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It is the policy of Rowan University that employees, students employed by the university, contractors, representatives or agents have a duty to report suspected wrongful conduct and they should be able to meet this duty without the fear of retaliation or reprisal. This policy gives everyone the opportunity to help Rowan achieve its mission.
IV. REFERENCES
- Corporate Integrity Agreement between the Office of Inspector General of the Department of Health and Human Services and the University of Medicine and Dentistry of New Jersey, September 25, 2009 to September 25, 2014, as amended by a Letter Agreement, UMDNJ-RowanSOM dated 5/1/2013.The Rowan University Voluntary Compliance Plan effective September 26, 2014.
- The Medicare and Medicaid Patient Protection Act of 1987, as amended, 42 U.S.C. §1320a- 7b (the "Anti-kickback Statute"),
- Stark Law, 42 CFR §§ 411.350 – 411.389.
- New Jersey's Conscientious Employee Protection Act (N.J.S.A. 34.19-1 et seq., also known as the "Whistleblower Act").
- Sarbanes-Oxley not only prohibits retaliating against whistleblowers (SOX section 806), it also affirmatively requires companies to set up hotlines or other "procedures" for the "confidential, anonymous submission of employee complaints and concerns" about audit/accounting fraud (SOX section 301).
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