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B. After the initial disclosure to the OIG, RowanSOM will conduct an internal investigation and a self-assessment of the financial impact of the suspected violation(s) and report the findings to the OIG as directed by the University’s Voluntary Compliance Plan (VCP) effective 9/26/2014 and refund applicable claims per RowanSOM policy.
- If at any time RowanSOM identifies or learns of any overpayment, RowanSOM shall notify the payor (Medicare/Medicaid) within 30 days after identification of the overpayment and take remedial steps within 60 days after identification to refund monies.
C. RowanSOM will also submit to the OIG a work plan describing RowanSOM's self- assessment process, and a Disclosure Report addressing the nature and scope of the non-compliance and why RowanSOM believes there is a potential violation.
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