ROWAN UNIVERSITY POLICY
Title: Focused Arrangement Database Policy & Approval Process
Subject: Office of Compliance & Corporate Integrity (OCCI)
Policy No: OCCI: 2013: C03
Applies: RowanSOM
Issuing Authority: Rowan President & RowanSOM Dean
Responsible Authority: RowanSOM Chief Compliance and Privacy Officer
Adopted:
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05/12
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/2009
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Reviewed:
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07/02/2012
Amended:
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07/01/2013
Last Reviewed:
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12/30
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/2014
I.
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PURPOSE
A. To set forth the general guidelines for the submission, approval and administration of all contractual agreements entered into by Rowan University School of Medicine (RowanSOM) which constitute Focus Arrangement (as defined below) under the terms of the Corporate Integrity Agreement ("CIA") dated September 25, 2009 between UMDNJ and the Office of Inspector General of the Department of Health and Human Services.
B. To establish procedures to activate and maintain a Focus Arrangements database through Rowan SOM electronic contract management system.
II.
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ACCOUNTABILITY
Under the direction of the President, the Dean, General Counsel and the Chief Compliance and Privacy Officer are to ensure compliance with this policy and the terms of the CIA. The deans, department chairs and chief executive officers shall implement this policy.
III.
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APPLICABILITY
This policy applies to all RowanSOM operating units, including but not limited to hospitals, physician practices, and outpatient centers.
IV.
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DEFINITIONS
A. "Arrangements" - every arrangement or transaction that:
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E. "Database or Contract Management System" - is the electronic contract management system, authorized by the Senior Vice President and General Counsel to process, execute, and store all arrangements and focused arrangements entered into on behalf of RowanSOM.
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V.
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REFERENCES
A. 42 U.S.C. § 1320a-7b; 42 C.F.R. § 1001.952(a)-(v); 42 U.S.C. § 1395nn; 42 C. F. R. § 411.350 et. seq.;
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C.66 Fed. Reg. 856 (Jan. 4 2001); 69 Fed. Reg. 16054 (March 26, 2004); Corporate Integrity Agreement Between the Office of Inspector General of the Department of Health and Human Services and the University of Medicine and Dentistry of New Jersey, September 25, 2009.
D. Contract Management
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VI.
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POLICY
A. All Focus Arrangements shall be compliant with the requirements of the CIA. All Focus Arrangements must be reviewed and approved by the applicable dean, chief executive officer and RowanSOM legal counsel prior to execution, and stored in the Focus Arrangement section of RowanSOM electronic contract management system after execution, in accordance with this policy.
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