Compendium of Student Policies for Faculty, Residents, and Staff

Compendium of Student Policies

for

Faculty, Residents, and Staff

The policies and procedures included in the Cooper Medical School of Rowan University (CMSRU) Compendium reflect

the most current policies and procedures of CMSRU and Rowan University (where applicable). CMSRU policies and

procedures are subject to amendment and change without prior notice. Minor changes will be posted directly to the

Compendium. When major changes occur, a notification will be sent to all faculty, residents, and staff.

Updated 8/2023

Table of Contents

CMSRU Medical Education Program Objectives 1

Policies Related to Student Affairs 11

Honor Code Policy 11

Professional Appearance Policy 12

Professional Conduct Policy 15

Policies Related to Medical Education 18

Student Attendance Policy 18

Conflict of Interest Policy 23

Duty Hours Limitations Policy 28

Formative Feedback Policy 29

Grading, Promotions, and Appeals Policy 30

Academic Workload Policy for Pre-Clinical Years 46

PRIME Policy 47

Student Clinical Assignment Policy 49

Medical Student Supervision During Required Clinical Activities Policy 50

Teacher-Learner Interaction Policy 52

Policies Related to Health and Safety 53

Alcohol and Other Drugs Policy 53

Anti-Violence Policy 59

COVID-19 Exposures and Testing Policy 61

Inclement Weather Policy 67

Infectious and Environmental Hazards, Needlesticks and Bloodborne Pathogens Exposure Policy 68

Impaired Student Process 71

Student Health Provider Policy 74

Student Healthcare Services Policy 75

Policies Related to Matriculation 77

Family Educational Rights and Privacy Act (FERPA) 77

Policies Related to Communications; and Information Technology and Resources 81

Acceptable Use Policy 81

Social Media Policy 89

Policies Related to Diversity, Equity, and Inclusion 98

Anti-Discrimination Policy 98

Student Mistreatment Policy 111

Religious Observance Policy 119

Student Sexual Misconduct and Harassment Policy 120

Title IX Student Sexual Harassment /Sexual Assault Policy 138

Technical Standards Required for Admission to and Completion of the MD Degree 157

Attestation 160

CMSRU Medical Education Program Objectives

General Competency: Medical Knowledge

Students will demonstrate knowledge of existing and evolving scientific information and its application

to patient care

Medical Education

Program Objective(s)

Outcome Measure(s)

Demonstrate a strong basic

science foundation in the

understanding of health and

disease (MK1)

Faculty Developed Examination Questions, NBME Subject

Examination, Practical Examinations, Life Stages TWA Assessment,

M3 Summative Assessment, M4 Summative Assessment, Summative

Narrative Assessment, Scholars Workshop Independent Capstone

Project, TBL Scores (IRAT/GRAT), ALG Student Assessments, M4

Resuscitation and Basics of Critical Care Oral Examination, Video

Review (Psychiatry), POPs Scores, Jigsaw Scores, Virtual Critical Care

Rounds-I (VCCR-I) Post Test, Student Presentations

Develop and demonstrate the

skills required to perform a

complete history and

physical examination (MK2)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Clinical Skills Examinations [mini-OSCEs],

Foundations of Medical Practice Individualized Education Plan, M3

Transdisciplinary Rubric, M3 Summative Assessment, M3 Student Self-

Assessment of Program Objectives, M4 Summative Assessment,

Summative Narrative Assessment, M4 Student Self, Assessment of

Program Objectives, Mini CEX, OSCEs, Patient and Procedure Logs,

M4 Resuscitation and Basics of Critical Care Oral Examination, Note

Review (Psychiatry), Neurology H&P/Consult Scoring Rubric, M3

Pediatric Mother, Infant Unit Assessment

Recognize the various

determinants of health,

including genetic

background, culture,

nutrition, age, gender and

social issues (MK3)

Ambulatory Clerkship Service Learning Reflective Essays, Ambulatory

Clerkship Behavior Checklist Assessment, Faculty Developed

Examination Questions, NBME Subject Examination, Practical Exams,

Foundations of Medical Practice Clinical Skills Examinations [mini-

OSCEs], Life Stages TWA Assessment, M3 Transdisciplinary Rubric,

M4 Summative Assessment, M3 Pediatric Mother-Infant Unit

Assessment

Access and critically evaluate

current medical information

and scientific evidence, and

apply this knowledge to

clinical problem-solving

(MK4)

Faculty Developed Examination Questions, NBME Subject

Examination, M3 Summative Assessment, M4 Summative Assessment,

Summative Narrative Assessment, Scholars Workshop Group Critical

Appraisal Project, Scholars Workshop Projects, WoW 1 Lean Six Sigma

Presentation, Video Review (Psychiatry), M3 Pediatric

Outpatient/Subspecialty Assessment, M3 Pediatric Mother-Infant Unit

Assessment, Virtual Critical Care Rounds-I (VCCR-I) Post Test, Student

Presentations, M3 Transdisciplinary Rubric

Medical Education

Program Objective(s)

Outcome Measure(s)

Apply current knowledge of

public health to patient care

(MK5)

Ambulatory Clerkship Behavior Checklist Assessment, Faculty

Developed Examination Questions, NBME Subject Examination, M3

Summative Assessment, M4 Summative Assessment, Summative

Narrative Assessment

Demonstrate an

understanding that racial

categories are not equivalent

to genetic ancestry. Rather,

race is a complex social and

political construct that may

engender bias and thereby

directly affects health

outcomes (MK6)

Ambulatory Clerkship Behavior Assessment, M3 Summative

Assessment, M4 Summative Assessment, Scholars Workshop Module

Assessment

Understand that the medical

literature may be biased by

historical racism and be

cognizant of this problem

when conducting the critical

appraisal and application of

medical literature (MK7)

Ambulatory Clerkship Behavior Assessment, M3 Summative

Assessment, M4 Summative Assessment, Scholars Workshop Module

Assessment, Faculty Developed Examination Questions

General Competency: Patient Care

Students will demonstrate an ability to provide patient care for common health problems across disciplines

that is considerate, compassionate, and culturally competent

Medical Education

Program Objective(s)

Outcome Measure(s)

Display appropriate clinical

skills, critical thinking,

medical decision-making and

problem-solving skills in the

delivery of care (PC1)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Clinical Skills Examinations [mini-OSCEs],

Foundations of Medical Practice Individualized Education Plan, M3

Summative Assessment, M3 Student Self-Assessment of Program

Objectives, M4 Summative Assessment, Summative Narrative

Assessment, OSCEs, Patient and Procedure Logs, M4 Resuscitation and

Basics of Critical Care Oral Examination, Note Review (Psychiatry),

Neurology H&P/Consult Scoring Rubric

Perform a complete history

and physical examination

(PC2)

Foundations of Medical Practice Clinical Skills Examinations,

Foundations of Medical Practice Individualized Education Plan,

Ambulatory Clerkship Behavior Checklist Assessments, M3

Assessments, OSCEs, M4 Summative Assessment, M3/M4/Student Self

Assessment of Program Objectives

Medical Education

Program Objective(s)

Outcome Measure(s)

Use and interpret diagnostic

studies appropriately (PC3)

Foundations of Medical Practice Clinical Skills Examinations

[miniOSCEs], Foundations of Medical Practice Individualized

Education Plan, M3 Summative Assessment, M3 Student Self-

Assessment of Program Objectives, M4 Summative Assessment,

Summative Narrative Assessment, M4 Student Self Assessment of

Program Objectives, OSCEs, Patient and Procedure Logs, ALG Student

Assessments, Note Review (Psychiatry)

Demonstrate relevant

procedural and clinical skills,

recognizing the indications,

contraindications and

complications, while

respecting patient needs and

preferences (PC4)

Foundations of Medical Practice Clinical Skills Examinations [mini

OSCEs], Foundations of Medical Practice Individualized Education

Plan, M3 Summative Assessment, M3 Student Self-Assessment of

Program Objectives, M4 Summative Assessment, Summative Narrative

Assessment, OSCEs, Patient and Procedure Logs, ALG Student

Assessments, Note Review (Psychiatry)

Assess, implement and

promote plans of disease

prevention, management and

treatment using evidence-

based medicine (PC5)

M3 Summative Assessment, M3 Student Self-Assessment of Program

Objectives, M4 Summative Assessment, Summative Narrative

Assessment, OSCEs, Patient and Procedure Logs, ALG Student

Assessments, M4 Resuscitation and Basics of Critical Care Oral

Examination, Note Review (Psychiatry), Neurology H&P/Consult

Scoring Rubric

Acknowledge, respect, and

integrate patients' and

families' lived experiences,

trauma, socio-cultural

background, and personal

values in clinical practice to

reduce health care disparities

(PC6)

Ambulatory Clerkship Behavior Assessment, M3 Summative

Assessment, M4 Summative Assessment, Scholars Workshop Module

Assessment

General Competency: Professionalism

Students will strive for excellence with regards to the enduring elements of professionalism, demonstrate a

commitment and an ability to perform their responsibilities with respect, compassion and integrity,

unconditionally in the best interest of patients

Medical Education

Program Objectives

Outcome Measure(s)

Demonstrate compassion,

empathy, honesty, and

respect for others (P1)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Clinical Skills Examinations [mini-OSCEs],

Foundations of Medical Practice Individualized Education Plan M3

Summative Assessment, M3 Student Self-Assessment of Program

Objectives, M4 Summative Assessment, Summative Narrative

Medical Education

Program Objectives

Outcome Measure(s)

Assessment, M4 Student Self-Assessment of Program Objectives,

OSCEs, Ambulatory Clerkship Satellite Assessment, Report of Service

Learning Hours, Required Session Attendance/Participation, M4

Resuscitation and Basics of Critical Care Oral Examination, Note

Review (Psychiatry), M3 Pediatric Outpatient/Subspecialty Assessment,

M3 Pediatric Mother-Infant Unit Assessment

Respect patient

confidentiality, dignity,

autonomy, and maintain a

professional relationship.

