the originally requested CAP. Health Net reviews Transplant Performance Centers that do not respond to the second letter of deficiency for recommendations or sanctions, which may include suspending new patient referrals.

Health Net sends a third and final notice to the Transplant Performance Center if a response to requests for a CAP have not been provided, or if there is insufficient progress toward correcting the deficiencies. Such notice informs the Transplant Performance Center of Health Net's decision, including potential termination of the transplant program and that these actions may be avoided if both of the following occur:

• The Transplant Performance Center submits an acceptable CAP to Health Net within 15 calendar days of receipt of the final notice.
• The Transplant Performance Center completes and demonstrates substantial progress toward completing the correction within 30 calendar days.

Once a CAP has been approved, the Transplant Performance Center program must report updates at six months and one year following the original CAP submission date, or until completion of the CAP implementation.

On-Site Visits

At any time, either Health Net or a Transplant Performance Center may request, with reasonable advance notice, a meeting to discuss transplant program issues or concerns. Either party may not unreasonably withhold such meeting requests.