Jefferson University Hospitals

Prohibition Against Retaliation for Good Faith Reporting of Noncompliance (Policy Number: 107.06)

Policy No: 107.06
Effective Date: 9/30/2003
Revision No: 1

Category: Compliance Administration
Title: Prohibition Against Retaliation for Good Faith Reporting of Noncompliance
Applicability: Thomas Jefferson University


Policy

Thomas Jefferson University employees and students have a responsibility to report concerns about any real or potential non-compliance with applicable federal, state and local laws and internal policies and procedures. The University is firmly committed to a policy which encourages timely disclosure of such concerns and prohibits retribution or retaliation against anyone who in good faith reports such concerns. This policy is intended to protect any individual who engages in good faith disclosure of alleged non-compliance to a designated University official or public body.

Procedure

Thomas Jefferson University and Jefferson University Physicians (the University) encourage employees, students, patients, visitors, volunteers and others to report, through appropriate channels, concerns regarding actual or potential non-compliance with applicable federal, state and local laws and internal policies and procedures. Reporting through appropriate channels means that individuals are encouraged to make an initial report to a supervisor or the Corporate Compliance Officer. However, the University realizes that individuals may be reluctant to report their concerns due to the threat of possible retaliation, retribution or harassment. Accordingly, in order to facilitate the reporting process, supervisors, managers, professors, instructors, co-workers or those in a similar position are forbidden from engaging in retaliation, retribution or harassment directed against an individual who in good faith reports a concern to a University official or public body.

If an adverse personnel or academic action is taken against a University employee, student or other individual in retaliation for his or her good faith disclosure of information to a designated University official or public body concerning alleged wrongful conduct, and if the employee or students conduct or performance did not otherwise warrant such action, the adverse personnel or academic action will be reversed and the individual engaging in the prohibited behavior may be subject to discipline under this policy.

However, this policy may not be used as a defense by an employee, student or other individual against whom an adverse personnel, academic, or other disciplinary action has been taken for legitimate reasons under University policies and procedures. Thus, an adverse personnel, academic, or other disciplinary action against an employee or student whose conduct or performance warrants that action will not be deemed a violation of this policy. Additionally, an individual who knowingly and intentionally makes false allegations of non-compliance to a public body or designated University official shall be subject to disciplinary measures, up to and including discharge, in accordance with University policies and procedures.

All suspected or alleged cases of retaliation, retribution and/or harassment must be reported to the Department of Human Resources which will refer the matter to the Corporate Compliance Officer. After a complete investigation of the circumstances in collaboration with the Department of Human Resources, the Corporate Compliance Officer will determine whether a violation of this policy has occurred. In the event a violation has occurred, the Corporate Compliance Officer will refer the matter to the Department of Human Resources which will determine the appropriate discipline of the individual who committed the violation in accordance with University policies and procedures.

Revision Date(s): 09/30/2003
Review Date(s):

Responsibility for maintenance of policy: Corporate Compliance Officer