(P2)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Clinical Skills Examinations [mini-OSCEs],

Foundations of Medical Practice Individualized Education Plan, M3

Summative Assessment, M4 Summative Assessment, Summative

Narrative Assessment, OSCEs, Ambulatory Clerkship Satellite

Assessment, Required Session Attendance/Participation, M4

Resuscitation and Basics of Critical Care Oral Examination, Note

Review (Psychiatry)

Show responsiveness,

professional competence, and

personal accountability to

patients, society and the

practice of medicine (P3)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Clinical Skills Examinations [mini-OSCEs],

Foundations of Medical Practice Individualized Education Plan, M3

Summative Assessment, M4 Summative Assessment, Summative

Narrative Assessment, OSCEs, Ambulatory Clerkship Satellite

Assessment, Required Session Attendance/Participation, M4

Resuscitation and Basics of Critical Care Oral Examination, Note

Review (Psychiatry), Scholars Workshop Module Student Assessments

Advocate for patients’

interests and the healthcare

of others (P4)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Clinical Skills Examinations [mini-OSCEs],

Foundations of Medical Practice Individualized Education Plan, M3

Summative Assessment, M4 Summative Assessment, Summative

Narrative Assessment, OSCEs, Ambulatory Clerkship Satellite

Assessment, Required Session Attendance/Participation, Note Review

(Psychiatry), Scholars Workshop Module Student Assessments, M3

Pediatric Outpatient/Subspecialty Assessment, M3 Pediatric Mother

Infant Unit Assessment, Student Presentations

Recognize and manage

personal limitations, conflicts

of interests and biases,

including awareness of

personal well-being and of

strategies and resources to

address burn-out (P5)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Clinical Skills Examinations [mini-OSCEs],

Foundations of Medical Practice Individualized Education Plan, M3

Summative Assessment, M4 Summative Assessment, Summative

Narrative Assessment, OSCEs, Ambulatory Clerkship Satellite

Assessment, Required Session Attendance/Participation, Note Review

(Psychiatry)

Medical Education

Program Objectives

Outcome Measure(s)

Incorporate the principles of

medical ethics, and of

professional and personal

responsibility into their care

of patients (P6)

Ambulatory Clerkship Behavior Checklist Assessment, M3 Summative

Assessment, M4 Summative Assessment, Summative Narrative

Assessment, OSCEs, Ambulatory Clerkship Satellite Assessment,

Required Session Attendance/Participation, Note Review (Psychiatry)

Recognize and address

disparities in the distribution

of health resources and

advocate for equitable access

to care (P7)

Ambulatory Clerkship Behavior Checklist Assessment, M3 Summative

Assessment, M4 Summative Assessment, Summative Narrative

Assessment, OSCEs, Ambulatory Clerkship Satellite Assessment, WoW

1 Lean Six Sigma Presentation, Required Session

Attendance/Participation, Note Review (Psychiatry), Scholars Workshop

Module Student Assessments

Continually identify,

acknowledge and challenge

our individual implicit biases

and their impact on patient

care and professional

relationships (P8)

Ambulatory Clerkship Behavior Checklist Assessment, M3 Summative

Assessment, M4 Summative Assessment,

General Competency: Interpersonal and Communication Skills

Students will demonstrate an ability to effectively communicate and collaborate with patients, families and

healthcare professionals

Medical Education

Program Objective(s)

Outcome Measure(s)

Demonstrate effective

interpersonal and

communication skills and

cultural competency with

patients about their care,

including ethical and

personal issues (ICS1)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Clinical Skills Examinations [mini-OSCEs],

Foundations of Medical Practice Individualized Education Plan, M3

Summative Assessment, M3 Student Self-Assessment of Program

Objectives, M4 Summative Assessment, Summative Narrative

Assessment, M4 Student Self-Assessment of Program Objectives,

OSCEs, M4 Resuscitation and Basics of Critical Care Oral Examination

Demonstrate effective

interpersonal and

communication skills and

cultural competency with

patient’s family, friends, and

other members of the

patient’s community, as

appropriate (ICS2)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Clinical Skills Examinations [mini-OSCEs],

Foundations of Medical Practice Individualized Education Plan, M3

Summative Assessment, M4 Summative Assessment, Summative

Narrative Assessment, OSCEs, M3 Pediatric Outpatient/Subspecialty

Assessment, M3 Pediatric Mother-Infant Unit Assessment

Medical Education

Program Objective(s)

Outcome Measure(s)

Demonstrate effective

interpersonal and

communication skills and

cultural competency with all

members of the healthcare

team and relevant agencies

and institutions (ICS3)

Ambulatory Clerkship Behavior Checklist Assessment, M3

Transdisciplinary Presentation Rubric, M3 Summative Assessment, M4

Summative Assessment, Summative Narrative Assessment, OSCEs,

Ambulatory Clerkship Satellite Assessment, WoW 1 Lean Six Sigma

Presentation, Scholars Workshop Module Student Assessments, M3

Pediatric Outpatient/Subspecialty Assessment, M3 Pediatric Mother-

Infant Unit Assessment

Maintain a professional

demeanor of integrity and

transparency in all

communications (ICS4)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Clinical Skills Examinations [mini-OSCEs],

Foundations of Medical Practice Individualized Education Plan, M3

Transdisciplinary Presentation Rubric, M3 Summative Assessment, M4

Summative Assessment, Summative Narrative Assessment, OSCEs,

Report of Service Learning Hours, Scholars Workshop Module Student

Assessments

Model anti-racist and

inclusive behavior by

demonstrating

communication skills that

reject oppressive and

discriminatory language in

all of its manifestations and

promote educational dialogue

and discussion (ICS5)

Ambulatory Clerkship Behavior Assessment, M3 Summative

Assessment, M4 Summative Assessment, Scholars Workshop Module

Assessment

General Competency: Practice-Based Learning and Improvement

Students will demonstrate the ability to investigate and evaluate their care of patients, appraise and assimilate

scientific evidence, and continuously improve patient care, based on constant self-evaluation and life-long

learning

Medical Education

Program Objective(s)

Outcome Measure(s)

Assess their own strengths,

deficiencies and limits of

knowledge and engage in

effective ongoing learning to

address these (PrBLI1)

Peer and Self-Assessment, Ambulatory Service Learning Group

Discussion Roundtable, Ambulatory Clerkship Service Learning

Reflective Essays, Ambulatory Clerkship Behavioral Checklist,

Foundations of Medical Practice Individualized Education Plan, M3

Summative Assessment, M3 Student Self-Assessment of Program

Objectives, M4 Summative Assessment, Summative Narrative

Assessment, M4 Student Self-Assessment of Program Objectives, ALG

Student Assessments, Report of Service Learning Hours, Scholars

Workshop Module Student Assessments

Medical Education

Program Objective(s)

Outcome Measure(s)

Effectively engage in

medical school, hospital and

community projects that

benefit patients, society and

the practice of medicine

(PrBLI2)

Ambulatory Clerkship Service Learning Reflective Essays, M4

Summative Assessment, Summative Narrative Assessment, Report of

Service Learning Hours, Scholars Workshop Module Student

Assessments

Identify, appraise and

assimilate evidence from

scientific studies using

information technology

(PrBLI3)

M3 Transdisciplinary Presentation Rubric, M3 Summative Assessment,

M4 Summative Assessment, Summative Narrative Assessment, Scholars

Workshop Group Critical Appraisal Project, Scholars Workshop

Independent Capstone Project

Recognize and empower

other members of the

healthcare team in the

interests of improving patient

care (PrBLI4)

Ambulatory Clerkship Behavior Checklist Assessment, M3 Summative

Assessment, M3 Student Self-Assessment of Program Objectives, M4

Summative Assessment, Summative Narrative Assessment, M4 Student

Self-Assessment of Program Objectives, M4 Resuscitation and Basics of

Critical Care Oral Examination

Apply the principles and

practices of patient safety

and quality improvement,

including process and

performance improvement

strategies (PrBLI5)

M3 Summative Assessment, M4 Summative Assessment, Summative

Narrative Assessment, M4 Student Self-Assessment of Program

Objectives, Scholars Workshop Projects, WoW 1 Lean Six Sigma

Presentation, Virtual Critical Care Rounds-I (VCCR-I) Post Test

General Competency: Systems-Based Practice

Students will demonstrate an awareness of responsiveness to the larger context and system of healthcare, as

well as the ability to effectively utilize other resources in the system to provide optimal healthcare

Medical Education

Program Objective(s)

Outcome Measure(s)

Work effectively to

coordinate patient care within

the social context of

healthcare (SBP1)

Ambulatory Clerkship Behavior Checklist Assessment, M3 Summative

Assessment, M3 Student Self-Assessment of Program Objectives, M4

Summative Assessment, Summative Narrative Assessment, M4 Student

Self-Assessment of Program Objectives, Note Review (Psychiatry)

Incorporate risk-benefit

analysis into care delivery

(SBP2)

Ambulatory Clerkship Behavior Checklist Assessment, M4 Summative

Assessment, Summative Narrative Assessment, M4 Student Self-

Assessment of Program Objectives, Note Review (Psychiatry)

Advocate for high-quality

patient care (SBP3)

Ambulatory Clerkship Behavior Checklist Assessment, M3 Summative

Assessment, M3 Student Self-Assessment of Program Objectives, M4

Summative Assessment, Summative Narrative Assessment, M4 Student

Self-Assessment of Program Objectives, Note Review (Psychiatry)

Medical Education

Program Objective(s)

