Settlement Agreement Regarding The George Washington University Medical Center

UNDER THE AMERICANS WITH DISABILITIES ACT OF 1990

  1. This Settlement Agreement ("Agreement") is made and entered into by and between the United States of America and The George Washington University ("GW"), including its unincorporated division, The George Washington University Medical Center ("GWUMC"), and its former unincorporated division, The George Washington University Hospital ("GWUH"), and, for the limited purposes stated in Paragraph 38 of this Agreement, District Hospital Partners, L.P. ("DHP") (collectively, the "Parties").
  2. This Agreement resolves an investigation by the United States Department of Justice into certain activities of GW, GWUMC, GWUH, and certain agents, servants, and employees of GWUMC under the Rehabilitation Act of 1973 ("Rehabilitation Act") and the Americans with Disabilities Act of 1990 ("ADA") concerning allegations made by an individual (the "Complainant") with the human immunodeficiency virus ("HIV") that he was denied surgical intervention while a patient at GWUH because of his HIV status in violation of the Rehabilitation Act and the ADA. GW, GWUMC, GWUH, and DHP deny the Complainant's allegations and deny any liability in this matter and have entered into this Agreement for the sole purpose of resolving a disputed claim.
  3. The Parties agree as follows:

DEFINITIONS

  1. "Department" means the United States Department of Justice and because the Department has designated enforcement authority for title III of the ADA and the Rehabilitation Act, "Department" is used interchangeably with "United States."
  2. "Respondents" means GW, GWUMC, GWUH, and DHP, collectively.
  3. "University" or "GW" means The George Washington University, a congressionally-chartered nonprofit corporation and comprehensive private university.
  4. "Hospital" or "GWUH" means The George Washington University Hospital, an acute care facility that is and will be located on Washington Circle in Washington, D.C., currently owned and operated by DHP, of which the University is a limited partner. At the time of the underlying events material hereto, the Hospital was owned and operated by the University. DHP had no ownership interest in GWUH at the time of the underlying events material hereto and had no involvement in the events giving rise to the Complainant's allegations.
  5. "Medical Center" or "GWUMC" means the University's Medical Center, which is an unincorporated division of the University and includes both its physicians and its medical training programs.
  6. "Medical Staff" means any physician or other professional who provides patient care services at the Hospital, who has been granted Medical Staff membership with clinical privileges at the Hospital, whether or not employed by or under contract with the Hospital. GWUMC represents that nearly all persons who are regular members of clinical departments of the medical faculty at GWUMC maintain Medical Staff membership with clinical privileges at the Hospital and are, thus, bound by the Standard Practices issued by the Hospital.
  7. "Allied Health Professional" means any health care provider other than a member of the Medical Staff who provides patient care services to patients at the Hospital.
  8. "Health Professional" means a member of the Medical Staff or an Allied Health Professional.
  9. "Cardiothoracic Surgeon" means a physician who specializes in providing cardiothoracic surgical services.
  10. "Patient" means any person presenting to the Hospital for health care services, whether those services are provided at its current or future location at Washington Circle in Washington, D.C., or are provided by or on behalf of the Hospital at another location.
  11. "Standard Practice" means an official policy that the Hospital has adopted regarding the manner in which health care services are to be provided by the Hospital's Medical Staff and Allied Health Professionals.

