ROWAN UNIVERSITY POLICY
Title: Excluded Individuals & Entities
Subject: Office of Compliance & Corporate Integrity (OCCI)
Policy No: OCCI: 2013: C07
Applies: RowanSOM
Issuing Authority: Rowan President & RowanSOM Dean
Responsible Authority: RowanSOM Chief Compliance and Privacy Officer
Adopted:
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11/19
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/1999
Reviewed:
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01/18
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/2012
Amended:
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07/01/2013
Last Reviewed:
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12/30
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/2014
I. PURPOSE
To establish a policy governing the Rowan School of Osteopathic Medicine (RowanSOM) employment of and entering into contracts with, individuals or entities who are currently excluded by the Office of Inspector General (OIG) , the General Service Administration (GSA), or the New Jersey Office of the Medicaid Inspector General from participation in Federal health care programs.
II. ACCOUNTABILITY
Under the direction of the President, the Dean, General Counsel, and Chief Compliance and Privacy Officer, shall ensure compliance with this policy. The Department Chairs/Directors in each School and all other RowanSOM Units shall implement this policy.
III. APPLICABILITY
This policy applies to all RowanSOM employees and all individuals/entities entering into a contract with RowanSOM.
IV. POLICY
In accordance with Federal law, RowanSOM will not employ or enter into contracts with any individual or entity which is currently excluded by the Office of Inspector General (OIG) and/or the General Service Administration (GSA), and/or from the New Jersey Medicaid Inspector General, (NJOMIG) disqualified/debarred provider list from participation in Federal health care programs.
V. ATTACHMENT
A. Procedures to Determine Excluded Individuals & Entities
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RowanSOM Chief Compliance and Privacy Officer
ATTACHMENT 1
PROCEDURES TO DETERMINE EXCLUDED INDIVIDUALS & ENTITIES
A. Prior to hiring an individual, entering into contracts with any individual or entity, or extending clinical privileges at RowanSOM, the Department of Human Resources must verify that the individual or entity does not appear on the OIG or GSA listing of excluded parties, and that the individual or entity does not appear on the NJOMIG disqualified/debarred provider list.
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