Outcome Measure(s)

Work in inter-professional

teams to enhance patient

safety and quality (SBP4)

Ambulatory Clerkship Behavior Checklist Assessment, M3 Summative

Assessment, M3 Student Self-Assessment of Program Objectives, M4

Summative Assessment, Summative Narrative Assessment, M4 Student

Self-Assessment of Program Objectives, WoW 1 Lean Six Sigma

Presentation

Demonstrate an appreciation

for and understanding of the

methodologies used to reduce

errors in care (SBP5)

M3 Summative Assessment, M4 Summative Assessment, Summative

Narrative Assessment, Scholars Workshop Projects

Recognize the value,

limitations and use of

information technology in the

delivery of care (SBP6)

Ambulatory Clerkship Behavior Checklist Assessment, M3 Summative

Assessment, M3 Student Self-Assessment of Program Objectives, M4

Summative Assessment, Summative Narrative Assessment, M4 Student

Self-Assessment of Program Objectives

Apply an understanding of

the financing and economics

of care delivery regionally,

nationally, and globally to

optimize the care of patients

(SBP7)

Faculty Developed Examination Questions, M4 Summative Assessment,

Summative Narrative Assessment, Scholars Workshop Module Student

Assessments

Recognize the inequitable

systems that affect

individuals directly and

indirectly within medical

training and practice (SBP8)

Ambulatory Clerkship Behavior Assessment, M3 Summative

Assessment, M4 Summative Assessment, Scholars Workshop Module

Assessment

Understand the historical

context and prevalence of

institutional and structural

racism in medicine and how

it contributes directly to

health disparities and

transgenerational trauma

(SBP9)

Ambulatory Clerkship Behavior Assessment, M3 Summative

Assessment, M4 Summative Assessment, Scholars Workshop Module

Assessment

Recognize and address issues

in diversity in medical

education, patient care, and

beyond and demonstrate

leadership in diversity,

equity, and inclusion in the

medical profession (SBP10)

Ambulatory Clerkship Behavior Assessment, M3 Summative

Assessment, M4 Summative Assessment, Scholars Workshop Module

Assessment

General Competency: Scholarly Inquiry

Students will demonstrate an ability to frame answerable questions, collect and analyze data and reach critically-

reasoned, well-founded conclusions in order to advance scientific knowledge in general and the care of individual

patients and populations

Medical Education

Program Objective(s)

Outcome Measure(s)

Demonstrate investigatory

and analytical skills to seek

and apply the best evidence

in making patient care

decisions (SI1)

Faculty Developed Examination Questions, Foundations of Medical

Practice Clinical Skills Examinations [mini-OSCEs], M3

Transdisciplinary Presentation Rubric, M3 Student Self-Assessment of

Program Objectives, M3 Summative Assessment, M4 Summative

Assessment, Summative Narrative Assessment, M4 Student Self-

Assessment of Program Objectives, Scholars Workshop Group Critical

Appraisal Project, Scholars Workshop Independent Capstone Project,

ALG Student Assessments, Scholars Workshop Module Student

Assessments, Virtual Critical Care Rounds-I (VCCR-I) Post Test,

Student Presentations

Design and execute studies to

answer well-structured basic,

translational, clinical, and

research questions (SI2)

M4 Summative Assessment, Summative Narrative Assessment, Scholars

Workshop Group Critical Appraisal Project, Scholars Workshop

Independent Capstone Project

Conduct research according

to good clinical practices and

strict ethical guidelines (SI3)

Faculty Developed Examination Questions, M4 Summative Assessment,

Summative Narrative Assessment, Scholars Workshop Independent

Capstone Project

Adhere to the principles of

academic integrity in

research and scholarship

(SI4)

M4 Summative Assessment, Summative Narrative Assessment, Scholars

Workshop Group Critical Appraisal Project, Scholars Workshop

Independent Capstone Project

Demonstrate skills that foster

lifelong learning (SI5)

Foundations of Medical Practice Individualized Education Plan, M3

Student Self-Assessment of Program Objectives, M4 Summative

Assessment, Summative Narrative Assessment, M4 Student Self-

Assessment of Program Objectives, ALG Student Assessments, Scholars

Workshop Module Student Assessments, Virtual Critical Care Rounds-I

(VCCR-I) Post Test, Student Presentations, M3 Transdisciplinary Rubric

General Competency: Health Partnership

Students will demonstrate the ability to deliver high-quality, comprehensive, cost-effective, coordinated Ambulatory

Care and community-oriented health education to underserved urban and rural populations

Medical Education

Program Objective(s)

Outcome Measure(s)

Recognize the social and

other determinants of health

(HP1)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Individualized Education Plan, M3 Transdisciplinary

Presentation Rubric, M3 Summative Assessment, M4 Summative

Assessment, Summative Narrative Assessment, Scholars Workshop

Module Student Assessments

Describe the healthcare needs

of patients from diverse

populations and develop

appropriately tailored care

delivery strategies (HP2)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Individualized Education Plan, M3 Summative

Assessment, M4 Summative Assessment, Summative Narrative

Assessment, Note Review (Psychiatry)

Develop the skills and

attitude to work in

partnership with members of

the community to promote

health, disease prevention,

and chronic care

management (HP3)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Individualized Education Plan, M3 Summative

Assessment, M4 Summative Assessment, Summative Narrative

Assessment

Appraise the impact of the

social and economic contexts

on healthcare delivery (HP4)

Ambulatory Clerkship Service Learning Reflective Essays, Ambulatory

Clerkship Behavior Checklist Assessment, Foundations of Medical

Practice Individualized Education Plan, M4 Summative Assessment,

Summative Narrative Assessment, Scholars Workshop Projects

General Competency: Learning and Working in Teams

Students will learn to work as a member of a team in the coordinated, inter-professional model of care delivery

Medical Education

Program Objective(s)

Outcome Measure(s)

Apply basic principles of

inter-professional and

multidisciplinary care

(Team1)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Individualized Education Plan, Life Stages TWA

Assessment, M3 Summative Assessment, M3 Student Self-Assessment

of Program Objectives, M4 Summative Assessment, Summative

Narrative Assessment, M4 Student Self-Assessment of Program

Objectives, TBL Scores (IRAT/GRAT), ALG Student Assessments,

Note Review (Psychiatry), POPs Scores, Jigsaw Scores, Scholars

Workshop Module Student Assessments

Develop the skills to

organize an effective

healthcare team, valuing

individuals’ skills and efforts

(Team2)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Individualized Education Plan, Life Stages TWA

Assessment, M3 Summative Assessment, M4 Summative Assessment,

Summative Narrative Assessment, TBL Scores (IRAT/GRAT), WoW 1

Lean Six Sigma Presentation, Jigsaw Scores

Medical Education

Program Objective(s)

Outcome Measure(s)

Work with professionals

from other disciplines or

professions to foster an

environment of mutual

respect and shared values

(Team3)

Ambulatory Clerkship Behavior Checklist Assessment, Foundations of

Medical Practice Individualized Education Plan, Life Stages TWA

Assessment, M3 Summative Assessment, M4 Summative Assessment,

Summative Narrative Assessment, TBL Scores (IRAT/GRAT), WoW 1

Lean Six Sigma Presentation, POPs Scores, Scholars Workshop Module

Student Assessments

Perform effectively in

different team roles to plan

and deliver patient and

population-centered care

(Team4)

Ambulatory Clerkship Behavior Checklist Assessment, Life Stages

TWA Assessment, M3 Summative Assessment, M3 Student Self-

Assessment of Program Objectives, M4 Summative Assessment,

Summative Narrative Assessment, M4 Student Self-Assessment of

Program Objectives, Ambulatory Clerkship Satellite Assessment, TBL

Scores (IRAT/GRAT), WoW 1 Lean Six Sigma Presentation, POPs

Scores, Jigsaw Scores, Scholars Workshop Module Student Assessments

Policies Related to Student Affairs

Honor Code Policy

POLICY: Honor Code

PURPOSE: This code of behavior is designed to assist in the personal, intellectual and professional development of the

medical student on the journey to becoming a physician and member of the medical community. All members of the

medical community must be accountable to themselves and others.

SCOPE: This policy applies to all CMSRU medical students and visiting medical students.

DEFINITIONS: The objective of the Honor Code is to foster an environment of trust, responsibility, and professionalism

among students and between students and faculty. Its fundamental goals are to promote ethical behavior, to ensure the

integrity of the academic enterprise, and to develop in students a sense of responsibility to maintain the honor of the

medical profession.

PROCEDURE: Students will abide by the CMSRU Honor Code which aims to foster an atmosphere of ethical and

responsible behavior and to reinforce the importance of honesty and integrity in the examination process and throughout

the medical school experience.

Student Responsibilities

Students will not:

● Give or receive aid during an examination.

● Give or receive unpermitted aid in assignments.

● Plagiarize any source in the preparation of academic papers or clinical presentations.

● Falsify any clinical report or experimental results.

● Infringe upon the rights of any other students to fair and equal access to educational materials.

● Violate any other commonly understood principles of academic honesty.

● Lie

No code can explicitly enumerate all conceivable instances of prohibited conduct. In situations where the boundaries of

proper conduct are unclear, the student has the responsibility to seek clarification from the Office of Student Affairs and

or the Office of Medical Education.

Each student has the responsibility to participate in the enforcement of this Code. Failure to take appropriate action is in

itself a violation of the Code.

The student must agree to participate in the enforcement of this Honor Code, and prior to matriculation, must sign a

statement agreeing to uphold its principles while enrolled at Cooper Medical School of Rowan University.

Professional Appearance Policy

POLICY:

Professional Appearance Policy

PURPOSE:

This policy is part of the overall emphasis on the importance of professionalism and defines appropriate attire and

appearance within that context.

