Page History

...

Under the direction of the President, the Dean, General Counsel and the Chief Compliance & Privacy Officer shall ensure compliance with this policy. This policy applies to and should be read by employees of schools, departments and units that are a part of RowanSOM as well as employees of other departments that bill federal or state programs for healthcare goods or services (“Related Healthcare Entity” or “Related Healthcare Entities.”). Employees of other University departments that support the Related Healthcare Entities in contracting for goods and services, including but not limited to Finance, University Procurement and the Office of the Senior Vice President and General Counsel, should also read this policy.

III. APPLICABILITY

RowanSOM units and departments that bill federal or state programs for healthcare goods or services (“Related Healthcare Entity” or “Related Healthcare Entities”) shall, when appropriate, follow the CMS Voluntary Self-Referral Disclosure Protocol (SRDP) for reporting to CMS suspected violations of the federal Stark law as set forth in this policy.

IV. RELATED DOCUMENTS

1. Rowan University Voluntary Compliance Plan (VCP) effective September 26, 2014
2. CMS Voluntary Self-Referral Disclosure Protocol https://www.cms.gov/Medicare/Fraud-and-Abuse/PhysicianSelfReferral/Downloads/6409_SRDP_Protocol.pdf OMB CONTROL NUMBER: 0938-1106
3. The Medicare and Medicaid Patient Protection Act of 1987, as amended, 42 U.S.C. §1320a-7b (the "Anti-kickback Statute"),
4. Stark Exceptions, 42 CFR §§ 411.350 – 411.389
5. Stark Law Section 1877 of the Social Security Act 42 U.S.C. 1395
6. Patient Protection and Affordable Care Act (the Affordable Care Act) (Publ. L. 111-148) F
7. Focus Arrangement Database
8. General Statement on Agreements with Referral Sources
9. Fair Market Valuation
10. Professional Services Policy
11. Contracts & Purchasing Policy
12. State College Contracts Law N.J.S.A. 18A:64 and N.J.S.A. 18A-64-65
13. Engagement and Payment of Professional Services Provider Policy
14. Rowan University Code of Conduct
15. State Uniform Ethics Code

...

V. POLICY

As recommended by CMS, once it is determined by RowanSOM that an alleged violation of the Stark Law has occurred and it wishes to report this alleged violation under the SRDP, the RowanSOM Chief Compliance & Privacy Officer, as the designated responsible party to ensure self-disclosure, shall obtain and report the following information to CMS:

...