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SETTLEMENT AGREEMENT <br /> This Settlement Agreement("Agreement") is entered into among the United States of <br /> America, acting through the United States Department of Justice and on behalf of the Office of <br /> Inspector General (OIG-HHS) of the Department of Health and Human Services (HHS);the <br /> Defense Health Agency(DHA), acting on behalf of the TRICARE program (collectively,the <br /> "United States"), and the City of Everett("Everett") (hereafter collectively referred to as "the <br /> Parties"),through their authorized representatives. <br /> RECITALS <br /> A. The City,through the Everett Fire Department(EFD),provides ambulance <br /> services for emergency transport for residents of Snohomish County. EFD bills Federal <br /> healthcare programs for basic life support(BLS)and advanced life support(ALS)transportation <br /> costs. <br /> B. The United States contends that EFD submitted or caused to be submitted claims <br /> for payment to the Medicare Program,Title XVIII of the Social Security Act,42 U.S.C. §§ <br /> 1395-1395kkk-1 ("Medicare") and the TRICARE Program, 10 U.S.C. §§ 1071-1110b <br /> ("TRICARE"). <br /> C. This Settlement Agreement is neither an admission of liability by EFD and the <br /> City of Everett nor a concession by the United States that its claims are not well-founded. <br /> D. The United States contends that it has certain civil claims against Everett arising <br /> from EFD's "up-coding" of claims for emergency medical transport from BLS to ALS which <br /> caused Medicare and TRICARE to pay EFD for certain services at a higher rate than they should <br /> have during the period from January 1, 2010 through June 26, 2016. That conduct is referred to <br /> below as the "Covered Conduct." <br /> {AGS 1613993.DOCX;3/13113.000005/ <br />