SUBJECT MATTER JURISDICTION

  1. GWUH is an acute care medical facility located at Washington Circle in Washington, D.C. GWUH is a private hospital whose operations affect commerce and is, therefore, a public accommodation within the meaning of 42 U.S.C. ァ 12181(7)(F); and a place of public accommodation within the meaning of 28 C.F.R. ァ 36.104. Because GWUH is a facility not intended for residential use whose operations affect commerce, it is also a commercial facility within the meaning of 42 U.S.C. ァ 12181(2) and 28 C.F.R. ァ 36.104.
  2. DHP is a private partnership that owns and operates GWUH. To the extent it owns, operates, and leases GWUH, which is a place of public accommodation, DHP is a public accommodation within the meaning of 42 U.S.C. ァ 12181(7)(F) and 28 C.F.R. ァ 36.104.
  3. GWUMC includes professional offices of health care providers whose operations affect commerce and, to that extent, is a public accommodation within the meaning of 42 U.S.C. ァ 12181(7)(F); and a place of public accommodation within the meaning of 28 C.F.R. ァ 36.104. To the extent GWUMC includes professional offices of health care providers it is a facility not intended for residential use whose operations affect commerce, and is also a commercial facility within the meaning of 42 U.S.C. ァ 12181(2) and 28 C.F.R. ァ 36.104. GW is a private nonprofit corporation that formerly owned and operated GWUH. To the extent it was an owner and operator of GWUH and, to the extent stated above for GWUMC, GW was and is a public accommodation within the meaning of 42 U.S.C. ァ 12181(7)(F) and 28 C.F.R. ァ 36.104.

ACTIONS TO BE TAKEN BY THE RESPONDENTS

Issuance of a Standard Practice

  1. GWUH shall issue a Standard Practice titled, "Nondiscrimination Concerning Patients with Infectious Diseases, Including HIV and AIDS," for the purpose of explaining the Hospital's nondiscrimination policy with regard to patients with infectious diseases. It includes the following provisions:
    1. PATIENTS WITH INFECTIOUS DISEASES, INCLUDING HIV OR AIDS
      1. Policy. It is the policy of The George Washington University Hospital that medically appropriate treatment (as determined by reasonable medical judgment based on current medical knowledge) shall not be denied or withheld on the basis of the patient's infectious disease status. Infectious diseases may include hepatitis B, hepatitis C, multi-drug resistant tuberculosis, Human Immunodeficiency Virus and Acquired Immune Deficiency Syndrome. Any Hospital employee, contractor or member of the Medical Staff found in noncompliance with this policy shall be subject to appropriate disciplinary action under the relevant procedures, which include those under applicable Hospital human resources policies and the Bylaws and Rules and Regulations of the Medical Staff.
      2. Example and Discussion. For example, a physician may not refuse to perform surgery or another procedure or discourage surgery or another procedure for a patient merely because the patient has HIV or AIDS. A physician, however, may make a reasonable medical determination, based on current medical knowledge, that the patient's illness makes such procedure inadvisable for the individual patient. It would be inappropriate to deny or discourage surgery or another procedure for a patient with HIV or AIDS merely because of a generalization that patients with HIV or AIDS are too sick to benefit from the surgery or procedure, without appropriately considering the patient's own condition. If a physician has a question whether surgery or another procedure would benefit a patient with HIV or AIDS, and if the procedure would be indicated in the absence of such condition, the physician shall request appropriate consultation with an Infectious Disease specialist or other appropriate specialist as time and circumstances permit, before making a final decision or recommendation to the patient.
      3. Universal Precautions. Universal Precautions and other special precautions as appropriate address the manner in which Hospital personnel may resolve concerns about their risk of exposure to infectious diseases. Universal Precautions are designed to address real or perceived risks of surgery or another procedure for patients with infectious diseases. Therefore, such concerns may not influence treatment decisions or recommendations to a patient with an infectious disease.
    2. EXPRESSIONS OF CONCERNS

      If a patient, family member, physician or other Hospital personnel believe that a patient may have received or be receiving medical care or services that is inconsistent with this policy, such person should contact the Patient Liaison (4-8889) during weekdays, or the Patient Hotline (4-3398) at all other times, or the Ethics Committee at (202) 994-3208 during regular business hours or through the page operator at (202) 994-3321 at other times. Once notified, the Ethics Committee will initiate an investigation as set forth in Standard Practice ETH 6 in a timely fashion. To the extent consistent with principles of patient confidentiality, the Ethics Committee will inform the patient, attending physician, Medical Director and reporting person of its recommendations. In addition, with respect to any disability, if a patient believes that s/he has been discriminated against because of a disability, the patient may contact the District of Columbia Department of Human Rights by calling (202) 724-1385, or may contact the Department of Justice Disability Rights Section by calling 1-800-514-0301.

