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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: 02/01

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/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.

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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.

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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]

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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]

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