SCOPE:

This policy applies to all CMSRU medical students and visiting medical students.

PROCEDURE:

This policy is based upon safety, concern for the patient, respect for others, an awareness of cultural competence, and the

central importance of professionalism in medicine. Recent trends in clothing, body art and body piercing may not be

generally accepted by your patients. Students must adhere to guidelines surrounding professional appearance, as outlined.

Clothing should be clean and neatly pressed. Note that CMSRU ID badges are to be worn at all times.

The following will outline the expectations of CMSRU in matters of professional appearance:

Phase I - During the majority of the first two years of the curriculum, students will spend time in lectures and small group

activities where attire should be comfortable, neat and not distracting. Avoid dress or attire that could be perceived as

offensive to others. During the WOW weeks, Ambulatory Clerkship, and when interfacing with patients at any Cooper

University Health Care (CUHC) facility students must follow the Dress Code Policy of CUHC stated below.

Phase II - During the last two years, all students will adhere to the Dress Code Policy of Cooper University Health Care

(8.604 Employee Relations-Employee Dress Code):

I. POLICY:

A. It is the policy of Cooper University Health Care to establish standards of dress, grooming and personal appearance.

Personal appearance should reflect a neat, professional, businesslike image and should be appropriate for the employee's

work situation. While Cooper understands that dress and appearance are often a matter of personal taste, Cooper must be

mindful of patient and employee safety as well as Cooper’s professional image. Therefore, Cooper maintains the right to

establish and enforce standards of dress, grooming and appearance as dictated by business need, interactions with patients

and other visitors. In addition to the traditional work setting, this policy applies to work related functions and events.

II. PURPOSE:

A. To set forth the standards of appropriate dress, grooming and appearance for employees and medical students.

III. PROCEDURE:

Dress code guidelines may vary by department, job function and location. Department dress codes may be more restrictive.

Cooper recognizes three (3) types of dress: business, business casual and uniforms. Management always reserves the right

to take appropriate action toward any employee whose grooming or dress violates the letter or the spirit of this policy.

Employees that appear for work inappropriately dressed will be sent home and directed to return to work in proper attire.

Under such circumstances, employees will not be compensated for time away from work and disciplinary action may be

taken.

A. General Guidelines

1. The Cooper identification badge is required to be worn at collar level with employee name and photo facing forward

and clearly visible at all times while working at any Cooper location. Badges must be free of obstacles so patients and

others can view the employee’s picture, name and job title. Lanyards should not be used unless they have a mechanism

to “break” in the back in the case of a safety issue. Lanyards must hang to allow visibility of the badge in the upper

chest area. Lanyards that are longer than upper chest area are not permitted. When off duty, the ID badge cannot be

worn at any Cooper location unless the employee is in compliance with the dress code.

2. All clothing should fit properly. Garments cannot be transparent, low cut at the neckline, or form fitting. Clothing

should not be unduly revealing or cause distracting or disruptive attention or reaction on the part of others.

3. Dresses and skirts cannot be excessively short, no more than 4 inches above the knee. Dress/skirt slits must not be

excessive.

4. Shirts/Blouses with lettering or graphics that advertise or promote a product or service or causes distracting attention or

reaction on the part of others will not be permitted. Only shirts/blouses with Cooper logo or approved graphics or

lettering are permitted.

5. Shoes must conform to safety and infection control standards by providing safe footing, protection against hazards and

be quiet for the comfort of patients. Examples of inappropriate footwear: canvas tennis shoes, sandals (i.e. open shoes

with straps including heels and flats), swim or beachwear and shoe covers. Leather sneakers may be worn only in

direct patient care areas. Socks or stockings must be worn in areas where we deliver direct patient care. Footwear must

be clean, polished and in good repair. Color and style of the shoes should be professional (neutral and/or in

coordination with clothing). In patient care areas, including ambulatory sites, open-toe shoes are not acceptable. In

non-patient care business areas, open-toe business style shoes are acceptable.

6. Hair, including facial hair, must be clean, neat, professional and maintained in a manner that does not interfere with

patient safety, infection prevention or equipment operation.

7. Fingernails must be clean and professional and maintained. For purposes of safety, infection prevention, and operation

of equipment, fingernails must be of a reasonable length for the performance of job functions. Employees having direct

and indirect patient contact or come into contact with the patient environment may not have fingernails in excess of ¼

inch in length and may not wear artificial fingernails, which is inclusive of gel nail polish, wraps, acrylics, silks, etc.

(Refer to 10.103 – Hand Hygiene Policy)

8. Tattoos must be modest and may need to be covered while at work in a manner that does not interfere with patient

safety, infection control or equipment operation. Tattoos shall be prohibited if they contain nudity, foul language, gang

symbols, convey an expression of hate, violate Cooper’s Harassment-Free Workplace Policy (See 8.615 Employee

Relations - Workplace Harassment and/or are inconsistent with a professional environment.

9. Earrings can be worn on the ears and generally should be no larger than one inch in diameter. Ear piercing will be

limited to a maximum of three (3) earrings per ear. Nose jewelry is discouraged and if worn, must be limited to one

small stud no larger than three (3) millimeters in diameter. Pierced jewelry and rings are not permitted on any other

visible body part (including but not limited to, eyebrows, lip and tongue). No ear gauges/expanders permitted.

10. Jewelry will be professional and kept to a minimum. Loose fitting jewelry that potentially poses safety issues is not

permitted.

11. The wearing of Cooper issued buttons or pins on a uniform is to be kept to a minimum and cannot be attached to or

conceal the Cooper identification badge.

12. Fragrances, perfumes, colognes, hair sprays, etc. should be kept to a minimum and may be prohibited if they pose a

health concern to others.

13. Head coverings (hats, caps, scarves, etc.) may be worn as part of the uniform when authorized or when required by

specific department standards or when required for safety or hygienic conditions. Employees whose religious, cultural

or ethnic beliefs require head covering, or employees who have special needs, may request an exemption and such

request will be given consideration for reasonable accommodation.

14. Sunglasses may not be worn indoors unless medically necessary.

15. The following are not considered appropriate dress:

a. Denim clothing of all colors

b. All types of shorts

c. Leggings/Spandex pants (unless worn under an appropriate dress)

d. Sweat jacket, pants, hoodie

e. Sweatshirts

f. Fleece jackets

g. Athletic clothing

h. Miniskirts

i. Beachwear

j. T-shirts

k. Tank tops or spaghetti strap shirts

l. Flashy, “loud” clothing

m. Lingerie-like clothing

n. Flip-flops/thong shoes

o. Pool shoes

16. Employees who require accommodation for medical or religious reasons should contact Human Resources.

B. Guidelines for employees who provide direct patient care, have direct patient contact or who work in patient care

areas:

1. Open toe shoes are not permitted. Heels must be of a reasonable height to perform assigned duties. Footwear is of

sturdy construction, well fitted and maintained in good repair. Flexible, non-slip soles are recommended in work

locations where use of liquids may increase the risk of falls.

2. Sleeveless shirts, blouses, and dresses are not permitted unless covered by a jacket or sweater.

3. Stockings or socks must be worn.

4. The length of pants/trousers must extend to the ankle.

5. When clothing is soiled with blood or body fluids, the clothes must be changed as soon as possible.

C. Guidelines for employees who do not provide direct patient care or do not have direct patient contact but may meet

with or be seen by patients/visitors.

1. Open toe shoes are permitted. Heels must be of a reasonable height to perform assigned duties. Footwear is of

sturdy construction, well fitted and maintained in good repair.

2. Sleeveless blouses and dresses are permitted.

3. Stockings or socks are optional.

4. The length of pants/trousers cannot be shorter than mid-calf.

D. Types of dress

1. Business Attire

a. In order to meet the expectations of patients and their families, Cooper must project a professional, business-

like image. Therefore, business attire is expected to be worn except where department specific dress

requirements, casual business attire or uniforms apply as outlined in sections 2 and 3 below. Business attire

includes such clothing as suits, ties, dresses, dress skirts and dress pants.

2. Business Casual Attire

a. A more casual or relaxed dress code will be permitted during the summer and on Fridays. Business casual

attire must still follow the guidelines outlined above and must be appropriate.

3. Uniforms

a. Uniforms may be required in specific areas. They will constitute regular business attire when approved by

management. Employees should consult with their individual Direct Supervisor for specific guidelines on

uniforms. Scrub uniforms may be worn with Departmental approval. Denim-like scrubs are not permitted.

Uniforms owned by Cooper must be returned upon separation of employment.

I. ATTACHMENTS

II. RELATED POLICIES

10.103– Hand Hygiene Policy

Professional Conduct Policy

POLICY:

Professional Conduct Policy

PURPOSE:

This policy is applied to student conduct relating to professional behavior while a student is enrolled at CMSRU. It is

expected that every student will follow the tenets of professional behavior both in and out of the classroom.

Professionalism is one of the CMSRU Core Competencies for students. It is also a code of behavior.

SCOPE:

Candidates for the Doctor of Medicine degree

DEFINITIONS:

Professionalism is broadly defined. It is expected that the tenets of professionalism will be applied beyond the elements of

the curriculum. It is expected to be a way of life for the health care professional. Student behavior and actions that are

considered unethical, unprofessional or illegal will be considered by CMSRU in the overall evaluation and promotion of a

student.

Core Competency: Professionalism: (as addressed and assessed within the curriculum) Students will demonstrate a

commitment to the profession of medicine and its ethical principles.