  2. The Standard Practice shall apply to all members of the Medical Staff and to all Allied Health Professionals at GWUH. GW or GWUH shall cause all affected Health Professionals to be provided notice of its issuance promptly, but no later than thirty (30) days after the Standard Practice is put into effect.
  3. In accordance with its standard policies and procedures, GWUH shall undertake disciplinary actions in accordance with the Bylaws and Rules and Regulations of the Medical Staff and any other means available in any instance where any person responsible for complying with the Standard Practice has failed to comply with it.

Revisions to By-Laws, Rules, and Regulations

  1. GWUH hereby represents that its current Bylaws, Rules, and Regulations require all members of the Medical Staff and Allied Health Professionals to abide by Standard Practices issued by the Medical Staff, the Hospital and any other department in which the Medical Staff member may provide health care services. In any revision of those Bylaws within the next five years after the date of this Agreement, the Hospital shall continue this requirement in substance and clarify if necessary that compliance with Standard Practices (or any future name of such policies) is a requirement of Medical Staff membership.

Revisions to "Patient Information - Your Guide" Booklet

  1. GWUH shall modify the booklet entitled "Patient Information - Your Guide to the George Washington University Hospital," to include the following language in the section currently entitled "Services for Disabled Patients":

    It is the Hospital's policy to provide medically appropriate treatment without unlawful discrimination based on whether a patient has a disability, is regarded as having a disability, or has an Infectious Disease that may or may not be regarded as a disability. Infectious Diseases may include hepatitis B, hepatitis C, multi-drug resistant tuberculosis, Human Immunodeficiency Virus (HIV) infection and Acquired Immune Deficiency Syndrome (AIDS). For example, a physician may not refuse to perform surgery or another procedure or discourage surgery or another procedure for a patient merely because the patient has HIV or AIDS. A physician, however, may make a reasonable medical determination, based on current medical knowledge, that a patient's illness and current medical condition makes such a procedure inadvisable for the individual patient. If you believe that you or any patient has been discriminated against because of a disability or infectious disease, please contact the Patient Liaison at (202) 994-8889, or the Ethics Committee at (202) 994-3208, during regular business hours, or through the pager operator at (202) 994-3321 at other times. If desired, you may also contact the District of Columbia Department of Human Rights by calling (202) 724-1385, and/or you may contact the Department of Justice Disability Rights Section by calling (800) 514-0301.

  2. The title of the section of the "Patient Information - Your Guide" booklet currently entitled "Services for Disabled Patients," shall be changed to "Services for Patients with Disabilities and Nondiscrimination Based on Disability," and the retitled section, along with the section currently entitled "Ethics Committee," shall be included in the booklet's Table of Contents.

Revisions to "Patient's Bill of Rights" Brochure

  1. GWUH shall modify the brochure entitled "Patient's Bill of Rights" to read as follows:

    Bullet No. 5: Receive Information that you need to give informed consent for any proposed procedure or treatment including information related to the risks, benefits, and alternatives to the proposed procedure or treatment in light of your condition and current medical knowledge.

    Bullet No. 14: Receive equal treatment at all times and under all circumstances, regardless of race, color, religion, national origin, sex, age, marital status, personal appearance, sexual orientation, veteran status, family responsibilities, disability, infectious disease, matriculation, political affiliation, source of income, or place of residence or business. For more information regarding the Hospital's policy on nondiscrimination, please refer to the Patient Information "Your Guide" Handbook.

Availability of Modified Documents

  1. GWUH and GWUMC shall provide the modified documents described in Paragraphs 22, 23, and 24 to every Patient at GW, GWUH, and GWUMC, by including such documents in each inpatient admission package, and by posting the modified "Patient's Bill of Rights" and providing copies of the "Patients' Information - Your Guide" pamphlet in every inpatient room and in appropriate public areas of GWUH and GWUMC, including the Emergency Room, all waiting rooms, and out-patient waiting areas. In addition, GWUH and GWUMC shall provide copies of the modified documents described in Paragraphs 22, 23, and 24 to any family member, friend, or acquaintance of a Patient upon request.
  2. GWUH and GWUMC shall make the modified documents available in alternate formats (e.g., large print, Braille, audio recording) to the extent required by the ADA and Rehabilitation Act.

