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This policy supplements and amends the RowanSOM policy, Reporting Compliance and Ethics Concerns, and those sections of the RowanSOM Compliance Plan that relate to the detection and prevention of fraud, waste and abuse in the implementation of federal and state healthcare programs and protection for those who report actual or suspected wrongdoing as well as sanctions for those who forward false information.

 The provisions of this policy are also intended to satisfy the requirements of the Deficit Reduction Act of 2005 (DRA), particularly Section 6032, by providing information about federal and state laws relating to liability for false claims and statements.

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