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Reporting Compliance

Reporting Compliance Concerns

The Compliance Helpline is one aspect of the College’s Institutional Compliance Program. Faculty, employees and students who, in good faith, have concerns relating to possible violations with government or external agency laws or regulations, College’s policies or with errors or irregularities in the College’s financial accounting practices or policies are encouraged to report them by choosing any of the following options: 

Local Resolution

The best place to raise a concern typically begins within your own department or unit through ordinary management or supervisory channels, beginning with an immediate supervisor, instructor or adviser. Usually, the local department or unit is the most familiar with the issues and parties and best equipped to address or raise a concern to a higher level. The Compliance Directory (below) also identifies a specific compliance coordinator to handle certain kinds of problems.

The members of the Institutional Compliance Committee consists of:

  1. Robert W. Amler, M.D. M.B.A., Dean of School of Health Sciences and Practice
  2. Edward C. Halperin, M.D., M.A., Chancellor and CEO
  3. Edmund LaGamma, M.D., School of Medicine
  4. Adam Hammerman, M.B.A., Vice President and Chief Financial Officer
  5. Patric K. Stanton, Ph.D., Graduate School of Basic Medical Sciences
  6. Denise Tahara, M.B.A., M.Phil., Ph.D., School of Health Sciences and Practice

Institutional Compliance Officer or Compliance Director

Sometimes, because of the subject matter or due to work or personal relationships, concerns may best be raised with the Institutional Compliance Officer or the Compliance Director.  You can reach the College’s Institutional Compliance Officer or the Compliance Director at (914) 594-4567.

Compliance Helpline

If you are uncomfortable raising compliance concerns through the normal channels listed above, you may use the Compliance Helpline, provided by The Network ReportLine, an independent company that furnishes similar services for hundreds of companies and universities.  A call to the Compliance Helpline can also be anonymous.

What not to Report:

Report emergencies to 911 and to the College’s Security Office, and not to the Compliance Hotline. Disputes or disagreements with supervisors regarding performance evaluations, wage increases, grievances or other employment concerns that do not involve legal or policy violations, or issues that the College is not reasonably responsible for, are also not to be reported through the Compliance Hotline. Purely student issues such as housing, financial aid, academic misconduct, and other student affairs issues should be raised directly with the responsible College office associated with that issue.  

Your Obligations as a Reporter:

College faculty, employees and students are expected to act in good faith, report on concerns that are reasonably considered to be in possible violation of any law, regulation or College policy governing any College activity, and are expected to be truthful and cooperative in the College's investigation of allegations. Such good faith reports will not jeopardize employment or academic standing. Making reports in bad faith, knowingly making false reports or providing false or untruthful information during an investigation can lead to discipline, including if warranted, termination. 

How to Use the Compliance Helpline:

The Compliance Hotline is available seven days a week, 24 hours a day: 1 (646) 565-6330

If you have any questions or concerns on the Institutional Compliance Program, please contact the Institutional Compliance Officer or the Compliance Director at:

Office of the General Counsel & Institutional Compliance 
New York Medical College 
Sunshine Cottage Administration Building, 2nd Floor
Valhalla, NY 10595
Tel. (914) 594-4567
Fax. (914) 594-4328


Compliance Risk Area

Responsible Senior Officer(s)

Functionally Responsible Office(s)

Functionally Responsible Compliance Coordinator(s)

 Representative Compliance Issues

Academic Integrity

Applicable Dean

Applicable Dean’s Office

Applicable Dean

Student Honor Code
Student Plagiarism
Academic cheating

Accreditations

Chancellor and Applicable Dean

Chancellor and Applicable Dean’s Office

Chancellor and Applicable Dean

Middle States Accreditation
Council on Education and Public Health accreditation
LCME

Asset Management / Endowment

Adam Hammerman

Finance Office

George Nestler

Compliance with state laws on not-for-profit organizations

Comparative Medicine

Dean, School of Medicine

Department of Comparative Medicine

Sulli Popilskis

Animal welfare
IACUC
Federal and state laws and regulations

Conflict of Interest and Commitment

Chancellor 

Chancellor Office

Chancellor or his designee

Institutional conflicts
Indemnification and reporting
Oversight and monitoring
Required record keeping
Consulting
Outside employment
Outside activities
Political activities and donations
Use of University resources
Nepotism and personal relationships
Solicitation
Gifts and gratuities

