Frequently Asked Questions
About the Integration of the School of Osteopathic Medicine with Rowan University
- What is a compliance program?
The goal of a Compliance Program is to ensure ethical behavior and fulfillment of laws, regulations and policies in all aspects of operations. A compliance program defines and governs the conduct expected of employees, provides guidance on resolving questions related to business conduct and ethical issues and establishes a mechanism by which employees can report possible violations. It complements the program, requirements and processes already in place to conform with the State of New Jersey Code of Ethics and Rowan University's Ethics Program.
- What are the components of an effective compliance plan?
- Promulgating and implementing written policies and procedures
- Designating a compliance officer and a compliance committee
- Conducting effective training and education
- Developing effective lines of communication
- Enforcing standards through well-publicized disciplinary guidelines
- Auditing and monitoring
- Responding to detected offenses and developing corrective action initiatives
- Why should we have an effective compliance program?
The Compliance Program:
- Shows to the local communities that the organization is committed to honesty and responsible corporate business practices.
- Reinforces employees' sense of right and wrong and provides a hotline for employees to report potential non-compliance issues or violations, without retaliation.
- Assists providers in their legal duty in submissions of accurate claims to government and private payers.
- Is cost effective, by preventing the provider business disruption and expense to defend against fraud investigations.
- Provides ongoing education and training to monitor employees' and contractors' understanding of compliance program rules and behaviors relating to fraud and abuse, enhances the quality of care provided to patients and sets forth codes of conduct for the provider.
- Provides policies and procedures to promptly and efficiently respond to and correct misconduct.
- May reduce any sanction imposed by the government after an investigation and may reduce chances of provider exclusions from federal programs.
- May protect the corporate executives and directors from personal liability.
- Is a successful healthcare business model.
- What is a corporate integrity agreement (CIA)?
A corporate integrity agreement (CIA) is a document that outlines the obligations an entity agrees to as part of a civil settlement. An entity agrees to the CIA obligations in exchange for the Office of Inspector General’s (“OIG”) agreement that it will not seek to exclude an entity from participation in Medicare, Medicaid or other federal health care programs. CIAs have common elements, but each one is tailored to address the specific facts of the case, and CIAs are often drafted to recognize the elements of a pre-existing compliance program.
- Where can I find an entity’s corporate integrity agreement?
The OIG website contains copies of current corporate integrity agreements (CIA) and certification of compliance agreements. The website list provides the names of those with settlement agreements with integrity provisions, but does not provide the electronic documents. To receive copies of settlement agreements with integrity provisions, a Freedom of Information Act Request must be filed with the Department of Justice http://www.justice.gov/oip/oip.html.
- Why is UMDNJ under a CIA?
UMDNJ has been under a CIA for the past four years. Under the terms of the CIA, UMDNJ agreed to adhere to requirements that will ensure regulatory and legal compliance with all federal healthcare programs. The CIA into which UMDNJ entered was part of the settlement covering two separate cases relating to actions taken as far back as 1993. One involved double-billing for Medicaid reimbursement. The second involved payments to cardiologists to refer their patients to UMDNJ. Neither of these cases occurred at the School of Osteopathic Medicine or the Stratford campus.
- How long does the CIA last?
The length of the average CIA is three to five years. The UMDNJ CIA is a five-year arrangement that began in September 2009 and will end September 2014. Thus, approximately 15 months will remain under the CIA after SOM becomes part of Rowan University. However, many of the elements of the compliance program implemented under the CIA will continue in the interests of sound business practices.
- What is HIPAA?
HIPAA is the “Health Insurance Portability and Accountability Act of 1996,” Public Law
104-191. HIPAA contains three parts relevant to healthcare information, which include requirements related to the:
- Privacy of individually identifiable health information
- Security of electronic health information
- Standardization of transaction and code sets.
The U.S. Department of Health & Human Services Office for Civil Rights (OCR) has issued new HIPAA guidance on communication with family, friends or others involved in a patient's care. This guidance does not reflect a change in any laws or regulations; it is intended to clarify HIPAA requirements so that providers do not unnecessarily withhold a patient's health information.
There are two guides available—one for providers and one for patients. These guides list common questions about HIPAA and indicate when health care providers may discuss or share health information with family members, friends or others involved in care or payment for care. The provider guide also includes a chart that summarizes relevant requirements under HIPAA.
To access these resources, visit the OCR health information privacy website at: http://www.hhs.gov/ocr/privacy/
Clinical Integration Issues
- Will there be any change in the policies and procedures in regards to the running of the clinical service delivery?
No, the current policies and procedures will remain in place as of July 1.
- How will patients be communicated to about the restructuring?
Guidelines are being crafted by communication specialists that will help staff communicate to their patients what will happen on July 1.
- Will any locations change?
Locations will not change as a result of the integration into Rowan. From time to time, clinical offices move, open or close to best serve our patients and as leases end.
- Will community relationships change with hospitals, nursing homes and others?
No, procedures to facilitate the transfer of all agreements between SOM and outside entities are in progress.
- Will SOM still have a faculty practice plan?
Yes, by both the desire of Rowan University and by state statute.
- Will SOM still be using the same EMR?