● Demonstrate humanism, compassion, integrity and respect for others

● Demonstrate a respect for patient confidentiality and autonomy

● Show responsiveness and personal accountability to patients, society and the practice of medicine

● Demonstrate the ability to respond to patient needs superseding self-interest

● Demonstrate sensitivity to broadly diverse patient populations

● Demonstrate the ability to recognize personal limitations and biases; know when and how to ask for help and do so

effectively

● Demonstrate the ability to effectively advocate for the health and the needs of the patient

● Show an understanding of the principles of medical ethics

● Demonstrate the ability to recognize and address disparities in health care

Professionalism Intervention Reports

Professionalism is assessed in all four years of the medical education program. Accordingly, course and clerkship directors

will evaluate each student’s professional attitudes and behaviors. Anyone may submit a written report describing any

incident that might reflect either unprofessional action(s) or behavior or exceptional professionalism. The Professionalism

Intervention Report forms are available in the student handbook and can also be accessed on CMSRU Blackboard, in the

Student Resources/Student Affairs section.

Professionalism Report for Exemplary Behavior

This form may be filed by anyone, including another student, when an incident of exemplary professional behavior is noted

involving a CMSRU student.

Retaliation

No student, faculty, resident, or staff member shall be subject to retaliation for filing a CMSRU Professionalism

Intervention Report or participating in an investigation regarding a report of unprofessional behavior. CMSRU prohibits

retaliation against a person who files a professionalism report or participates in the investigation of a professionalism

complaint or has assisted others who raised a complaint of professionalism.

Hearing Body for Student Rights (HBSR)

The Hearing Body for Student Rights shall have the responsibility for hearing allegations of matters of professionalism for

students, not related to a course or a clerkship, upon referral from the Director of Professionalism. The Hearing Body for

Student Rights recommends whether or not to uphold the decision of the Director of Professionalism. Their

recommendation goes to the executive cabinet, whose decision is binding. In addition, the Hearing Body for Student Rights

shall hear appeals of decisions impacting individual students made by committees working under the supervision of the

Office of Student Affairs. Their recommendation goes to the executive cabinet, whose decision is binding.

The Hearing Body for Student Rights shall consist of eleven members. Six members shall be from the faculty (three

members elected and three members appointed by the Dean); two phase 2 students shall be elected by their peers; the M4

president of student government shall serve as a member; the CMSRU Ombudsman and one member of the Office of

Student Affairs administration shall serve as ex-officio members. The term of office shall be three years, except where the

member serves as an ex- officio member. Phase 2 students will serve a term of two years; the M4 SGA president shall

serve one year. All student members must be in good academic standing as outlined in the Student Activities Policy.

Meetings shall be convened by the Chair or on request of the Dean or any member of the Committee. The Hearing Body

shall conduct all hearings and all deliberations in accordance with the policies of CMSRU.

GUIDELINES:

● By enrolling in CMSRU, a student accepts the professional standards of the school at all times.

● Each student must demonstrate appropriate standards of professional and ethical conduct, attitudes, and moral and

personal attributes deemed necessary for the practice of medicine.

● These behavior traits include, but are not limited to: honesty; integrity; willingness to assume responsibility; strong

interpersonal skills; compassion; good judgment; the absence of chemical dependency; and appropriate social, moral,

and personal behavior.

● Failure to meet these standards and requirements may cause CMSRU to impose sanctions that may include, but are

not limited to mandatory counseling, expulsion, disciplinary suspension or lesser sanctions.

● Students may face disciplinary action by CMSRU if they abuse alcohol or drugs, consume illegal substances, or

possess, distribute or sell illegal substances.

● Students involved in criminal matters before local, state or federal courts may be found to be unfit for the medical

profession and be expelled by CMSRU or face lesser disciplinary sanctions.

● Students are expected to comply with the laws of the United States, the State of New Jersey, county and city

ordinances and the lawful direction and orders of the officers, faculty, and staff of CMSRU who are charged with the

administration of institutional affairs.

PROCEDURE:

● Issues related to professionalism that relate to a course or clerkship are managed as per the Grading,

Promotions and Appeals Policy (GPA).

● Issues related to professionalism that occur outside of the curriculum that are unrelated to a course or

clerkship include, but are not limited to:

o Unprofessional behavior at a CMSRU sponsored social event or activity;

o Student to student mistreatment at social events or outside of CMSRU; and

o Vandalism or theft of CMSRU/Cooper University Health Care (CUHC) property or at an affiliate

hospital, physician practice or ambulatory clinic.

● Issues related to professionalism that occur outside of the curriculum, including the filing of a Professionalism

Intervention Report for Breach of Professional Conduct that is unrelated to a course or clerkship, will be

managed as follows:

o All matters will be reported to the Assistant Dean for Student Affairs;

o The Assistant Dean for Student Affairs will counsel the student and may refer the issue to the Director

of Professionalism;

o If the issue is referred to the Director of Professionalism, the student will be notified, and a meeting

will be scheduled with the student by the Director of Professionalism;

o The Director of Professionalism will investigate the issue and may provide a decision/remediation

plan to the student directly. Remediation plans of the Director of Professionalism are not appealable;

o The Director of Professionalism may recommend to the Dean or designee that a student be placed on

immediate leave for an issue related to professional behavior pending further investigation; and

o Depending on the severity and nature of the issue, the issue may be referred to the Academic Standing

Committee (ASC) (Refer to GPA Policy

: Probation – Non-Academic).

● If a student objects to the decision of the Director of Professionalism surrounding an issue that has been

determined as not rectifiable by a remediation plan, or that has not been referred to the ASC, the student may

appeal the decision to the Hearing Body for Student Rights. This request is made through the Director of

Professionalism.

o The Hearing Body for Student Rights will be convened at the request of the Director of

Professionalism;

o The student shall be given up to three business days’ notice of the time and place of the committee’s

hearing;

o At the discretion of the student making the appeal, one individual may accompany the student during

the hearing in the capacity of advisor and/or advocate. The advisor/advocate does not have a “voice”

at the hearing;

o All other advocacy efforts must be in the form of written communications to the committee and must

be received by the committee no later than 24 hours preceding the time scheduled for the start of the

appeals hearing;

o The Chair will communicate the recommendation of the Hearing Body for Student Rights to the

CMSRU Executive Cabinet within ten (10) business days. Decisions of the CMSRU Executive

Cabinet are considered as final and are not subject to appeal. If a recommendation by the HBSR is

dismissal, the executive cabinet will review and determine if the dismissal recommendation is

appropriate. If appropriate, the student will be referred to the ASC; and

o The Director of Professionalism will communicate the decision of the executive cabinet to the student.

● In addition, the Hearing Body for Student Rights shall hear appeals of decisions impacting individual students made by

ad hoc committees working under their supervision of the Office of Student Affairs. Their recommendation is sent to

the CMSRU Executive Cabinet for final decision.

o The Hearing Body for Student Rights will be convened at the request of the Asst. Dean for Student

Affairs (ADSA) or the Assistant Dean for Student Affairs;

o The student shall be given advance notice, up to three business (3) days, of the time and place of the

committee’s hearing;

o At the discretion of the student making the appeal, one individual may accompany the student during

the hearing in the capacity of advisor and/or advocate. The advisor/advocate does not have a “voice”

at the hearing;

o All other advocacy efforts must be in the form of written communications to the committee, and must

be received by the committee no later than 24 hours preceding the time scheduled for the start of the

appeals hearing;

o The chairperson will communicate the recommendation of the Hearing Body for Student Rights to the

CMSRU Executive Cabinet and the Dean within ten (10) business days. Decisions of the CMSRU

Executive Cabinet are final and not subject to appeal;

o The decision of the executive cabinet shall be communicated verbally and in writing to the Associate Dean

for Student Affairs/Assistant Dean for Student Affairs within ten (10) business days; and

o The Associate Dean for Student Affairs/Assistant Dean for Student Affairs shall communicate the final

decision to the student.

Policies Related to Medical Education

Student Attendance Policy

POLICY: Student Attendance

This policy outlines what constitutes an absence and the processes that apply when submitting an absence request and the

consequences of an unexcused absence.

PURPOSE: Students may have events occur during their medical education that will result in an absence from educational

activities or assessments sessions. The importance of the health and welfare of each student is paramount. It is necessary to

provide unambiguous expectations for active student participation in the educational program in a manner that is respectful

of and adaptable to these events, and allows students to plan their schedules responsibly. This policy outlines the

importance of in-person, active engagement among students and faculty and the process for anticipated and unanticipated

absences.

SCOPE: This policy applies to students at CMSRU in all four years.

DEFINITIONS: “Attendance” is defined as presence during the entire scheduled activity (as appropriate)

• Anticipated absence is defined as an absence that is expected and known about well in advance of the scheduled

activity (for example - religious holiday or important family event).

• Unanticipated absence is defined as an absence that is unexpected related to an illness or serious person matter.

• Unexcused absence is defined as an absence without reporting/logging the absence or being absent if the absence was

not approved.

PROCEDURE: Please note that all policies that apply to the medical education program are available in the CMSRU

Student Handbook. http://www.rowan.edu/coopermed/students/files/handbook.pdf

You will be notified when there is a revision to any policy during an academic year. Please address any questions you may

have about the medical education program policies to the Assistant Deans for Phase 1 or Phase 2 or the Senior Associate

Dean for Medical Education.

All absence requests are to be made using the Absence Request System in the CMSRU portal system.

http://cmsruapps.rowan.edu

; Login using your username and password, then from menu go to: Attendance - Create

Absence Request.

Phase I

First and Second Year Students

Your attendance and participation in all educational sessions is vital for your education, as well as that of your classmates.

CMSRU data demonstrates a significant relationship between student attendance at educational sessions and performance

in the medical education program and on the USMLE Step exams.

Students must submit an absence for all mandatory sessions. If a student is absent from a mandatory session and

has not logged/reported the absence, this will be considered as an unexcused absence.

