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Although this policy is written so as to provide guidance for executing Professional Services Agreements in which RowanSOM Professionals are providing health care-related services to a Provider (see, for example, Section V. Procedure, Paragraph 3: “ RowanSOM Professionals shall provide the Provider with a written statement or other documentation substantiating the services that have been rendered prior to each payment.”), this policy should be and is intended to be construed to apply also when the Provider is providing health care-related services to RowanSOM. In such cases, the guidelines set forth in this policy shall apply equally to a Provider.


  1. Professional Services Agreements – any arrangement under which services, including but not limited to clinical or administrative services are provided by a Provider (as defined below) to another entity.
  2. 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.
  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. Focus Arrangement as defined in the Voluntary Compliance Plan (VCP) - 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 Rowan SOM and a physician (or a physician’s immediate family member (as defined at 42 C.R.F. 411.351) who makes a referral (as defined at 42 C.F.R. 1395nn(h)(5)) to RowanSOM for designated health services (as defined at 42 U.S.C. 1395nn(h)(6)).
  5. 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 C.R.F. 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.
  6. Provider - providers of health care services or business including, but not limited to, facilities and other entities and individuals with whom RowanSOM Professionals may enter into agreements to provide goods and services.
  7. Designated Health Services - (1) Inpatient and outpatient hospital services, (2) Clinical laboratory services, (3) Radiology and certain other imaging services, including X-ray, MRI, CT, Ultrasound, Nuclear Medicine (including PET), and Bone densitometry, (4) Radiation Therapy services and supplies, (5) Durable medical equipment and supplies, (6) Parenteral and enteral nutrients, equipment and supplies, (7) Prosthetics, orthotics and prosthetic devices and supplies, (8) Home health services and supplies, (9) Outpatient prescription drugs, (10) Physical therapy, occupational therapy and speech-language pathology services.