Enforcement and Prevention

Approval/Effective Date: 5/12/2010
Last Reviewed: 4/27/2015

Policy: The University of Washington School of Dentistry will respond to all reports of conduct and or activity which may be contrary to applicable Federal and state laws or regulations.

Purpose: The purpose of this policy is to set forth the procedures that will be used by University of Washington School of Dentistry to respond to reports that departments or individuals are engaging in activity which may be contrary to applicable Federal and state laws or regulations.

Procedures: Upon receipt of a complaint or other information which suggests the existence of a serious pattern of conduct in violation of compliance policies or applicable laws or regulations, an investigation under the direction and control of the Compliance Director will be commenced. The Associate Dean of Information Management and Quality Improvement and Executive Director of Health Sciences (when appropriate) will be notified immediately. The investigation will begin as soon as reasonably possible.

The Compliance Director will determine the most appropriate method of investigation under the specific circumstances of each reported or suspected violation. In undertaking this investigation, the Compliance Director may solicit the support of external auditors and counsel and internal and external resources with knowledge of the applicable laws and regulations. These persons will function under the direction of the Compliance Director and will be required to submit relevant evidence, notes, findings and conclusions to the Compliance Director. The Compliance Director will maintain documentation of all investigative actions, details and findings.

The purpose of the investigation will be to identify those situations in which the laws, rules and standards of Federal and state programs may not have been followed; to identify individuals who may have knowingly or inadvertently caused claims to be submitted or processed in a manner which violated Federal or state laws, rules, or standards; to facilitate the correction of any practices not in compliance with Federal or state laws, rules and standards; to implement those procedures necessary to ensure future compliance; to protect the University of Washington School of Dentistry in the event of civil or criminal enforcement actions, and to preserve and protect the assets of the University of Washington School of Dentistry.