1. All absences must be logged/reported by the student, as soon as they are aware they will be missing a mandatory

session. If it is an unanticipated absence, it must be submitted at least two (2) weeks prior to the session. If it is an

unanticipated absence it must be submitted as soon as the student is aware they will miss the session and should be

posted prior to the start of the session. All absences are monitored by the Office of Medical Education (OME). (Please

also see the Prolonged Absence Policy for extended absences).

1. Students will be notified by email of each absence reported in the system.

2. It is solely the student’s responsibility to ensure that their presence at required sessions is recorded, including

bringing their ID to swipe into a mandatory session. Students who forget their ID should immediately notify

the course director by email. Record absences due to failure to bring ID will not be retroactively excused.

2. Students should also contact the course director or session leader to determine the information they will be missing and

make it up.

a. Course/Clerkship director(s), at their full discretion, may require make-up work of course material missed during

absences, in any form that the course/clerkship director(s) chooses. Failure to submit this work may result in an

incomplete grade.

b. For anticipated absences involving Ambulatory Clerkship, WOW I and II, and Selectives, students must notify

their course/clerkship director(s) for prior approval before the absence.

3. For medical absences for three (3) consecutive dates (6 half days total) a doctor’s note will need to be provided to the

Office of Student Affairs (OSA) within three (3) days upon the student’s return.

4. Any absence on the day of an assessment will require the assessment to be rescheduled.

a. An unanticipated absence that includes an assessment on the day before an assessment will require a doctor’s note

within three (3) days upon the student's return. The documentation will be sent to the Assistant Dean for Student

Affairs. Only full day absences are allowed on assessment days. A score of zero (0) will be assigned if a doctor’s

note or proper documentation is not provided for any assessment.

i. Assessments must be rescheduled after the original date of the assessment. Summative assessments will not be

administered to any student or subset of students before the scheduled summative assessment date.

b. Students must contact their course/clerkship director and the Assistant Dean of Assessment and CQI so the

assessment can be rescheduled.

c. The Office of Medical Education staff members will then schedule the student to make-up the missed summative

assessment the next time the staff has a scheduled make-up summative assessment planned.

d. For absences occurring on assessment dates in more than three (3) courses during an academic year, the Assistant

Dean for Student Affairs will be notified, and a meeting with the student will be required.

5. The Office of Medical Education will monitor absence records.

a. No more than two (2) half-day absences are allowed per course; and no more than six (6) half-day absences total

are allowed per semester.

b. Students in the PC-3 program are not allowed more than two (2) half-day absences during the summer session.

c. Absences due to religious holiday observances will not be counted toward the total allowed absences.

d. Students re-entering the curriculum after the start of a semester will be allowed a prorated number of absences for

that semester. The student will be notified of the number of absences available at the time they enter the

curriculum.

6. If a student’s absences exceed the allowed numbers, or otherwise violate any of the policies above:

a. The Assistant Dean for Student Affairs will be notified and may require additional information from and\or a

meeting with the student to establish the reason for the repeated absences.

b. The Assistant Dean for Student Affairs will notify the course and/or clerkship director(s) as necessary.

c. The student may be referred to the Director of Professionalism.

7. If a student is found to have been absent from a mandatory session and did not log/report the absence, was not

approved for an absence and \or did not inform OSA/OME of their absence their grade in the enrolled course or

clerkship will result in an Unsuccessful Remediable (UR) grade. A course or clerkship director cannot overturn this

grade. The student will need to meet with the Assistant Dean of Phase I to discuss remediation plans. In addition, a

Professionalism Form will also be submitted for an unexcused absence.

**Please note: Referrals may also be made to the Director of Professionalism when:

• Students are excessively tardy.

• Students sign-in or swipe-in for a session and leave.

• Students sign-in or swipe-in for someone else.

• Students leave early during a required session.

Phase II

Third Year Students

The M3 Education Coordinator will monitor all absences for third year students.

Daily attendance and engagement in the clinical experience is critical for learning and assessment and is required on all

clerkships and electives.

All absences must be logged/reported by the student as soon as they are aware they will be missing a clinical

experience activity. If it is an unanticipated absence, it must be submitted at least two (2) weeks prior to the session.

If it is an unanticipated absence it must be submitted as soon as the student is aware they will miss clinical time.

In addition, the student must notify their clerkship/elective director, preceptor, and clerkship or elective coordinator of the

time they will miss. The clerkship/elective director and/or preceptor will then notify the student of the remediation for the

missed time.

If a student is absent for more than 2 days of any 6-week clerkship block during the third year, the time must be

made up (there are seven 6-week clerkships blocks in the M3 year).

Examples:

• If you missed 3 total days on your 6 week Pediatrics Clerkship, you would have to make up 1 of these days.

• If you are in a 6-week Anesthesiology/Neurology block (2 weeks of Anesthesiology/4 weeks of Neurology) you can

only be absent a total of two (2) days during the 6-week block.

*Exceptions to this rule:

• Certain individual activities or clinical experiences must be made up regardless of the number of absences when they

are a required component of the clerkship. These include, but are not limited to:

The following sessions cannot be missed:

• Transdisciplinary Sessions

• Ultrasound Sessions

• M3 formative OSCE

• M3 summative OSCE

• Shelf exam

Please refer to the clerkship syllabus to see any other absences which must be made up no matter the circumstance

(example – Ob/Gyn call time that is missed must be made up).

M3 One-Week Electives:

Absences of more than one half of a day of a one-week elective must be made up.

Ambulatory Clerkship:

• For absences involving the Ambulatory Clerkship third-year students must notify the ambulatory director (s) for prior

approval for the absence. Unexcused absences may be documented in the narrative section of the Ambulatory

Clerkship summative evaluation. A Professionalism Report may be completed for unexcused absences.

PC-3 Students:

• If a student has a total of 8 absences in an academic year, the M3 Education Coordinator will alert the Assistant Dean

for Student Affairs, who will then determine if a meeting is required to discuss reasons behind multiple absences

(Personal illness, family issues, etc.) and possible solutions. This is to ensure student welfare.

• For medical absences for three (3) consecutive dates, a doctor’s note will need to be provided to the Office of Student

Affairs within three (3) days upon the student’s return.

• Unexcused absences in the M3 or PC-3 year are unacceptable. If a student is found to have been absent from their

educational activities and did not log/report the absence, was not approved for an absence and \or did not inform

OSA/OME of their absence their grade in the enrolled clerkship will result in an Unsuccessful Remediable (UR) grade.

A course or clerkship director cannot overturn this grade. The student will need to meet with the Assistant Dean of

Phase II to discuss remediation plans. In addition, a Professionalism Form will also be submitted for an unexcused

absence. Per the Grading, Promotion, and Appeals (GPA) policy, any unexcused absence will automatically lead to

failing the clerkship/rotation and an Unsatisfactory (U) grade.

• An unanticipated absence that includes a shelf exam, or the day before a shelf exam, will require a doctor’s note within

three (3) days upon the student's return. The documentation will be sent to the Assistant Dean for Student Affairs. A

score of zero (0) will be assigned if a doctor’s note or proper documentation is not provided for any missed shelf exam.

• Any absence on the day of a shelf exam will require the assessment to be rescheduled. Assessments must be

rescheduled after the original date of the assessment. Summative assessments will not be administered to any student

or subset of students before the scheduled summative assessment date.

• Absences due to illness or serious extenuating circumstances occurring on the date of scheduled exams, must be

communicated to the Assistant Dean for Student Affairs and will require supporting documentation sent from a

physician within three (3) days of the absence. Absence requests are to be made using the Absence Request System in

the CMSRU portal system

***Retroactive absences are absolutely not allowed (you cannot apply for an absence AFTER an absence occurs). This

will be considered an unexcused absence. Missed time will be made up and can lead to a Professionalism Report.

Fourth Year Students

The M4 Education Coordinator will monitor all absences for fourth year students.

Daily attendance is required on all clerkships and electives.

The M4 Academic year consists of 40 weeks, including eight (8) weeks that can be utilized for residency interviews,

vacation, and other personal time.

• These 8 weeks may be broken up into 4-week, 2-week, or 1-week time spots or can be taken as an entire 8 weeks, so

long as the 32 weeks of required clerkships/electives can be completed in the time frame to graduate. This time cannot

be taken within a clerkship / elective / Sub-Internship. For example – you cannot start your Sub-Internship and then

take a week off within the Sub-Internship block.

• Students who will be absent beyond the eight (8) weeks must email the Assistant Dean for Student Affairs for their

reason for the absence. The Assistant Dean for Student Affairs will alert the M4 Director and the M4 Education

Coordinator. Should the absence be excused, the student will be responsible to make up any missed time.

Absences during a Clinical Rotation:

All absences must be logged/reported by the student as soon as they are aware they will be missing a clinical

experience/activity. If it is an unanticipated absence, it must be submitted at least two (2) weeks prior to the session.

If it is an unanticipated absence it must be submitted as soon as the student is aware they will miss clinical time.

A. In addition, the student must notify their clerkship/elective director, preceptor, and clerkship or elective coordinator of

the time they will miss.

B. Absences for any reason during a fourth year clerkship/elective, must be made up at the discretion of the

clerkship/elective director. Remediation for the missed time can take the form of clinical time/patient care, writing a report

on a topic of the clerkship/elective director’s choosing, or any other educational activity that the clerkship/elective director

chooses.

C. F

ailure to complete missed time due to an absence will lead to an incomplete grade and possible failure of the

clerkship/elective.

D. For medical absences for three (3) consecutive dates, a doctor’s note will need to be provided to the Office of Student

Affairs within three (3) days upon the student’s return.

Absences due to Residency Interviews:

CMSRU wants to ensure students are able to go on residency interviews while obtaining the clinical knowledge and

experience necessary to succeed in residency. Below are the rules regarding interviews during a clerkship / elective / Sub-

Internship:

• Maximum of 4 excused days for residency interviews AND travel to and from your residency interviews in a 4 week

rotation.

