ROWAN UNIVERSITY POLICY

Title: Responding to Suspected Violations of the Stark Law That Do Not Implicate the Anti- Kickback Statute
Subject: Office of Compliance & Corporate Integrity
Policy No: OCCI:2013:C09
Applies: RowanSOM
Issuing Authority: Rowan President & RowanSOM Dean
Responsible Authority: RowanSOM Chief Compliance & Privacy Officer & General Counsel
Originally Issued: 01/24/2013
Revisions: 07/01/2013
Reviewed: 01/07/2014

I. PURPOSE

To ensure that the Related Healthcare Entities follow the Centers for Medicare and Medicaid Services' (CMS) Voluntary Self-Referral Disclosure Protocol (SRDP) when appropriate.

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