Message from the Office of the President
July 6, 2016
Members of the Rutgers Community:
As we continue to grow and thrive as a community, we must all take an active role in preserving Rutgers' reputation as one of the finest research universities in America. We have tasked the Office of Enterprise Risk Management, Ethics, and Compliance with developing a universitywide system to recognize potential problems and take the appropriate steps to safeguard our community.
I'm pleased to announce that our Ethics Office has launched Rutgers Ethics Armor (ethics.rutgers.edu) as a proactive approach to help protect the integrity and reputation of Rutgers, its faculty, and its staff. Ethics Armor provides a centralized, automated system for conflicts of interest disclosures for faculty and staff, reinforcing the university's existing policies in a simple, straightforward process.
Ethics Armor includes automatic reminders, email notifications, and streamlined methodology, so faculty and staff can complete their disclosures in a straightforward and efficient manner, in about the amount of time it takes to fill out a survey. The Ethics Armor program includes:
- Rutgers Code of Conduct – annual review
- Outside Activity Questionnaire (OAQ) – for secondary employment, submitted annually and part of your personnel record
- Attendance at Events Forms – as needed when attending events away from the university
- Supervisor Review – supervisors and department heads will have the opportunity to review submissions for operational concerns
- Ethics Office Review – The Ethics Office staff will review disclosures for potential conflicts of interest
- Scholarly Capacity Annual Disclosures – specifically for faculty, submitted annually to disclose awards and publications
These disclosures should be familiar to you already; Ethics Armor just eliminates the need for paper forms and creates a uniform, consistent process across the entire university. The Ethics Armor website at ethics.rutgers.edu also maintains all the information to answer any questions you may have regarding the disclosures or the relevant university policies regarding conflicts of interest.
You should expect to be contacted by the Rutgers Ethics Office to begin the disclosure process, but if you have any questions please feel free to contact the office by e-mail at firstname.lastname@example.org or by phone at 732-743-3344.
Message from the Office of the President
December 21, 2015
Members of the Rutgers Community:
I am writing to announce management changes within the Office of Enterprise Risk Management, Ethics, and Compliance and the Office of General Counsel.
First, I am pleased to announce that William F. Brossman, Jr. has been appointed Senior Vice President and Chief Enterprise Risk, Ethics and Compliance Officer for Rutgers University. He begins his tenure on January 4, 2016.
Mr. Brossman brings deep and relevant expertise in risk management and compliance to this position. For the past five years he has served as Corporate Chief Risk Officer and Enterprise Risk Management (ERM) Process Leader for Marsh & McLennan Companies, a leading professional services firm with offices in 50 countries. From 2005 to 2010, Mr. Brossman was the chief compliance officer for the healthcare consulting firm Mercer Health & Benefits, and, for 17 years before that, served as that firm’s national compliance practice leader. Having handled healthcare-related regulatory issues for many years, he is particularly well-suited to ensuring that Rutgers takes full advantage of the opportunities—and navigates the risks—of our new era as a comprehensive public research university.
Mr. Brossman earned a J.D. from Western New England University School of Law and an LL.M. in taxation law from New York University School of Law. He also holds a master’s degree in risk management from NYU’s Stern School of Business and certification from the Society of Corporate Compliance and Ethics.
I want to thank Frances Bouchoux, who has served with dedication and integrity and has done an outstanding job as Interim Senior Vice President for the past 19 months. Ms. Bouchoux will now serve as Vice President and Deputy Chief Risk Officer; in this position, she will develop and expand the institutional compliance program, including the ethics and privacy programs, and direct the Enterprise Risk Management Program.
As noted in a previous communication, we have launched a search for a new Senior Vice President and General Counsel. As we complete the process, I have asked Lisa Wahler to serve as Interim Senior Vice President, effective January 4, 2016.
Lisa, who holds three academic degrees from Rutgers, including her J.D., has been a valued member of the Office of General Counsel since her appointment in 2002. She was instrumental in supporting Rutgers during the Restructuring Act integration and has remained a constant source of support for the Office of General Counsel. We are pleased that she is supporting Rutgers again by accepting this interim role.
Please join me in welcoming Bill, applauding Fran, and wishing Lisa well in her interim appointment.
What to Expect After Our Final CIA- Reporting Period?
Chancellor Strom Updates the RBHS Community on the Corporate Integrity Agreement
The reporting period for the final year of the Corporate Integrity Agreement (CIA) between Rutgers and the Office of Inspector General of the Department of Health and Human Services will conclude on September 25, 2014. We should all have a sense of pride and accomplishment as RBHS successfully meets this milestone. As we acknowledge this achievement, it is important to emphasize how the compliance program has made RBHS a stronger institution.
To achieve our full potential we must continue to adhere to the highest professional and ethical standards, to abide by federal and state laws, and maintain a robust compliance program. Following the expiration of the CIA, we will be reviewing and modifying RBHS policies to ensure they allow all of our units to transact business while minimizing the risks we face as a healthcare provider. In partnership with the Office of the General Counsel, we will continue to track focus arrangements (agreements involving actual or potential sources of referral) to ensure compliance with Stark and Anti-Kickback laws, monitor changes to pertinent laws, certify the focus arrangements database on a quarterly basis, and develop a standardized approach to contracting among all units to ensure compliance with relevant laws, regulations, and university policies. The RBHS Compliance Committee will continue to operate in conjunction with the appropriate committees based in each unit. We will also continue the annual compliance training requirements and monitoring of non-monetary compensation. Lastly, to ensure continuous improvements in process, we will also arrange for an annual compliance effectiveness review.
Our recent experience makes clear that a strong program promotes both regulatory and legal compliance and provides reputational, fiscal, and operational benefits to the institution. In fact, the Office of Enterprise Risk Management, Ethics and Compliance (OERMEC) will be developing and expanding a university-wide compliance program modeled after the RBHS healthcare compliance program.
Thank you for your cooperation and assistance in helping us reach this important turning point for RBHS in our efforts to achieve our full potential as a premier academic health center.
Brian L. Strom, MD, MPH