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- The Rowan University Voluntary Compliance Plan effective September 26, 2014.
- The Medicare and Medicaid Patient Protection Act of 1987, as amended, 42 U.S.C. §1320a- 7b (the "Anti-kickback Statute"),
- Stark Law, 42 CFR §§ 411.350 – 411.389.
- New Jersey's Conscientious Employee Protection Act (N.J.S.A. 34.19-1 et seq., ., also known as the "Whistleblower Act").
- Sarbanes-Oxley not only prohibits retaliating against whistleblowers (SOX section 806), it also affirmatively requires companies to set up hotlines or other "procedures" for the "confidential, anonymous submission of employee complaints and concerns" about audit/accounting fraud (SOX section 301).
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Reporting Policy Violations & Crime
Employees, students employed by the university and even contractors occasionally violate university policy or even commit crimes. Unfortunately, there are times when these behaviors go unreported because people fear reprisal or retribution from those who are committing the acts.
Rowan University prohibits retaliation, harassment, intimidation or discrimination against any individual who makes a good faith report of suspected wrongdoing. If something seems wrong, it may be, so employees are encouraged to report it.
Reporting compliance and ethics concerns
As always, report immediate threats or danger by calling 911. Other University contacts include:
University Ethics Liaison Officer (ELO), established under Executive Order 24 (Christie). The University's ELO is Robert Zazzali who is located on the Glassboro Campus at Bole Hall. He can be reached at 856-256-4110. The Deputy ELO is Ray Braeunig who is located on the Stratford Campus in the University Education Center (UEC-1034). He can be reached at 856-566-6136.
University Chief Audit, Compliance & Privacy Officer, Ray Braeunig. As Compliance Officer, he is obligated by law to report any violations of any Federal Health Care program requirements or of Rowan's own Policies & Procedures to the Office of Inspector General (OIG). While his Compliance duties relate primarily to Federal Health Care program requirements, his duties as Privacy Officer extend across all campuses.
University Equity and Diversity Office, Frankie Lucas is the Title IX/EEO Investigator and Acting Title IX Coordinator and can be reached at the located at the Glassboro Campus in Linden Hall. She can be reached at , 856-256-5831. The Office of Equity and Diversity oversees compliance with policies that include but are not limited to: The NJ Policy Prohibiting Discrimination in the Workplace, Americans with Disabilities Act, Title IX Compliance, Rowan University Workplace Violence Policy, and EEO Compliant Search Practices..
The obligations and authority of these offices overlap in some measure, but their jurisdictions and authority are different. Calls to them are confidential, and they will direct you to the right area based on the issue or registered concern.
The university also maintains a confidential hotline. It is the Rowan University Integrity Hotline; available 24 hours a day/7days a week, via a toll free phone number, 1 855-431-9967, and via a website: http://rowan.edu/integrityline.
The schools, departments and units that are a part of Rowan University have established, and shall continue to maintain, effective and confidential means for individuals to report allegations or concerns that include actual or suspected violations of law, violations of Rowan University policies or procedures, or any other type of wrongful conduct. Individuals will be permitted to make such reports anonymously if they so desire, and their anonymity will be protected to the extent possible and as permitted by law.
To make a report, individuals may contact their direct manager or other members of their management team. In addition, individuals may call the units Compliance Office, General Counsel; Ethics Liaison Officers; or they may call the Rowan University Integrity Line.
Integrity hotline: 855-431-9967
New in 2014, Rowan has created a phone hotline for those who want to report issues confidentially (to the extent possible) to an outside agency. The hotline, (855) 431-9967, is managed by Global Compliance, an independent organization that provides a secure and confidential means to file a report 24 hours a day, seven days a week. The system accommodates callers in 150 languages as well as callers with special needs.
Global Compliance logs each and every report. Whether you use the Integrity Hotline Phone number or website the Rowan University-Integrity Hotline allows you to report issues and concerns you may have (regarding but not limited to), unethical behavior, inappropriate conduct, bullying, harassment, and any other violation to Rowan University policies. This reporting process is secure and confidential. The organization prioritizes the speed with which reports must be addressed as follows:
Priority A – Immediate
Priority B – Moderate
Priority C – StandardA committee of two University employees reviews each and every report. Should they believe the report involves factors that require greater perspective and independence they have access to outside investigators.
Visit www.rowan.edu/compliance to learn more about Rowan's policy on Reporting Compliance and Ethics Concerns, the protection afforded to employees who report violations and rights of individuals accused of wrongdoing.
Protection from reprisal or retaliation
Rowan University policy prohibits retaliation, harassment, intimidation or discrimination against individuals who make good faith reports of suspected wrongdoing. Any employee found to have retaliated against anyone who has made a good faith report shall be subject to appropriate disciplinary action up to and including termination of employment. Good faith reports that are not substantiated are protected under this policy.
Complaints made in bad faith using falsified information is contrary to the intent and spirit of this policy, and may subject the reporter to disciplinary action up to and including termination.
To make reports of immediate threats or danger, call 911. The Rowan University Alert Line should not be used for emergencies. There are other reporting methods for concerns which are summarized in Attachment 2.
