ROWAN UNIVERSITY POLICY

Title:  Fair Market Valuation
Subject: Office of Compliance & Corporate Integrity (OCCI)
Policy No: OCCI:2013:C06
Applies: RowanSOM
Issuing Authority: Rowan President & RowanSOM Dean
Responsible Officer: Chief Audit, Compliance & Privacy Officer
Date Adopted: 07/13/2020
Last Revision: 7 04/01/20132020
Last Reviewed: 04/01/2020

I.    PURPOSE

To provide guidance as to Rowan University School of Osteopathic Medicine’s (RowanSOM) process of determining whether a transaction with a Potential Referral Source (as defined below) is made at fair market value in order to comply with Stark Law (42 U.S.C. § 1395nn ) and the Anti-kickback Statute (42 U.S.C. § 1320(a)-7b(b)).

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1. Referral Source - an actual source of health care business or referrals to RowanSOM, or between RowanSOM and a physician (or a physician’s immediate family member (as defined at 42 CFR. 411.351) - include, but are not limited to, another Physician, hospitals, long-term acute care centers, nursing homes, clinics, physician group practices, therapists and other individuals and entities who are in a position to influence or make referrals.
2. Focus Arrangement - every arrangement that involves, directly or indirectly, the offer or payment of anything of value and is between RowanSOM and any actual source of health care business or referrals to RowanSOM, or is between RowanSOM and a physician (or a physician’s immediate family member (as defined at 42 CFR 411.351) who makes a referral (as defined at 42 CFR. 1395nn(h)(5)) to RowanSOM for designated health services (as defined at 42 U.S.C. 1395nn(h)(6)). 
3. Immediate Family Member - husband or wife; birth or adoptive parent, child or sibling; stepparent, stepchild, stepsibling; father-in-law, mother-in-law, son-in-law, daughter-in-law, brother-in-law or sister in-law; grandparent or grandchild; spouse of grandparent or grandchild.
4. Physician - a doctor of medicine or osteopathy, a doctor of dental medicine or dental surgery, a doctor of podiatric medicine, a doctor of optometry, or a chiropractor.
5. Potential Referral Sources - physicians, hospitals, long-term acute care centers, nursing homes, clinics, physician group practices, therapists and other individuals and entities who are in a position to influence referrals.

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