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- When there are suspected violations of the Anti-kickback statue and Stark law violations that potentially implicate the Anti-kickback statute and
- To possibly mitigate potential exposure under section 1128J(d) of the Act, 42 U.S.C. 1320a-7k(d). Section 1128J(d)(2) of the Act requires that a Medicare or Medicaid overpayment be reported and returned by the later of (1) the date that is 60 days after the date on which the overpayment was identified or (2) the date any corresponding cost report is due, if applicable. Any overpayment retained by a "person," as defined in section 1128J(d)(4)(C) of the Act after this deadline may create liability under the Civil Monetary Penalties Law (CMPL), section 1128A of the Act, and the False Claims Act (FCA), 31 U.S.C. 3729.Penalties Law (CMPL), section 1128A of the Act, and the False Claims Act (FCA), 31 U.S.C. 3729. [i]
II. ACCOUNTABILITY
Under the direction of the President, the Dean, General Counsel and the Chief Compliance and Privacy Officer shall ensure compliance with this policy. Schools, departments and units that are a part of Rowan School of Osteopathic Medicine (RowanSOM) that bill federal or state programs for healthcare goods or services ("Related Healthcare Entity" or "Related Healthcare Entities") shall, when appropriate, consider use of the HHS Office of the Inspector General Self-Disclosure Protocol for reporting to the OIG suspected violations of the federal Anti-kickback statute as set forth in this policy.
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