Adoption of Agreed Upon Language

  1. The documents and policies described in Paragraphs 18 through 26 shall be proposed by GWUH in the forms and language as stated herein. In the event the governing bodies of GWUH fail to adopt this language verbatim, the dispute resolution provisions of Paragraphs 41 and 42 shall be applicable with regard to each instance where the language adopted differs from that stated herein. The actions set forth in Paragraphs 18 through 27 shall be completed no later than April 30, 1998.

Subsequent Revisions to Modified Documents

  1. The portions of the documents and policies to be modified and/or adopted in accordance with Paragraphs 18 through 27 shall not be modified or rendered in any way ineffective for a period of 5 years from the date of this Agreement unless warranted by changes in medical or scientific knowledge or required by applicable law. Within that 5 year time period, if GWUH or any of the Respondents propose making any changes whatsoever that affect the textual provisions set forth in this Agreement, the Respondents must provide at least sixty (60) days advance written notice to the Department, setting forth the exact wording of the proposed change and the reasoning for the proposed change. If the Department provides written notice of disagreement with any such proposed changes to GWUMC and GWUH within ninety (90) days of receipt of such proposed changes, the Department can, at its option, consider such changes to be a potential violation of the Agreement subject to the dispute resolution and enforcement provisions contained herein.

Modifications to Universal Precautions Re-Certification Training

  1. GWUH shall modify its annual Universal Precautions Re-Certification Training, given as required by law to all Health Professionals who are employed by or under contract with GW, GWUMC, or GWUH and who provide health care services at GWUH, to include a presentation on HIV-infected patients, the nondiscrimination policy contained in the Standard Practice, and the nondiscrimination provisions of the ADA and the Rehabilitation Act. The format and content of such training as relate to this Agreement are to be submitted to the Department in the form of a script or outline for its approval, which shall not unreasonably be withheld. The script or outline shall be submitted to the Department no less than 60 days before the commencement of the first such training provided, however, that nothing in the Agreement shall be construed to prevent GWUH or GWUMC from conducting such training as it deems necessary to meet its legal and regulatory obligations.
  2. In the event that the Department does not agree to the form and content of the relevant portions of the training as set forth in the script or outline, the Department will notify GWUH, in writing, of the specific provisions that it finds unacceptable no later than 30 days after receiving the script or outline submitted by GWUH. Respondent GWUH will have 30 days to make changes to the portions of the outline or script specified. In the event that GWUH does not agree to make changes that will make the script or outline satisfactory to the Department, it shall set forth its reasoning for such refusal in writing within 30 days. If the Department still feels that the script or outline is inadequate, it may seek enforcement of the Agreement in the manner set forth in Paragraphs 41 and 42.
  3. The annual Universal Precautions Re-Certification training, including the presentation specified in Paragraphs 29 and 30, shall be administered to all Medical Staff and Allied Health Professionals at GWUH and GWUMC at least once per year for a period not less than five (5) years from the effective date of this Agreement, and such persons shall be required to receive the training in its entirety.
  4. In the event that Respondents' legal obligation to provide Universal Precautions Re-Certification training shall be reduced or eliminated so that such training is no longer provided to all Medical Staff and Allied Health Professionals at GWUH and GWUMC at least once per year during the five years following the effective date of this Agreement, Respondents' obligation to provide training on the nondiscrimination policy described in Paragraph 29 shall nonetheless continue and such training shall be provided to all members of the Medical Staff and all Allied Health Professionals at GWUH and GWUMC at least once per year during that five year period.

