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A. Corporate Integrity Agreement between the Office of Inspector General of the Department of Health and Human Services and the University of Medicine and Dentistry of New Jersey, September 25, 2009 to September 25, 2014, as amended by a Letter Agreement, UMDNJ-RowanSOM dated 5/1/2013.
B. The Medicare and Medicaid Patient Protection Act of 1987, as amended, 42 U.S.C. §1320a- 7b (the "Anti-kickback Statute"),
C. Stark Law, 42 CFR §§ 411.350 – 411.389
D. New Jersey's Conscientious Employee Protection Act (N.J.S.A. 34.19-1 et seq., also known as the "Whistleblower Act")
E. Sarbanes-Oxley Sarbanes-Oxley not only prohibits retaliating against whistle blowers (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).
V. The Policy
A. Reporting Policy Violations & Crime
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