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HCA has developed compliance monitoring and auditing programs designed to assess the effectiveness of the Ethics and Compliance Program.

Monitoring systems are designed to be incorporated into day-to-day processes. Auditing efforts typically use a retrospective approach. The Company's Responsible Executives develop monitoring programs and the Internal Audit Department develops compliance audit plans and conducts audits.

In addition to the auditing efforts, the Program Assessment team of the Ethics and Compliance Department conducts on-site Compliance Process Reviews. A random sample of HCA facilities is selected each year to undergo a review of each facility's Ethics and Compliance Program to ensure the appropriate processes and procedures are in place and that these processes and procedures are providing the desired results. From a facility perspective, the review provides the Ethics and Compliance Officer ("ECO") with valuable guidance to assist in strengthening process controls and improving the overall performance of the facility's program. From a Company perspective, the reviews allow for the gathering of large volumes of Ethics and Compliance Program data collected from multiple facilities throughout the Company. The analysis of this data assists in identifying both trends and opportunities for improvement to our Company-wide ethics and compliance efforts.