• Maximum of 2 excused days for residency interviews AND travel to and from your residency interviews in a 2 week

rotation.

• Maximum of 1 excused day for residency interview AND travel to and from your residency interview in a 1 week

rotation.

• Excused days for residency interviews do not have to be made up, as long as they are within the limit.

o Exception – this only applies for rotations where you are required to come in every day. For rotations such as

Emergency Medicine and Pediatric Emergency Medicine where you are not required to report every day and you

work shifts, you will need to move your shifts so that you are not scheduled to work a shift on an interview day

You CANNOT use excused days for residency interviews for any other purpose. Inappropriate use of residency

interview days will be viewed as unprofessional behavior and will lead to a Professionalism Report and possible

failure of the Clerkship/Elective Rotation. Students may be required to present documentation of their

residency interview.

Absence due to Step 2 CK:

• Excused days for Step 2 do not have to be made up.

Unexcused absences in the M4 year are unacceptable. If a student is found to have been absent from their educational

activities and did not log/report the absence, was not approved for an absence and \or did not inform OSA/OME of their

absence their grade in the enrolled clerkship will result in an Unsuccessful Remediable (UR) grade. A course or clerkship

director cannot overturn this grade. The student will need to meet with the Assistant Dean of Phase II to discuss

remediation plans. In addition, a Professionalism Form will also be submitted for an unexcused absence. Per the Grading,

Promotion, and Appeals (GPA) policy, any unexcused absence will automatically lead to failing the clerkship/rotation and

an Unsatisfactory (U) grade.

Match Week:

• Students are REQUIRED to attend all Mandatory Match Week Sessions.

Conflict of Interest Policy

POLICY:

Conflict of Interest Policy

PURPOSE:

To establish guidelines for interactions between Industry and faculty, staff and students of Cooper Medical School of

Rowan University.

SCOPE:

This policy applies to all faculty, staff, and students of Cooper Medical School of Rowan University (CMSRU), to all

healthcare professionals and staff employed and/or contracted by Rowan University at CMSRU, and to all facilities owned

or controlled by Rowan University at CMSRU or in which faculty and trainees are working. In all cases where this policy

is more restrictive than Rowan University conflict of interest policies, this policy shall take precedence. This policy applies

to interactions with all sales, marketing or other product-oriented personnel of Industry, including those individuals whose

purpose is to provide information to clinicians about company products, even though such personnel are not classified in

their company as “sales or marketing.”

DEFINITIONS:

N/A

PROCEDURE:

CMSRU is committed to providing humanistic education in the art and science of medicine within an environment in

which excellence in patient care, innovative teaching, research and service to our community are valued. These goals

require that faculty, students, trainees and staff of CMSRU interact with representatives of pharmaceutical, biotechnology,

medical device and hospital equipment supply industry (hereinafter “Industry”), in a manner that advances the use of the

best available evidence so that medical advancements and new technologies become broadly and appropriately used. While

the interaction with Industry can be beneficial, Industry influence can also result in unacceptable conflicts of interest that

may lead to increased costs of healthcare, compromised patient safety, negative socialization of students and trainees, bias

of research results, and diminished confidence and respect among patients, the general public and regulatory officials.

Because provision of financial support or gifts may exert an impact on recipients’ behavior, CMSRU has adopted the

following policy to govern the interactions between Industry and CMSRU personnel (defined above under Scope). This

policy has been designed to reflect the best available literature on conflict of interest and is intended to provide guiding

principles that members of the CMSRU community as well as representatives of Industry can use to assure that their

interactions result in optimal benefit to clinical care, education, research, and maintenance of the public trust.

STATEMENT

OF THE POLICY:

It is the policy of CMSRU that clinical decision-making, education and research activities are free from influence created

by improper financial relationships with, or gifts provided by Industry. These general principles should guide interactions

and relationships between CMSRU personnel and Industry representatives. The following limitations and guidelines are

directed to certain specific interactions. For situations not specifically addressed, CMSRU personnel should consult in

advance with their deans, departmental chairs and/or their administrators to obtain further guidance and clarification.

SPECIFIC

ACTIVITIES:

1. Support of Continuing Education in the Health Sciences:

Industry support of continuing education (“CE”) in the health sciences can provide benefit to patients by ensuring that the

most current, evidence-based medical information is made available to healthcare practitioners. To ensure that potential for

bias is minimized, all CE events in which CMSRU participates as a co-sponsor must comply with the ACCME Standards

for Commercial Support of Educational Programs (or other similarly rigorous, applicable standards required by other

health professions), whether or not CE credit is awarded for attendance at the event. CMSRU conducts educational events

in conjunction with Cooper University Health Care (CUHC) as they have ACCME accreditation and abide by those

standards. All agreements for Industry support must be negotiated through and executed by the CUHC Department of

Continuing Education and must comply with all policies for such agreements. Industry funding for such programming

should be used to improve the quality of the education and should not be used to support hospitality, such as meals, social

activities, etc., except at a modest level.

Industry funding may not be accepted for social events that do not have an educational component. Industry funding may

not be accepted to support the costs of internal department meetings or retreats (either on or off campus). At CMSRU co-

sponsored Continuing Education programs, if there is an area utilized and designated for vendor displays, that area will be

separate from the location assigned for the educational presentations. All vendors are required to sign a CE agreement. Any

materials utilized by the industry vendors will be subject to the guidelines established in Section 3. Promotional materials

shall be limited to those which do not include product brand names and logos. Additionally, no gifts or enticements such as

food or snacks will be permitted at these displays.

2. Industry Sponsored Meetings or Industry Support of Off-campus Meetings:

CMSRU faculty, personnel, students or CMSRU providers or staff are discouraged from participating in or attending

Industry-sponsored meetings or other off-campus meetings where Industry support is provided. However, if they do attend

or participate:

a. The activity must be designed to promote evidence-based clinical care and/or advance scientific research;

b. The financial support of Industry must be prominently disclosed;

c. Industry may not pay attendees’ travel and expenses;

d. Attendees may not receive gifts or other compensation for attendance;

e. Meals provided must be modest (value comparable to Standard Meal Allowance as specified by IRS); and

f. If participating as a speaker, lecture content may not be promotional in nature but purely educational, its content

determined by the speaker and not industry, reflect a balanced assessment of the current science and treatment options,

and the speaker must make clear that the views expressed are the views of the speaker and not of CMSRU.

Additionally, compensation must be reasonable and limited to reimbursement of reasonable travel expenses and a

modest honorarium not to exceed $2,500 per event.

3. Gifts and Provision of Meals:

CMSRU personnel shall not accept or use personal gifts (including food) from representatives of Industry, regardless of

the nature or dollar value of the gift. Although personal gifts of nominal value may not violate professional standards or

anti-kickback laws, such gifts do not improve the quality of patient care, and research has shown they may subtly influence

clinical decisions and add unnecessary costs to the healthcare system. Gifts from Industry that incorporate a product or

company logo (e.g., pens, notepads or office items such as scales or tissues) introduce a commercial, marketing presence

that is not appropriate to a non-profit educational and healthcare system.

Meals or other hospitality funded directly by Industry may not be offered in any facility owned and operated by Rowan

University at CMSRU. CMSRU personnel may not accept meals or other hospitality funded by Industry, whether on-

campus or off-campus, or accept complimentary tickets to sporting or other events or other hospitality from Industry.

Modest meals provided incidental to attendance at an off-campus event that complies with the provisions of subsection 2,

above, may be accepted.

All full-time and part-time CMSRU faculty, as well as CMSRU medical students will act in accordance with CMSRU

policy at all times, including during time spent in the community with CMSRU clinical faculty.

Industry wishing to make charitable contributions to CMSRU may contact the Development Office. Such contributions

shall be subject to any applicable policies maintained by CMSRU.

4. Consulting Relationships:

CMSRU recognizes the obligation to make the special knowledge and intellectual competence of its faculty members

available to government, business, labor and civic organizations, as well as the potential value to the faculty member and

CMSRU. However, consulting arrangements that simply pay CMSRU personnel a guaranteed amount without any

associated duties (such as participation on scientific advisory boards that do not regularly meet) shall be considered gifts

and are consequently prohibited. Consulting or advising relationships for purely commercial or marketing purposes are

discouraged, while consulting or advising relationships for research and scientific activities are permissible.

To avoid gifts disguised as consulting contracts, where CMSRU personnel have been engaged by Industry to provide

consulting services, the consulting contract must provide specific tasks and deliverables, with payment commensurate with

the tasks assigned and at fair market value. All such arrangements between individuals or units and outside commercial

interests must be reviewed and approved by the Associate Dean for Research or departmental chair prior to initiation in

accordance with appropriate CMSRU policies. For employees of Rowan University at CMSRU who are not faculty, prior

written approval of the appropriate supervisor within CMSRU is required for any outside consulting. CMSRU reserves the

right to require faculty and employees to request changes in the terms of their consulting agreements to bring those

consulting agreements into compliance with CMSRU policies.

5. Frequent Speaker Arrangements (Speakers Bureaus):

While one of the most common ways for CMSRU to disseminate new knowledge is through lectures, “speakers bureaus”

sponsored by Industry may serve as little more than an extension of the marketing department of the companies that

support the programming. Before committing to being a speaker at an Industry-sponsored event, careful consideration

should be given to determine whether the event meets the criteria set forth in Section 2 of this policy, relating to Industry

Sponsored Meetings. CMSRU personnel may not participate in, or receive compensation for, talks given through a

speaker’s bureau or similar frequent speaker arrangements if any of the following are true:

a. Events do not meet the criteria of Section 2;

b. Content of the lectures given is provided by Industry or is subject to any form of prior approval by either

representatives of Industry or event planners contracted by Industry;

c. Content of the presentation is not based on the best available scientific evidence;

d. Company selects the individuals who may attend or provides any honorarium or gifts to the attendees; and

e. Under no circumstances may CMSRU personnel be listed as co-authors on papers ghostwritten by Industry

representatives. In addition, CMSRU personnel should always be responsible for the content of any papers or talks that

they give, including the content of slides.