Sponsorship of Symposium

  1. GWUMC agrees to sponsor a symposium on HIV and cardiothoracic surgery (the "Symposium"), which shall be attended by David Alyono, M.D. and Benjamin Aaron, M.D. and any Cardiothoracic Surgeons employed by or under contract with GWUMC or GWUH at the time of the Symposium. GWUMC shall make reasonable efforts to promote the Symposium to all major hospitals and all Cardiothoracic Surgeons in the general area from Charlottesville to Baltimore. The Symposium will address issues of infection control during open-heart surgery, the current state of medical knowledge regarding cardiopulmonary bypass surgery on patients with HIV infection and AIDS, and ethical and legal considerations related to the treatment of patients with HIV infection and AIDS, and will be presented by experts from GWUMC and elsewhere. GWUMC will pay all costs in accordance with a budget that is to be agreed upon by the Parties within 30 days after the effective date of this Agreement. The Symposium will be conducted prior to June 30, 1998.
  2. The Respondents shall provide the Department with a detailed description of all of their plans to publicize the Symposium. This report is to be provided no later than forty-five (45) days prior to the Symposium, and is to be updated fifteen (15) days prior to the Symposium. In its first progress report to the Department following the Symposium, GWUMC shall provide the Department with a list of all persons employed by, or under contract with, GW, GWUMC, and GWUH who attended the Symposium. In addition, in its first progress report to the Department following the Symposium, GWUMC shall provide the Department with data on the number of persons who attended the Symposium, their occupation and medical specialization, if applicable, and the states in which they reside.

Efforts to Disseminate Materials From the Symposium

  1. GW, in conjunction with the speakers for the Symposium, will make its best efforts to disseminate the substantive presentations by publishing them in one or more appropriate publications circulated to Cardiothoracic Surgeons and others nationally. GWUMC shall submit to the Department, in writing, a detailed explanation of its efforts to publish the presentations made at the Symposium no more than 60 days after the date on which the Symposium is completed. If the material has not been accepted for publication at the time of submission of such report to the Department, GW shall provide updates to the Department quarterly for a period of one year, or until publication, detailing its efforts to publish the materials.

Exhibit A

  1. GW shall comply with the provisions set forth in Exhibit A to this Agreement.

Progress Reports

  1. Except as may be inconsistent with the foregoing paragraphs, GW shall provide the Department with written progress reports setting forth in detail the progress made regarding each of the things Respondents are required to do in this Agreement. Such progress reports shall be provided on the first week of each month for a period of two (2) years from the effective date of this Agreement.

DHP

  1. DHP did not exist at the time of, and had no involvement in, the events giving rise to Complainant's allegations; however, DHP has since assumed ownership, and responsibility for, the operations of GWUH. DHP hereby agrees to obtain or make available to GWUH whatever resources are necessary for GWUH to comply with the terms of this Agreement and further agrees not to take any actions that would hinder performance of the terms of this Agreement by GW, GWUH, or GWUMC.

ACTIONS TO BE UNDERTAKEN BY THE DEPARTMENT

  1. The Attorney General is authorized, pursuant to Section 308(b)(1)(B) of the ADA, to bring a civil action enforcing the ADA in any situation where a pattern or practice of discrimination is believed to exist or a matter of general public importance is raised. In consideration of the terms of this Agreement as set forth above and upon execution of this Agreement, the Attorney General agrees to refrain from undertaking further investigation under the ADA or the Rehabilitation Act with regard to the allegations by Complainant referenced in Paragraph 2 of this Agreement, or from filing civil suit or taking any other legal action based upon the underlying complaint against GW, GWUMC, GWUH, or DHP or any of their agents or employees except as provided in this Agreement.

