VOLUNTARY COMPLIANCE AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND THOMAS JEFFERSON UNIVERSITY HOSPITALS INC. & OUTPATIENT IMAGING AFFILIATES, LLC. DJ# 202-62-458

B. TERMS OF AGREEMENT

8. Within 30 days of the effective date of this Agreement, Jefferson Outpatient will adopt and incorporate the Non-Discrimination Policy (attached as Exhibit 1) into its existing policies and post it in conspicuous locations in all of its offices.  Jefferson Outpatient will also post and maintain a hyperlink to the Non-Discrimination Policy on the home page of its website.

9. Jefferson Outpatient will ensure that individuals with disabilities are afforded equal access to its facilities and services. Jefferson Outpatient will also train all staff who interact with patients on the requirements of Title III of the ADA as they apply to healthcare facilities and on techniques for safely assisting individuals with mobility disabilities to transfer to imaging equipment or examination tables.  In addition, Jefferson Outpatient will incorporate the above training into its new employee orientation for all future employees who will have contact with patients.

10. To ensure that it provides individuals with mobility disabilities equal access to its services and facilities – whether by appointment or walk-in – Jefferson Outpatient will have staff available to safely assist individuals with mobility disabilities with transferring to imaging equipment or examination tables at all times when its facilities are accepting patients.  In addition, Jefferson Outpatient represents that it has taken steps to ensure that each of its outpatient facilities has, and will maintain, a Hoyer lift, or other patient lift designed to safely transfer a patient, to existing DEXA machines, examination tables, or other equipment.

11. Within 14 days of the effective date of this Agreement, Thomas Jefferson University Hospitals, Inc., will offer to pay compensatory damages to the complainant in the amount of $5000.00, subject to his execution and return of a release (attached as Exhibit 2).  Within 14 days of receipt of the executed release, Thomas Jefferson University Hospitals, Inc., or Jefferson Outpatient shall send, by U.S. Mail, return receipt requested or by overnight delivery, a check for $5000.00 to the complainant.

12. Should the complainant choose to seek treatment, testing, or any other services at Jefferson Outpatient, Jefferson Outpatient will not engage in any retaliatory conduct towards complainant as a result of his filing a complaint with the Department, participation in the investigation process, or receipt of compensatory damages.

13. In consideration of the terms of this Agreement, the Department agrees to close its investigation of this matter, DJ# 202-62-458, except as provided in Section C, below.