Retaliation & Whistleblower Protection
Reporting and Investigating Retaliation Allegations:
Reporting: Anyone who has provided information who believes he or she is the subject of retaliation should report the facts supporting the allegations of retaliation to the Chief Compliance Officer; Assistant Vice President Equity and Diversity; General Counsel, Ethics Liaison Officers (ELO) or the Alert Line.
All investigations of alleged retaliation will be conducted as sensitively and expeditiously as possible. Due consideration will be given to existing grievance procedures under applicable collective bargaining agreements.
Should an investigation lead the appropriate Rowan University authority to conclude that retaliation has been substantiated; the individual(s) responsible for committing the retaliation, in addition to any civil or criminal proceedings, shall be subject to disciplinary action up to and including termination.
In accordance with New Jersey's Conscientious Employee Protection Act (N.J.S.A. 34.19-1 et seq., also known as the "Whistleblower Act"), Rowan University shall take no retaliatory action against an employee as identified in Attachment 1.
The Conscientious Employee Protection Act Annual Notice is Attachment 1.
Sanctions
Failure to comply with this policy may result in sanctions up to, and including, termination of employment or termination of a contractor's agreement.
Communications
As Rowan University grows it is important to have process in place to ensure concerns are addressed in a timely and a efficient basis. Effective communication is necessary for a University to swiftly communicate information to personal that are a part of Rowan University to report Non-compliant activities. The document below provides a mechanism for anonymous and confidential reporting without any form of retaliation. It also provides a wide array of direction for all Rowan personal to address concerns. Please read and keep this information available to you.
Notices: Posters will be placed in each Human Resource site for each Rowan University unit/school. See below Attachment 1 – Annual Notice.
Email: An email will be sent in the second week of the fall, spring and summer terms of each year to all faculty, staff, students employed by the university and Trustees.
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- New Jersey law prohibits an employer from taking any retaliatory action against an employee because the employee does any of the following:
- Discloses, or threatens to disclose, to a supervisor or to a public body an activity, policy or practice of the employer or another employer, with whom there is a business relationship, that the employee reasonably believes is in violation of a law, or a rule or regulation issued under the law, or, in the case of an employee who is a licensed or certified health care professional, reasonably believes constitutes improper quality of patient care;
- Provides information to, or testifies before, any public body conducting an investigation, hearing or inquiry into any violation of law, or a rule or regulation issued under the law by the employer or another employer, with whom there is a business relationship, or, in the case of an employee who is a licensed or certified health care professional, provides information to, or testifies before, any public body conducting an investigation, hearing or inquiry into quality of patient care; or
- Provides information involving deception of or misrepresentation to, any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity.
- Provides information regarding any perceived criminal or fraudulent activity, policy or practice of deception or misrepresentation which the employee reasonably believes may defraud any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity.
- Objects to, or refuses to participate in, any activity, policy or practice which the employee reasonably believes:
- is in violation of a law, or a rule or regulation issued under the law or, if the employee is a licensed or certified health care professional, constitutes improper quality of patient care;
- is fraudulent or criminal; or
- is incompatible with a clear mandate of public policy concerning the public health, safety or welfare or protection of the environment. N.J.S.A. 34:19-3.
- The protection against retaliation, when a disclosure is made to a public body, does not apply unless the employee has brought the activity, policy or practice to the attention of a supervisor of the employee by written notice and given the employer a reasonable opportunity to correct the activity, policy or practice. However, disclosure is not required where the employee reasonably believes that the activity, policy or practice is known to one or more supervisors of the employer or where the employee fears physical harm as a result of the disclosure, provided that the situation is emergency in nature.
CONTACT INFORMATION
The following contact persons at Rowan University have been designated to answer your questions or provide information regarding your rights and responsibilities under the Whistleblower Act (N.J.S.A. 34:19-4):
*Name: Robert Zazzalli
Address: Bole Hall
Telephone Number: (856) 256-4110
Or
*Name: Rowan University Integrity Line
Telephone Number: 1-855-431-9967
Website Access: http://rowan.edu/integritylineyintegrityline.
This notice must be conspicuously displayed.
Once each year, employers must distribute notice of this law to their employees.
If you need this document in a language other than English
or Spanish, please call (609) 292-7832.
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- New Jersey law (NJSA 9:6-8.10) requires all persons who have reasonable cause to believe that a minor has been subject to abuse or neglect to report it to the New Jersey Division of Child Protection and Permanency, formerly the Division of Youth and Family Services (DYFS) at 1-877-NJABUSE (1-877-652- 2873).
- Anyone who suspects that a minor has been subject to abuse or neglect must immediately notify the Rowan University Police Department (RUPD) at 856-757-7777.
- Website Page – www.rowan.edu/compliance
- Protection of Minors Policy - http://www.rowan.edu/studentaffairs/reslife/documents/RowanUniversityStudentHandbook2013-2014.pdf
Accident/Injury
- In an Emergency, call 911
- Job-related injury reporting- http://www.rowan.edu/hr/pension/workerscomp.html
- Injury Reporting Form for Student or the Public - http://www.rowan.edu/open/studentaffairs2/healthcenter/confidentiality.html
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