UMDNJ Enters Into a Corporate Integrity Agreement

William F. Owen, Jr., MD
President, University of Medicine and Dentistry of New Jersey

September 15, 2009

Dear Members of the University Community,

I have important news regarding a decision by the University Board of Trustees at its meeting today (Sept. 15th). The Board voted to approve a Corporate Integrity Agreement (CIA) with the Office of Inspector General (OIG) of the United States Department of Health and Human Services (HHS). Under the terms of the CIA, UMDNJ agrees to adhere to specific requirements that will ensure that we are in compliance with all laws and regulations involving Medicare/Medicaid and all other Federal health care programs.

I am encouraging all of you to view the CIA as I do. Consider it a milestone in the University’s ongoing efforts to demonstrate that we are conducting all aspects of our business in an ethically sound manner and in full compliance with all federal and state laws and regulations. The CIA is the last major step in a chain of measures taken against the University because of poor past business practices carried out by a tiny fraction of University employees who are no longer here.

A CIA is by no means unique to UMDNJ. Major hospital centers, global pharmaceutical companies, health insurers and individual health care providers have entered into a CIA to demonstrate sound compliance and to continue doing business with the Federal government. Our CIA is just one of many hundreds of such agreements now in effect.

I also want to underscore that the CIA is in response to old violations stemming from improper conduct dating as far back as 1993. One involves double-billing for Medicaid reimbursement -- the second, payments to cardiologists to refer their patents to UMDNJ.

Most of the reforms under the CIA are already in place. The most impactful requirement for you will be additional training in compliance matters. Otherwise, your routines are unaffected. This is not a Federal monitorship or Deferred Prosecution Agreement. Thanks to so many of you, we are truly a changed institution, committed to conducting all business matters in an ethical and legally compliant manner and with a zero tolerance policy for practices that fall short of those standards. We have a strong compliance program in place -- at least as stringent as any you might find at any major university, hospital center or academic medical center. So many of you have been going the extra mile to help restore public trust and confidence in our business operations. The CIA will allow us to validate just how far we’ve come.

I am confident that we will all do what’s requested of us to meet the CIA’s requirements. The first critical step is reading UMDNJ’s revised Code of Conduct that each of you will be receiving in the coming days. The Code outlines the standards for ethical conduct in all workplace dealings. You will be receiving another message from me regarding what is expected of you concerning the Code. That and other details of CIA requirements will also be communicated to you by your managers. For those of you with additional questions about the Corporate Integrity Agreement and its implications for the University and for you as a University employee, please refer to Frequently Asked Questions regarding the CIA posted on my web page. For information about CIAs in general, I urge you to visit the website of the Office of Inspector General at the following link:

http://oig.hhs.gov/fraud/cias.asp

The CIA is a necessary and welcome directive vital to the University’s strength as a valuable state-wide asset. The CIA will allow us to prove to the public what many of you already know: our house is in much better order and we are better poised than ever for an exciting and fruitful future.

Best regards,

William F. Owen, President