SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND AURORA HEALTH CARE UNDER THE AMERICANS WITH DISABILITIES ACT

EVIDENCE OF AURORA'S COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS

12. Aurora has reviewed and revised as appropriate, and the United States has approved, all existing non-discrimination and infectious disease policies, programming and training that are relevant to the complaints.

13. The role of Aurora's Civil Rights Officer has been expanded to better coordinate handling of any future discrimination complaints. Prior to receiving notice of the Department's investigation in early December 2015, the role of Aurora's Civil Rights Officer was expanded to better coordinate handling of any future discrimination complaints. The Civil Rights Officer position was moved from Interpreter Services as a part-time position and made into a separate and distinct position under Aurora's Diversity and Inclusion department. The Civil Rights Officer now works directly in collaboration with Aurora's Legal, Risk and Compliance departments to appropriately respond to civil rights complaints as well as perform proactive services that increase civil rights awareness and compliance within the Aurora community. In October 2016, the Civil Rights Officer position was made into a full-time position.

14. Aurora requires the completion of annual compliance training as a condition of employment for all Aurora employees, including those who are directly involved with the admissions or treatment of patients. This annual training has been supplemented to include additional instruction on civil rights, protected classes, HIV/AIDS and discrimination in general. In addition, all licensed independent practitioners (physicians, podiatrists, etc.) and advanced practice professionals are required to complete annual compliance training as a condition of Medical Staff membership.

15. Aurora requires the completion of annual safety training, including instruction on standard precautions—recommended by the Centers for Disease Control for the care of all patients, regardless of their diagnosis or presumed infection, and inclusive of universal precautions—as a condition of employment for all Aurora employees, including those who are directly involved with the admissions or treatment of patients.

16. Appropriate employment-related disciplinary actions were taken with respect to the orthopedic surgeon who encountered Complainant No. 1, which included supplemental trainings relating to non-discrimination and standard precautions, and a donation of $9,680 was made to the AIDS Resource Center. This supplemental training also was rolled out to all Aurora physicians, including the urologist who examined Complainant No. 2, and advanced practice providers as mandatory education intended to supplement the 2017 annual compliance course.

17. Aurora electronically maintains an attendance log that monitors mandatory compliance, civil rights, and safety training of all Aurora employees who are involved with the admissions or treatment of patients.