ROWAN UNIVERSITY POLICY

Title: Fraud, Waste & Abuse Protection & Federal Deficit Reduction Act of 2005
Subject: Office of Compliance & Corporate Integrity (OCCI)
Policy No: OCCI: 2013: C02
Applies: RowanSOM
Issuing Authority: Rowan President & RowanSOM Dean
Responsible Executive(s): RowanSOM Chief Compliance and Privacy Officer
Adopted: 07/21/2009
Amended: 07/01/2013
Reviewed: 01/05/2015

I. PURPOSE

This policy provides guidance to RowanSOM and other RowanSOM units and departments that bill federal or state programs for healthcare-related goods or services ("Related Healthcare Entity" or "Related Healthcare Entities") and independent contractors who may be engaged by the Related Healthcare Entity as to the requirements of the Federal Deficit Reduction Act of 2005 and fraud, waste and abuse protections contained in various state and federal laws and regulations.

II. ACCOUNTABILITY

Under the direction of the President, the Sr. Vice President for Healthcare, the Sr. Vice President and CFO, General Counsel, Dean, Associate Deans, Department Chairs, Chief Compliance and Privacy Officer, Vice President for Research, Executive Director, and the Information Security Officer shall implement and ensure compliance with this policy.

III. APPLICABILITY

This policy applies to all employees, contractors or agents of RowanSOM, its departments and units, and employees of RowanSOM departments that support the Related Healthcare Entities in their operations, including but not limited to University Procurement Services, the Office of the General Counsel, and University Finance.

IV. REFERENCES

A. Rowan University Policy - Reporting Compliance and Ethics Concerns Rowan University Policy - Reporting Compliance and Ethics Concerns^[i]

B. Fraud, Waste and Abuse Protection and the Federal Deficit Reduction Act of 2005 Summaries of Federal and State Laws as Required By Section 6032 of the Deficit Reduction Act^[ii]

C. Federal Civil False Claims Act (31 U.S.C. §3729 et seq.)^[iii]

D. The New Jersey Medical Assistance and Health Services Act (NJSA 30:4D-17(1)-(d)) ^[iv]

E. MAHA (NJSA 30:4D-17(e) - (i)) ^[v]

F. The New Jersey Health Care Claims Fraud Act (NJSA 2C:21-4.2 and 4.3; NJSA 2C:51-5) ^[vi]

G. The New Jersey False Claims Act The New Jersey False Claims Act ^[vii]

H. The New Jersey Conscientious Employee Protection Act (NJSA 34:19-1 et seq.) ^[viii]

V. POLICY

A. This policy provides guidance to RowanSOM and its departments that bill federal or state programs for healthcare-related goods or services ("Related Healthcare Entity" or "Related Healthcare Entities") and independent contractors who may be engaged by the Related Healthcare Entity as to the requirements of the Federal Deficit Reduction Act of 2005 and fraud, waste and abuse protections contained in various state and federal laws and regulations.

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 C. The provisions of this policy are also intended to satisfy the requirements of the Deficit Reduction Act of 2005 (DRA), particularly Section 6032, by providing information about federal and state laws relating to liability for false claims and statements.

VI. ATTACHMENTS

A. Attachment 1, Hyperlinks

By Direction of the President:

Signature on file
RowanSOM Chief Compliance and Privacy Officer

ATTACHMENT 1
HYPERLINKS

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