Yes, GE will continue to be used as SOM’s EMR. The transfer will be seamless.
- Will SOM still be using IDX?
Yes, IDX will be seamlessly transferred.
- Will clinical trials continue?
Yes, the agreements will be transferred.
- What IRB will SOM be using?
The eIRB that is currently in place at SOM will be transferred.
- What will our medical malpractice coverage be?
Employees will be covered by the state of New Jersey as before.
Human Resources/Labor/Employment Issues
- With this "partnership," did my job just become less secure?
Rowan and SOM employees will continue to be represented by their respective bargaining units, and the legislation specifies that there will be no layoffs, due to the restructuring, of employees represented by the bargaining units for one year following the July 2013 effective date. Administrators believe Rowan and SOM will become stronger and larger than they would have been independently and that employment opportunities will increase, not decrease, in the future. Rowan has experienced continued growth since the 1990s and the demand for a quality, affordable education is not expected to change. Likewise, SOM has increased its class size by 50 percent during the past few years, greatly enhancing its capacity to train the physicians of tomorrow. A graduate degree program in biomedical sciences at SOM, launched in 1997, now numbers 190 students in master's and doctoral programs. As the demand for health professionals continues to rise, Rowan expects greater employment opportunities.
- If my position is at SOM may I apply for positions with Rowan in Glassboro or Camden?
After the July 1, 2013, effective date, there may be opportunities for transfers to either campus, similar to the opportunities that already exist at each institution.
- May families of SOM employees enroll in courses and degree programs at Rowan?
Rowan offers as a benefit an option for employees and dependents of employees represented by various unions to receive undergraduate tuition. This benefit has been specifically negotiated between the State and those bargaining units. Employees may be eligible to receive the benefit for graduate studies if those studies are related to their positions and approved by their unit heads. Employees covered under agreements established between collective bargaining units and UMDNJ will be governed by those agreements and State law.
- As an SOM unionized employee, what will my employment status be effective July 1, 2013?
All unionized employees who are in employment status effective July 1, 2013, will remain in that status with no loss in pay, benefits, etc., through at least June 30, 2014.
- As an SOM unionized employee, what will the status of my bargaining unit be effective July 1, 2013? Will I be transferred to an equivalent union in place at Rowan University?
In accordance with the legislation, all SOM unionized employees will remain in their current unions effective July 1, 2013, and those union contracts will remain in effect until such time as new or revised agreements or contracts are agreed to.
- A good number of SOM employees are identified as central administration with UMDNJ identified as the employer of record. What will their employment status be effective July 1, 2013?
Currently, part of the integration transition process involves identifying all employees who work on the SOM campus or who are affiliated with the SOM and who will become Rowan University employees. Those employees are so identified and who are in good standing will be employed by Rowan University effective July 1, 2013.
- As a future Rowan employee, will there be any lapse in benefits once the integration occurs effective July 1, 2013, and/or do I have to do anything to ensure that there is no lapse in coverage?
A key part of the integration transition process is to ensure that there is NO disruption in benefits and that effective July 1, 2013, there will be a seamless transition regarding payroll, benefits, etc. This seamless transition is being managed by Rowan staff and their counterparts at UMDNJ-SOM, with assistance from the State.
- Will my years of service, and benefits that come with them, transfer to Rowan.
The goal is that all seniority and benefits will transfer seamlessly to Rowan on July 1, 2013.
- Will Teamsters Local 97 represented employees have the option to join CWA—already a part of Rowan—on July 1, 2014?
The law provides for the continuation of bargaining units until and unless the employees make changes consistent with federal labor law. Existing titles with bargaining unit contracts will continue until expiration or revision of the contracts. The possibility of transfers will be discussed by labor and management in specific instances as they arise.
- Will all my email, including the documents saved in email folders, transfer to Rowan’s email?
Yes, the plan is to migrate the email system in its entirety (i.e., mail, calendar, address books, tasks, etc.). Archives are stored on the local hard drive and will remain intact.
- What are the pay periods, and will my direct deposit be impacted?
Rowan pays employees every other week. Existing direct deposit arrangements will continue with no lapse.
- I have been accepted into the UMDNJ-SOM class of 2017 (beginning this year). As an out-of-state student, what will be the policy for out-of-state students for changing their residency status to in-state, after the first year, since the school will be absorbed into Rowan?
The policy will continue for the class entering summer 2013.
- Will students be able to verify their medical education records, obtain transcripts, receive financial aid, etc., without a gap in service during the transition?
Yes. Maintaining seamless support for students to the greatest degree possible is an important element both institutions are emphasizing in our integration planning.
- What will the diplomas say of students who graduate after July 1.
Students who graduate after July 1 will receive a Rowan University School of Osteopathic Medicine diploma with language indicating that they earned the degree while a student at UMDNJ.
- What will replacement diplomas say?
Replacement diplomas will bear the Rowan University School of Osteopathic Medicine name, but indicate it was formerly associated with UMDNJ.
- Will there be new parking passes and will the fees change?
Students and faculty will need new parking passes, but the timeline for this transition has not been determined. Fees will remain the same at least for this coming academic year.
Questions and answers related to research can be found here.