Contracts

OGC

Office of General Counsel

Emily Berstein

Negotiation of contract terms
Review of contract language
Processing and execution of contracts

Gift Restrictions

Amy Khan

Office of University Development

Kevin Daly or his designee

Requirements relating to use of donor funds
Statutory or regulatory limits on donor gifts
Tax treatment

Employment discrimination / Sexual or racial harassment / Disabilities

As applicable, Chancellor or respective Dean 

Human Resource Department and the Office of General Counsel

Theresa Haviland

Unfair treatment or harassment on the basis of a protected classification, such as sex, religion, race, ethnicity, disabilities

Environmental Health & Safety

Michael Rogovin

EEHS Department

Sarah Cottet

OSHA
Fire safety & inspections
Building Safety
Construction and housing codes
Asbestos
Chemical and oil spills
Biosafety
Electrical safety
Energy plant

Faculty Practice Plans (at New York City Health and Hospital Corporation (NYCHHC))

Adam Hammerman

Finance Office

Percival Liongson, and Phy-CARE’s Compliance Officer

Agreements
Doctors Council
Hospital Affiliations

Fiscal

Adam Hammerman

Controller’s Office

George Nestler

Cash draws
Disbursements
Allowability of expenses
Accounts receivables
Purchasing
Record security
Accounts payable
Property (Inventory, Tracking, Reporting)
Financial reporting
System controls
Debt management

Human Resources

Michael Rogovin

Human Resources Department

Theresa Haviland

Recruiting and hiring
Employment Immigration and VISA status for employees
Termination and departure
Compensation
Benefits
Leaves
Performance management
Overtime/Overload
Labor relations
EEOC / Affirmative Action
Americans with Disability Act
Workers Compensation

Human Subjects Research

Dean, School of Medicine

Office of Research Administration

Salomon Amar

Required training
Protocol review
IRB operations 
Documentation 
Approvals and certification
Adverse event & other reporting
Subject recruiting and informed consent
Federal and state laws and regulations

Immigration (for students, faculty, researchers)

Applicable Dean

Office of International Students and Scholars

Elizabeth Ward

Documents and reporting for international students, faculty, researchers

Information Technology

Michael Rogovin

Information Services

Luis Montes

Use of College computer and communications equipment
Improper use of College email, voicemail and internet service
Data privacy
(See also Data Retention above)

Intellectual Property / Technology Licensing

Dean, School of Medicine

Office of Research Administration and Office of General Counsel

Salomon Amar

Disclosure of inventions
Patent prosecutions
Commercialization and licensing of College-owned patents
Copyright protections

Payroll

Adam Hammerman

Controller’s Office

Alex Kajdi

Payroll

Privacy: FERPA / Student Records

Dean, School of Medicine

Registrar

Eileen Romero

Requests and subpoenas for student record information
Protection against unauthorized access to and disclosure of covered information of students

Privacy: HIPAA

OGC

Office of General Counsel

Salomon Amar for research; Theresa Haviland for employees

Requests and subpoenas for health information
Protection of covered health information
Privacy notices
HIPAA security rule

Radiation Safety

Michael Rogovin

EEHS Department

Sarah Cottet

Radiation safety

Real Property & Land Use

Adam Hammerman

Finance Office

Adam Hammerman

Leases on College buildings from County of Westchester
Purchase and sale of properties
Leasing or subleasing property to outside entities 
Compliance with building codes (See also Environmental, Health & Safety above)
Renovation and deferred maintenance

Research Administration

Dean, School of Medicine

Office of Research Administration

Salomon Amar

Research policy
Grants applications and management
Reporting
Principal Investigators (PIs)

Scientific Misconduct

Dean, School of Medicine

Office of Research Administration

Salomon Amar

Fabrication, falsification or plagiarism
Investigation of allegations of scientific misconduct
Reporting to appropriate federal and/or state agencies

Security / Campus Safety

Michael Rogovin

Security

William Allison

Campus crime
Workplace violence
Reporting of campus crime statistics
Security preparedness
Emergency/Disaster preparedness and response

Student Financial Aid

Dean, School of Medicine and Adam Hammermann

Office of Student Financial Planning and Bursar’s Office

Anthony Sozzo

Federal student loans
Private student loans
Grants and scholarships
Compliance with federal, state and local laws and regulations

Tax

Adam Hammerman

Controller’s Office

George Nestler

Compliance with federal, state and local tax codes and regulations