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1. Log into the MediTract system using your designated username and password.
2. Upload the contractual agreement and proceed to answer the seven compliance questions located in the compliance tab on the MediTract System cover page.
3. If the contractual agreement has been determined to be a Focused Arrangement, make sure the focused arrangement contains a certification by each party stating that each party will not violate the Anti-Kickback Statue of the Stark Law with respect to performance of the focused arrangement.
4. Review of the following key items is essential when assessing the contract:
   
   • Is this contract completed?
   • Does it contain FMV documentation? Procedure to follow located at link below:
     http://www.rowan.edu/compliance/policies/documents/FocusedArrangementProtocolEstablished.pdf
   • Is it signed by both parties?
   • If this contract is considered a focus arrangement contract, and the contract is expired, determine whether we are still providing services.
     
     1. If still providing services then this contract needs to be amended, consult legal management.
     2. If we are not providing services, archive the contract according to NJ State Record Retention Policy. (Refer to State of New Jersey General Record Retention Schedule; State of New Jersey Four Year College Record Retention Schedule; State of New Jersey Health Care Facilities Retention Schedule).
5. The Office of Legal Management Attorneys will be notified by System Administrator that contracts are ready to be viewed. Attorneys will:
   
   • Review designated contracts located in RowanSOM Focused Arrangement Database.
     
     1. Legal Counsel Review to include:
        1. The names of the parties to the agreement
        2. The type of Focus Arrangement
        3. The effective and expiration dates and any automatic renewal provisions or amendments
        4. The amount and means by which the compensation is paid
        5. Were applicable, that the FMV statement is attached to the agreement in the Focus Arrangement Database (FAD)
        6. A statement that the amount of compensation to be paid pursuant to the written terms of the Focus Arrangement has not been determined based on the volume or value of referrals between the parties
        7. The Focus Arrangement satisfies all requirements of the VCP
   • Generate emails via MediTract to the responsible party (team member) when contract is incomplete and missing the disclosed “key items” referred to in #4 above.
   • Be requesting responsible party (team member) to locate or correct the current state of the contract.
   • Note general emails, if contract is fully executed. The review of the contract is complete and the contract remains in the Focus Arrangement Database.
6. Upon receiving the email from Legal Counsel, the responsible party (team member) must work expeditiously to bring current any and all parts of the contract, which the attorney will request via email. This entails contract clean-up and the following steps must be performed:
    
   • Ensure fully executed contract with all parties signatures are located in the system as a replacement contract, not a new document.
   • Ensure this is an FMV related to the contract.
   • Ensure FMV is attached to MediTract as an attachment, and not within the contents of the contract.
   • Any other requirements specified by the reviewing attorney.
7. Steps four through six should be performed on a continuous basis until all contracts have been updated and to secure the integrity of the database. Schools/units should develop an internal process to ensure all contractual agreements and focused arrangements contain the most current information
   
   • Service and Activity Logs
     
     1. Service and activity logs must be completed properly and reviewed by Department Heads or Administrators for completeness and accuracy.
     2. Department Administrators will check to ensure all signatures, required contractual provisions and certifications have been compiled before services are provided. Department Administrators will sign and date document to ensure services are not rendered prior to the start date of the contract.
   • Quarterly Audits
     • As part of the ongoing quarterly FAD review, Compliance will audit quarterly all new contracts to ensure that no services begin prior to effective dates of contracts.
   • Annual audits
     • To ensure compliance with the Anti-Kickback Statute/Stark Statues and the VCP, annual audits will be conducted. Tests via random selection to be done (ensure leases are included) for the three key indicators {1. Invoice; 2. Time & Effort Reporting; 3. Payments}, verifying that service and activity logs are properly completed and remuneration is properly tracked. The Chief Compliance & Privacy Officer is the responsible party for conducting the annual sample reviews for time & effort reporting and remuneration tracking.

H. Leased Space
Usage of leased space shall be monitored quarterly and memorialized on logs, as appropriate, to ensure that usage is restricted as set forth in the contract. Under the guidance of the Administrators, front desk personnel will maintain logs monitoring and tracking usage.

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