IMPLEMENTATION AND ENFORCEMENT OF THE AGREEMENT

Inclusive Agreement

  1. This Agreement and the exhibits attached hereto constitute the entire agreement between the parties on the matters raised herein, and no other statement, promise, or agreement, either written or oral, made by any of the parties or agents of any of the parties, that is not contained in this written Agreement, shall be enforceable. This agreement does not purport to resolve any other potential violations of the ADA, the Rehabilitation Act, or any other federal law other than those arising from the allegations of the Complainant referenced herein. This Agreement does not affect the continuing responsibility of the Respondents to comply with all aspects of the ADA, the Rehabilitation Act, and any other applicable laws. It also does not affect in any way the Department's ability to enforce any provision of the ADA or any other civil rights law with regard to the Respondents at any time except as specifically stated herein. No other contract or agreement that conflicts with the terms stated herein shall in any way limit this Agreement or any of its provisions.

Enforcement of the Agreement

  1. The Department may review compliance with the Agreement at any time. Except as provided in Paragraph 43, if the Department believes that this Agreement or any provision of it has been violated, the Department shall promptly advise the Respondents in writing of the nature of that violation, and, within fifteen (15) days of receipt by Respondents of said written notice from the Department, the Parties shall meet and confer in a good faith attempt to resolve the issue. In the event the Parties are not able to resolve this issue to the satisfaction of the Department, the Department may seek enforcement of the Agreement or any provision thereof in the United States District Court for the District of Columbia, pursuant to Paragraph 42 of this Agreement.
  2. In the event that the Department seeks enforcement of this Agreement or any provision of it the Parties agree:
    1. That the United States District Court for the District of Columbia has personal and subject matter jurisdiction over this Agreement, the matters set forth in it, and the Parties to it;
    2. That the United States District Court for the District of Columbia has the power to award whatever relief is required, at law and in equity, to enforce the terms of this Agreement, including the authority to order specific performance of any of the obligations that the Parties have assumed under the terms of the Agreement, and
    3. That, in the event the Court determines that Respondents, or any of them, have failed to comply with the Standard Practice, such breach shall be treated as a violation of Section 308(b)(2)(C)(ii) of the ADA, and any Respondents found responsible for the breach shall be liable for civil penalties in an amount to be determined by the Court; and in the event the Court determines that Respondents, or any of them, have failed to comply with any other provision of this Agreement, such breach shall be treated as a violation of Section 308(b)(2)(C)(i) of the ADA and any Respondents found responsible for the breach shall be liable for civil penalties in an amount to be determined by the Court.

Expedited Enforcement of the Agreement

  1. In the event that the Department believes that this Agreement has been or is about to be violated and the Department believes that such violation will result in imminent physical harm to a Patient or potential Patient at GWUH, the Department may expedite enforcement of the Agreement with regard to that individual by applying for appropriate injunctive and/or other relief, in the United States District Court without performing the prerequisite steps outlined in Paragraphs 41 and 42, except that the Department shall make reasonable efforts promptly to notify Respondents of any such perceived violations.

Failure to Enforce All Provisions of Agreement

  1. Failure by any Party to enforce this entire Agreement or any provision thereof with regard to any deadline or any other provision contained herein shall not be construed as a waiver of such Party's right to do so with regard to that or any other provision of the Agreement.

Bankruptcy

  1. If any provision of this Agreement is affected by any future proceeding in bankruptcy, the parties shall jointly apply to the Bankruptcy Court for withdrawal to the United States District Court for the District of Columbia for resolution of this matter. By signing this Agreement, the Respondents consent to this withdrawal.

Signed Counterparts of the Agreement

  1. This Agreement may be executed in several counterparts, each of which shall be deemed an original and shall constitute one and the same instrument. All exhibits hereto are hereby incorporated by specific reference into this Agreement, and their terms are made a part of this Agreement as though fully recited herein. All signed counterparts of the Agreement need not be present to enforce the terms of the Agreement.

Authorization of Signatories

  1. A signer of this document, in a representative capacity for a partnership, corporation, or other entity, including a governmental agency, represents that he or she is authorized to bind such partnership, corporation, or other entity or agency to the terms of this Agreement.

