The Rowan School of Osteopathic Medicine (RowanSOM) departments and units that bill federal or state programs for the provision of healthcare-related goods and services (“Related Healthcare Entity or “Related Healthcare Entities”) are committed to the highest possible standards of ethical business conduct and to the proposition that, not only that employees have a responsibility and an affirmative duty to report actual or suspected wrongful conduct, but also that they should be able to do so without fear of reprisal. Such reports shall be accepted willingly, kept confidential to the extent possible in conformance with applicable laws, regulations and other procedures, and addressed promptly and appropriately. All employees and faculty of the Related Healthcare Entities are responsible to ensure that their activities on behalf of the Related Healthcare Entity, and those of their colleagues, comply with all applicable federal and state laws, Rowan University policies and RowanSOM policies.
This policy applies to and should be read by all employees, contractors or agents of the schools, departments and units that are a part of RowanSOM units and departments that bill federal or state programs for healthcare-related goods or services (“Related Healthcare Entity” or “Related Healthcare Entities”) as to their duty to report suspected wrongdoing, the methods they may use to meet their reporting requirements and the protections in place for individuals who may reports of suspected wrongdoing in good faith. Other employees of RowanSOM departments that support the Related Healthcare Entities in their operations, including but not limited to Rowan University Procurement Services, The Office of General Counsel and RowanSOM University Finance should also read this policy.
This policy is intended for all faculty members, employees, students and independent contractors of RowanSOM departments and units that bill federal or state programs for the provision of healthcare-related goods and services (“Related Healthcare Entity” or “Related Healthcare Entities”). These faculty members, employees, students and independent contractors have a duty to report suspected wrongful conduct and that they should be able to meet this duty without the fear of reprisal.
A. Voluntary Compliance Plan effective September 26, 2014 [i] .
B. The Medicare and Medicaid Patient Protection Act of 1987, as amended, 42 U.S.C. §1320a-7b (the "Antikickback Statute") [ii] ,
C. Stark Law, 42 CFR §§ 411.350 – 411.389 [iii]
A. Reporting Compliance and Ethics Concerns
B. Retaliation
C. Sanctions
Failure to comply with this policy may result in sanctions up to, and including, termination of employment or termination of a contractor’s agreement.
A. Attachment 1, Where to Go For Support/Direction and How to Report an Issue
B. Attachment 2, Hyperlinks
By Direction of the President:
Signature on file
RowanSOM Chief Compliance & Privacy Officer
Critical information system being hacked or compromised (Oracle, PeopleSoft, Banner, e-mail)
http://www.rowan.edu/som/ist/index.html
Disability: Americans with Disabilities Act (staff-related)
Disability: Americans with Disabilities Act (student-related)
Discrimination
Export Controls (Research)- www.rowan.edu/compliance, click research tab
Fair Labor Standards Act and Overtime Provisions
Fraud (Financial)
Harassment
Student Sexual Misconduct and Harassment Policy-
http://www.rowan.edu/equity/documents/TITLEIXCOMPLAINTFORM_004.pdf
http://www.rowan.edu/som/hr/documents/orientation.pdf
Healthcare Compliance
Human Subject Research Violations of DHHS/OHRP, FDA and other Federal Regulations pertaining to human subject research
Improper accounting and costing on sponsored projects
Improper document of or billing for healthcare goods or services
Laboratory Safety Violations
Misconduct in Research including Falsification of Documents/Records
Open Public Meetings Act –
Open Public Records Act –
Radiation Safety Violation of NRC or DCRA Regulations
Records Management (e.g. document retention schedules, archiving documents)
www.rowan.edu/compliance - Policies- Records Management
Records: Loss of records; inability to find records; improper release, disclosure or access to records
http://www.rowan.edu/adminfinance/records
http://www.rowan.edu/som/hr/documents/orientation.pdf
Student Information: The Office of Student Affairs Compliance - http://www.rowan.edu/som/education/student_affairs/contact.html
http://www.rowan.edu/equity/titleix
Patient Information - RowanSOM Chief Compliance & Privacy Officer (856-566-6136) or
HOTLINE 1-855-431-9967, www.rowan.edu/compliance
Non-public personal information of any individual, including credit card information, social security numbers, driver’s license numbers, etc. – Compliance HOTLINE-1-855-431-9967.
Director of Information Protection and Security or go to the Information Protection and Security website Research Compliance- http://www.rowan.edu/som/ist/index.html
• Office of the Vice President of Research and Economic Development Director of Regulatory Affairs - http://www.rowan.edu/som/research/admin.html
28. Research: Sponsored Project Billing and Reporting
• Division of Grant and Contract Accounting- http://www.rowan.edu/som/research/admin.html
• Internal Audit Department
29. RowanSOM Biomedical and Health Sciences Compliance Issues
• The RowanSOM Office of Compliance and Corporate Integrity- www.rowan.edu/compliance
or call (856) 566-6136
30. Sexual Harassment
• Policy Prohibiting Discrimination and Harassment - http://www.rowan.edu/equity, or http://www.rowan.edu/som/hr/documents/orientation.pdf
• Office of Employment Equity: http://www.rowan.edu/equity
• Harassment: A Guide for Faculty- http://www.rowan.edu/som/hr/documents/orientation.pdf
• Harassment: A Guide for Staff- http://www.rowan.edu/som/hr/documents/orientation.pdf
• Harassment: A Guide for Students- http://www.rowan.edu/equity/documents/StudentSexualPolicy7-25-12_002.pdf
• Code of Student Conduct (also see school-specific Codes of Student Conduct on the school’s website) http://www.rowan.edu/som/education/student_affairs/documents/SOMStudentHonorCode-Final.pdf
• Office of Student Conduct handles complaints against students arising out of their conduct as students- http://www.rowan.edu/som/education/student_affairs/documents/SOMStudentHonorCode-Final.pdf
31. Student Billings
• RowanSOM Office of Student Accounting, Billing and Cashiering - http://www.rowan.edu/adminfinance/policies_procedures/chap07/BURSAR%20Chapter%207%20OCT%2007%20%282%29.032808.pdf
http://www.rowan.edu/som/education/student_affairs/index.html
32. Student Loan Abuses
• RowanSOM Office of Financial Aid- http://www.rowan.edu/som/financialaid/Apply_JUMP.htm
33. University Property: Loss or Theft