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ROWAN UNIVERSITY POLICY


Title:  Fair Market Valuation
Subject: Office of Compliance & Corporate Integrity (OCCI)
Policy No: OCCI:2013:

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C10
Applies: RowanSOM
Issuing Authority: Rowan President & RowanSOM Dean
Responsible Officer: Chief Audit, Compliance & Privacy Officer
Date Adopted: 07/13/2020
Last Revision: 04/01/2020
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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