Internal Review And Monitoring
Each employee engaged in billing shall be reviewed periodically by the Unit Compliance Officer. The Unit Compliance Officer may require more frequent reviews as deemed necessary and appropriate. If a review identifies issues of non-compliance, the Unit Compliance Officer shall report the issue to the particular Chairperson, the Chief Compliance Officer and if necessary, the UMDNJ Office of the General Counsel. In consultation with legal counsel, the Chief and/or Unit Compliance Officer shall review the situation to determine if there has been any activity inconsistent with the School policies. If, at the conclusion of any investigation, it appears there are compliance concerns, a corrective action plan will be formulated and initiated as quickly as possible.
All employees will be trained on the importance of adherence to this Plan. All newly appointed employees will be required to acknowledge that adherence to the Compliance Program outlined in this Plan is a material condition of employment. Employees will be informed that failure to comply with the requirements of the Plan will result in discipline up to and including immediate dismissal.
The Chief Compliance Officer shall verify annually in writing to the University President and to the Board of Trustees through the Audit Committee that the Plan has achieved the following goals:
- Established compliance standards and procedures that are reasonably capable of assuring ethical and compliant conduct;
- Designated specific individuals with a sufficient level of authority to oversee compliance with the standards and procedures set out in the Compliance Plan;
- Communicated effectively the standards and procedures to be followed by employees and established a mechanism to report possible issues of non-compliance and misconduct by means which minimizes the potential for retaliation and harassment;
- Used monitoring and auditing systems reasonably designed to detect illegal conduct and achieve substantial compliance with the applicable standards and procedures to the best of the Compliance Officer’s knowledge;
- Consistently enforced appropriate discipline of individuals who engage in activity which equates to non-compliance or misconduct and for individuals who are responsible for, and fail to detect, noncompliance or misconduct;
- Implemented effective compliance practices to prevent reoccurrence of non compliance or misconduct; responded to any reports of possible misconduct; and modified standards and procedures as necessary to achieve compliance.
The University will not appoint any person who is known to have intentionally engaged in misconduct to any position in which the person will have discretionary authority, and the University shall take reasonable steps to verify that applicants for positions requiring the exercise of discretionary authority have no history of illegal activity or exclusion from any Federal program.