Notice to Parties

  1. In any instance where this Agreement requires that notice be given or progress reports provided to any or all of the Parties, such notice shall be provided in writing, sent via hand-delivery or certified or registered U.S. Mail, return receipt requested, to the following individual[s] in their capacities as representatives of the Parties to this Agreement:

GW and GWUMC:

Dr. John F. Williams
Vice President for Health Affairs & Executive Dean
The George Washington University
Room 713, Ross Hall
2300 Eye Street, NW
Washington, D.C. 20052

with a copy to:

Jennifer L.W. Korjus, Esq.
Medical Center Legal Counsel
Vice President & General Counsel
The George Washington University
2100 Pennsylvania Avenue, NW, Suite 690
Washington, D.C. 20052

DHP and GWUH:

Phillip S. Schaengold
Chief Executive Officer
District Hospital Partners, L.P.
T/A The George Washington University Hospital
901 23rd Street, Suite 2500 North
Washington, D.C. 20037

with a copy to:

Bruce R. Gilbert, Esq.
General Counsel
Universal Health Services, Inc.
367 South Gulph Road
P.O. Box 61558
King of Prussia, PA 19406

The Department:

John L. Wodatch, Section Chief
Disability Rights Section
Civil Rights Division
U.S. Department of Justice
P.O. Box 66738
Washington, D.C. 20035-6738

Successors in Interest

  1. This Agreement shall be binding on the Respondents, their parents, controlled affiliates, agents, and subsidiaries, and all of their successors in interest. Each Respondent has a duty to notify all such successors in interest, if any, of these obligations and to include in all relevant future documents transferring any right or interest in them or the facilities subject to this Agreement, notice of the obligations to comply with this Agreement.

Disclosure of Agreement and Exhibit

  1. Except for Exhibit A, this Agreement is a public document. A copy of this document or any information contained herein but not contained in Exhibit A, may be made available to any person. The Department shall provide a copy of this Agreement, exclusive of Exhibit A, to any person on request.
  2. Exhibit A will be released by the Department only as required by the Freedom of Information Act or judicial order.

Effective Date

  1. The effective date of this Agreement is the date of the last signature below. This Agreement shall remain in effect for five (5) years from the effective date.

UNITED STATES OF AMERICA

BILL LANN LEE
Acting Assistant Attorney General

_____________________________      Date:____________



_____________________________      Date:____________
JOHN L. WODATCH, Section Chief
RENEE M. WOHLENHAUS,
Acting Deputy Section Chief
JOSEPH C. RUSSO
D.C. Bar No. 432249
JEANINE M. WORDEN
D.C. Bar No. 420177
Trial Attorneys
Disability Rights Section
Civil Rights Division
U.S. Department of Justice
P.O. Box 66738
Washington, D.C. 20035-6738
(202) 307-0663

THE GEORGE WASHINGTON UNIVERSITY

By:_____________________________      Date:____________
   JOHN F. WILLIAMS, M.D., ED.D.
   Vice President for Health Affairs


BY:_____________________________      Date:____________
   LOUIS H. KATZ
   Vice President and Treasurer

THE GEORGE WASHINGTON UNIVERSITY
MEDICAL CENTER
, an unincorporated division
of The George Washington University

By:_____________________________      Date:____________
   JOHN F. WILLIAMS, M.D., ED.D.
   Vice President for Health Affairs


BY:_____________________________      Date:____________
   LOUIS H. KATZ
   Vice President and Treasurer

DISTRICT HOSPITAL PARTNERS, L.P.
T/A THE GEORGE WASHINGTON
UNIVERSITY HOSPITAL

By:_____________________________      Date:____________
   PHILLIP S. SCHAENGOLD
   Chief Executive Officer
   District Hospital Partners, L.P.
   T/A The George Washington University Hospital
   901 23rd Street, Suite 2500 North
   Washington, D.C. 20037

THE GEORGE WASHINGTON UNIVERSITY
HOSPITAL

By:_____________________________      Date:____________
   PHILLIP S. SCHAENGOLD
   Chief Executive Officer
   District Hospital Partners, L.P.
   T/A The George Washington University Hospital
   901 23rd Street, Suite 2500 North
   Washington, D.C. 20037

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Updated August 6, 2015

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