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Title: Responding to Suspected Violations of the Anti-Kickback Statute or for Stark Law Violations that Potentially Implicate the Anti-Kickback Statute
Subject: Office of Compliance & Corporate Integrity (OCCI)
Policy No: OCCI: 2013: C08
Applies: RowanSOM
Issuing Authority: Rowan President & RowanSOM Dean
Responsible Authority: RowanSOM Chief Compliance & Privacy Officer & General Counsel
Adopted: Jan 24, 2013
Amended: July 1, 2013
Reviewed: Jan 67, 2015
I. PURPOSE
To ensure that when considering "self-disclosure", schools, departments and units that are a part of RowanSOM that bill federal or state programs for patient goods or services ("Related Healthcare Entity" or "Related Healthcare Entities") follow the recommendations of the Office of Inspector General in the OIG's Self Disclosure Protocol:
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