USPI, INC.
TARPON SPRINGS, FLORIDA

United Surgical Partners International (USPI) and Tenet have combined forces to create the nation’s largest ambulatory surgery provider. Our combined network of exceptional surgical and imaging facilities includes approximately 20 imaging centers, over 90 urgent care facilities, and over 265 short-stay surgical facilities. Together, our partnerships include over 50 health systems and more than 4,000 physicians. in safe, efficient and caring USPI facilities in communities of every size across 28 states. Our physician partners are focused on providing quality patient care, in part because they are invested in their USPI facility. We provide the infrastructure and support they need to perform their best. This is one of the advantages of partnering with USPI. We share a vision with our physician and health system partners. Our goal is to provide the quality of healthcare services we would insist upon for our own families. Since our founding in 1998, this goal has helped us grow exponentially. Today, our strategic joint venture with Tenet establishes USPI as one of the nation's leading providers of ambulatory solutions. See how our joint venture model between Baylor and USPI has yielded tremendous success in the Dallas-Fort Worth market. We are a United Surgical Partners International is an experienced and trusted partner in some of the nation’s most successful ambulatory surgical networks. We are dedicated to providing high-quality, lower-cost solutions as various reform initiatives unfold in the communities we serve. We provide strategic solutions for physicians, health systems and those paying for the cost of health care services, such as employers, insurance companies and government programs. Our mission is to care for every patient and their family as if they were our own. Each patient, each family, each and every time. Our operating model is scalable, but also flexible enough to adapt to the needs of each market. Health systems partner with us to further execute their ambulatory network strategies and fulfill their missions and ministries. We align with our health system partners both clinically and economically to enhance their facility network, while providing more access, as the importance of moving business to shorter stay settings elevates. Our physicians align with us to solidify their market position as networks form and narrow. Our physicians partner with us to increase their productivity, better control the outcomes of the facilities in which they practice, and to ensure excellence in the experience of their patients and families. See how our joint venture model between Baylor and USPI has yielded tremendous success in the Dallas-Fort Worth market. Each year, USPI recognizes exceptional employees across our facilities wh USPI's EDGE™ stands for Every Day Giving Excellence. It is a proprietary approach to continuous performance improvement developed by USPI that enables us to share best practices and to maintain continuous clinical quality and safety improvements at every USPI facility. USPI's EDGE™ USPI's EDGE™ , our patients receive the benefit of lessons learned across the entire USPI network, and our staff acquires the knowledge they need to provide the highest level of quality, safety and service to your patients. See how our joint venture model between Baylor and USPI has yielded tremendous success in the Dallas-Fort Worth market. The Chief Compliance Officer provides regular reports to the Quality, Compliance & Ethics committee of Tenet's Board of Directors. USPI's Code of Conduct is distributed to all USPI employees and certain contractors and vendors. The Code of Conduct is also available on USPI’s InSite, USPI's intranet communication system. The Code of Conduct sets forth USPI's commitment to compliance with all federal healthcare program requirements. Updates to the Code of Conduct are provided as necessary. USPI has a comprehensive set of policies and procedures that address a wide range of compliance- related issues including but not limited to physician relationships, coding, specific billing and reimbursement topics, and human resources General Training to All USPI Employees All new employees must complete an initial ethics and compliance training program as part of their onboarding process. In addition, all employees must complete annual ethics and compliance refresher training. USPI’s Code of Conduct, described above, is used as the foundation for the training. Certain contract workers also are required to complete these training sessions. USPI's comprehensive training program provides relevant employees with customized compliance training, including HIPAA/information privacy and security. Additional training may be required when a new policy is adopted. Under the terms of the Charter, USPI provides additional specialized training to the following groups: Each quarter, USPI’s operations and financial teams sign an attestation which covers compliance with USPI’s policies, conflicts of interest, internal controls, financial statement accuracy, fraud and awareness of the Compliance Hotline. These attestations are submitted by 700+ individuals, and any exceptions noted are reviewed by USPI’s Disclosure Committee. Annually, USPI determines its monitoring and auditing priorities by conducting an annual risk assessment and developing a compliance work plan. The work plan activities includes areas such as reviews of arrangements with physicians and other referral sources, coding compliance audits, clinical quality audits, privacy and security vulnerability reviews. USPI’s dedicated compliance officers track responses and resolution of any issues identified through the Compliance Hotline, employee reports, external reports and internal or external auditing results. The compliance officers use a database to track progress toward issue review and resolution, and work to ensure that USPI has access to relevant documentation each time an issue is resolved. As described throughout this summary, USPI investigates reported allegations and takes appropriate corrective action. Elements of each corrective action plan include: