Instructions for Use

This register is ABAS's single consolidated record of its vendor and contractor arrangements, replacing the earlier practice of keeping arrangements in separate per-payor cloud folders. It serves two compliance processes:

• POL-005 (Anti-Kickback Statutes). The annual review of active vendor and referral-source arrangements, with the Compliance Officer's review and the Executive Director's signature.
• POL-011 (Exclusion Checks). The pre-engagement and monthly exclusion screening of every vendor against the federal and state lists.

The Director of Operations maintains the register, keeping the written agreements and the current list of active arrangements available for compliance review (POL-005, Procedures, Responsibilities) and running vendor screening (POL-011, Procedures, Responsibilities).

How to use this register:

1. Before ABAS enters any arrangement involving payment or anything of value with a vendor or referral source, the employee proposing it sends the terms to the Compliance Officer for review (POL-005, Procedures, Step 1). Record the arrangement once it is under review.
2. Record the Compliance Officer's review date and conclusion, including the fair-market-value basis, the documented business need, and any safe harbor relied on (POL-005, Procedures, Step 2).
3. Record the Executive Director's signature and date for each approved arrangement, and store the written agreement (POL-005, Procedures, Step 3). Enter the written-agreement reference, the effective date, and the next-review date.
4. Before any vendor begins work, screen it against the LEIE, SAM.gov exclusions, and the Medicaid exclusion list of each state in which ABAS operates, and record the screening (POL-011, Procedures, Steps 1 and 3).
5. Each calendar month, re-screen all active vendors against the same three lists and update the exclusion-screening record (POL-011, Procedures, Step 2).
6. If a screening returns a potential match, do not act on it alone. Forward it to the Compliance Officer, who verifies identity using additional identifiers before treating the match as confirmed (POL-011, Procedures, Step 4). Record the outcome under POL-003.
7. Use the Referral Source flag to mark vendors that are also referral sources, so the annual POL-005 review can focus on those arrangements. Keep each vendor's status current (Active or Inactive).

Form Realization and Fallback

This is the canonical, authoritative version of Form REG-002, maintained in the compliance documentation. It defines the columns, fields, and structure that any realization of the vendor and contract arrangements register must capture.

ABAS maintains this register as a single consolidated record under the Director of Operations, replacing the earlier per-payor cloud folders. That consolidated register, whether a spreadsheet, a database, or a contract-management system stored in company files, is the electronic realization of this form: it must capture the same content defined here and carry the form identifier REG-002, so the policies and procedures refer to the register by its identifier rather than to any one folder or channel.

The documented register here is always available as a fallback. It can be printed and maintained on paper whenever the electronic register is unavailable or a paper record is otherwise needed, for example during a system outage or a loss of internet access.

Alternate-language and electronically read (screen-reader) versions are derived from this canonical form and must match it, so the same content stays authoritative across every realization.

Vendor & Contract Arrangements Register

Maintained by: Director of Operations

Record one row per vendor or contractor arrangement. The arrangement type describes what the vendor provides (for example: clinical contractor, professional service, supplier, referral source). Flag any vendor that is also a referral source. The status is one of: Active or Inactive.

CO = Compliance Officer; ED = Executive Director; FMV = fair market value. The annual POL-005 review uses the CO Review, FMV, business-need, and Next Review fields; focus the review on arrangements flagged as referral sources.

Exclusion Screening Record

Maintained by: Director of Operations

Screen every vendor before engagement and re-screen all active vendors each calendar month (POL-011, Procedures, Steps 1 and 2). The lists checked are the LEIE, SAM.gov exclusions, and the Medicaid exclusion list of each state in which ABAS operates (in Massachusetts, the MassHealth suspended or excluded provider list). Record the lists actually checked for each vendor. The result is one of: Clear or Potential match. A potential match is forwarded to the Compliance Officer for identity verification before it is treated as confirmed (POL-011, Procedures, Step 4).

Each screening record is retained for at least six years (POL-011, Procedures, Step 3).

Form REG-002 · Owning policies: POL-005 (Anti-Kickback Statutes) and POL-011 (Exclusion Checks). Version number and effective date are set in ABAS's document-control record at adoption.

Retention

The vendor and contract arrangements register is part of ABAS's compliance records. Per POL-005 and POL-011:

• The Director of Operations retains the register and the underlying written agreements, and keeps the current list of active arrangements available for compliance review (POL-005, Procedures, Responsibilities).
• Each exclusion-screening record, pre-engagement and monthly, is retained for at least six years (POL-011, Procedures, Step 3).
• The register is the source for the Compliance Officer's annual review of active vendor and referral-source arrangements (POL-005, Procedures, Step 5) and for the monthly exclusion re-screening (POL-011, Procedures, Step 2), and supports reporting to the Compliance Committee.

The Director of Operations is custodian of the register and maintains it at a company-owned level, consistent with the compliance program's records practices.