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Title: General Statement on Agreements with Referral Sources
Subject: Office of Compliance & Corporate Integrity (OCCI)
Policy No: OCCI: 2013: C04
Applies: RowanSOM
Issuing Authority: Rowan President & RowanSOM Dean
Responsible Authority: RowanSOM Chief Compliance and Privacy Officer
Adopted: 12/ Dec 15/, 2009.
Reviewed: July 2, 2012
Amended: July 1, 2013
Last Reviewed: Jan 6, 2015


C. The Office Compliance and Corporate Integrity will educate responsible parties on the laws, regulations and policies applicable to Subject Agreements with Potential Referral Sources, will monitor and review such Subject Agreements, will ensure that fair market value documentation attached to Subject Agreements reflects fair market value for the services rendered and will assist the responsible dean or chief executive officer with remediating such Subject Agreements when potential violations of Section VI of this policy are detected.

D. Execution Timing: The Subject Agreement must be fully executed before any services are provided and before payment is made or received.

 E. Compliance with Subject Agreement terms: In all arrangements with Potential Referral Sources, payments must be consistent with the terms of the Subject Agreement and performance of all of the terms of the Subject Agreement is required. For example, monies owed by a physician under a lease agreement must be paid in accordance with the terms of the documents. Accurate and complete records of all time and effort must be maintained by the facility, clinical unit or department. The RowanSOM Operating Unit must accurately track remuneration paid or received pursuant to an agreement. The Office Compliance and Corporate Integrity is responsible for conducting annual probe sample reviews for time and effort reporting and remuneration tracking.