Speaking relationships with company or company event planners are subject to review and approval of the participant’s

department chair, or dean as delineated in Section 4, Consulting Relationships.

6. Ghostwriting:

Under no circumstances may CMSRU personnel be listed as co-authors on papers ghostwritten by Industry representatives.

In addition, CMSRU personnel should always be responsible for the content of any papers or talks that they give, including

the content of slides.

7. Industry Support for Scholarships or Fellowships and other Educational Funds to Students and Trainees:

CMSRU may accept industry support for scholarships and discretionary funds to support trainee or student travel or non-

research funding provided that the following criteria are met:

a. Industry support for scholarships and fellowships must comply with all CMSRU requirements for such funds,

including a written pledge agreement through the Development Office. It will be maintained in an appropriate

restricted account, managed at the school as determined by the dean. CMSRU will select the recipients of such funds

with no involvement by the donor industry. Written documentation of the selection process will be maintained.

b. Industry support for other student or trainee activities, including travel expenses or attendance fees at conferences,

must be accompanied by a written agreement and will only be accepted into a common pool of discretionary funds,

which will be maintained under the direction of the dean. Industry cannot designate contributions to fund specific

recipients or specific expenses. Departments may apply to use monies from this pool to pay for reasonable travel and

tuition expenses for students, or other trainees to attend conferences or training that have legitimate educational merit.

Recipients will be selected by the department based on merit and/or financial need. Proper documentation must

accompany the request.

c. Final approval and possible exceptions shall be at the discretion of the dean.

8. Samples:

Utilization of drug or device samples at CMSRU run clinics will be judicious and cost-effective. Utilization of drug

samples will be at the discretion of the appropriate medical care provider solely for the purpose of patient care (e.g.,

allowing patients to begin early treatment; testing a therapeutic option prior to filling a prescription; offering an alternative

for individuals having difficulty affording their medicines). Utilization of equipment or device samples will be deemed

appropriate when healthcare practitioners are developing a familiarity with new materials. Samples of any kind are not

intended for personal use by faculty, staff or students. The sale or trade of any industry related sample is strictly prohibited.

Wherever possible, a central distribution and documentation site for medication samples should be established in each

healthcare facility that maintains storage of such samples. Samples should be logged in through a designated and secure

sample storage process. Logs should include the name of the medication, lot number, expiration date, date of receipt,

quantity received, and the name of the individual receiving the samples, including those received on behalf of a group

practice. Logs will be maintained in the healthcare facility for a specified time as designated per policy. All samples will be

labeled and dispensed in accordance with federal and state laws. A Sample Medication Form will be used to document

dispensing information, patient counseling and auxiliary notes. Utilization of vouchers is preferable to actual physical drug

samples. The preferred method of obtaining pharmaceuticals for indigent patients would be through specific corporate

plans which provide such product directly to the patient.

9. Site Access for Industry Representatives:

All Industry professionals wishing to gain access to CMSRU designated sites will be required to check into the facility

through a centralized, appointed individual. Purposes which are appropriate for site visits include the exchange of scientific

information, dissemination of materials/information regarding new therapeutic options, and training or discussions which

can lead to the advancement of healthcare. Name badges are required for all Industry personnel when visiting a CMSRU

site. Industry representatives are prohibited from roaming areas frequented by faculty or students. They may provide

informational material, such as product literature or journal articles, only at the request of a faculty or staff member.

Prior to gaining access, the individual must have a scheduled appointment with appropriate CMSRU personnel. There may

be designated times for Industry representatives to convene in a specific location as pre-determined by department heads in

order for questions to be answered or for information to be distributed regarding new equipment or therapeutic options.

Any marketing activities will be limited as per sections 1 and 3 of this policy.

Upon an initial visit to a CMSRU site, industry representatives will be provided a vendor policy sheet which will outline

procedures that they must follow while visiting the facility.

10. Conflict-of-Interest Disclosure:

CMSRU faculty and staff will disclose all ties to Industry on an annual basis using either the CUHC and/or Rowan

University Conflict of Interest disclosure form, depending on the employer of record. Additionally, any CMSRU faculty

and staff lecture must disclose all Industry ties to trainees and/or audience that could potentially influence their clinical or

educational duties.

11. Conflict-of-Interest Curriculum for Medical Students

CMSRU is committed to educating its medical students about the ways that Industry may attempt to influence prescribing

and treatment habits of physicians. Toward that end, CMSRU has developed a conflict-of-interest curriculum that is

integrated within our Active Learning Groups (ALG), Scholar’s Workshop, and Foundation of Medical Practice. Methods

of instruction include lectures, small group discussions and panel discussions. The curriculum will aim to educate the

students on the impact that Industry marketing may have on physician practice, and how Industry may influence the

regulation and marketing of drugs and devices.

12. Policy Enforcement

Faculty and Staff: Any violations of this policy should be reported to the Rowan University Hotline (855-431-9967) or

http://rowan.edu/integrityline

, where it will be directed to the Conflict-of-Interest Committee. Possible consequences of

policy violation include but are not limited to: counseling, training, requiring repayment of monies acquired in violation of

policies, fines or termination.

Industry personnel: Any violations of this policy may be subject to any of the following disciplinary actions: warnings

issued to corporation and supervisory personnel (written &/or verbal); access to CMSRU revoked for offending

representative and other company personnel; and lengthy restriction by all personnel from any access to the property for

varying lengths of time.

Duty Hours Limitations Policy

POLICY:

Duty Hours Limitations Policy

PURPOSE:

The faculty and academic administrators of CMSRU recognize the need to balance the learning and wellbeing of CMSRU

students during their clinical clerkship education. Therefore, they have established this policy setting duty hours limitations

to which students must adhere in Phase 2 of the curriculum.

SCOPE:

This policy applies to all candidates for the Doctor of Medicine Degree (M.D.)

DEFINITIONS:

Duty Hours: as defined by the Accreditation Council for Graduate Medical Education (ACGME) website October 24,

2013.

“Duty hours are defined as all clinical and academic activities related to the program; i.e., patient care (both inpatient and

outpatient), administrative duties relative to patient care, the provision for transfer of patient care, time spent in-house

during call activities, and scheduled activities, such as conferences. Duty hours do not include self-directed learning time.”

Duty hours are explained at CMSRU as:

● Time spent in all clinical and scheduled educational activities.

o This includes:

▪ Patient care in hospital, office, skilled nursing facility, rehabilitation center, etc.

▪ Administrative activities related to the educational program

▪ Scheduled conferences; advisory college meetings; meetings with administrators, learning support specialists,

student affairs officers, etc.

▪ Approved research-related activities

o It excludes self-directed learning time.

A stint is defined as a continuous period of duty.

PROCEDURE:

I. PROCEDURE:

● Maximum hours of clinical and educational work per week:

o Students are allowed to work no more than 80 hours per week, averaged over 4 weeks.

o Students may be on-call in-house no more often than every third night.

● Maximum hours of clinical work and education per stint:

o Students must work no more than 24 hours of continuous scheduled time (clinical plus educational) per stint.

▪ The student may spend up to 4 hours of additional time per stint for activities related to patient safety and/or

education (maximum is 28 contiguous hours).

● Mandatory time free of clinical work and educational activities:

o Students must have at least 8 hours off between stints lasting less than 24 hours.

▪ Students may, of their own accord, choose to shorten this interval to check on a patient, but they cannot exceed the

80 hours per week maximum.

o Students must have at least 14 hours free of clinical work and scheduled educational activities after a 24-hour

continuous stint.

o Students must have at least one day in seven (averaged over 4 weeks) free of clinical work and scheduled educational

experiences.

II. RESPONSIBILITY

Implementation

1. Office of Medical Education and the Office of Student Affairs and Admissions

M3 and M4 students will complete a self-reported duty hour exception report, through the One45

curriculum

management system, at the end of each inpatient block, listing violations of the duty hour limitations policy during that

block, and the reasons for each violation. The Assistant Dean for Assessment and Continuous Quality Improvement

will report duty hour policy violations every month to the Associate Dean for Student Affairs and will report every

three months any patterns of violation to the Phase 2 Subcommittee of the Curriculum Committee. The Phase 2

Subcommittee of the Curriculum Committee provides reports to the curriculum committee.

2. Students

Students must comply with these duty hour limitations policies and procedures. Any student who repeatedly fails to

comply will meet with the Associate Dean for Student Affairs for counseling. Recalcitrant noncompliance may be

taken as evidence of unprofessional behavior (see Grading, Promotions and Appeals Policy, V.B.). Students may be

referred to the Director of Professionalism for review and possible remediation plan. The Director of Professionalism

may refer students directly to the Academic Standing Committee.

3. Faculty

Faculty members must encourage students to adhere to duty hour policies and procedures. Faculty members agree to

abide by the above duty hours limitations in the design and implementation of their courses and clerkships, and in the

supervision of CMSRU students. A faculty member who repeatedly encourages student noncompliance with the duty

hour limitations will meet with the assistant dean for curriculum phase 2 for counseling. Faculty members responsible

for a pattern of student violations of the duty hour limitations will meet with the dean, who may recommend revocation

of their faculty appointment.

Formative Feedback Policy

POLICY:

Formative Feedback

PURPOSE:

In its efforts to ensure excellent medical education and to provide for appropriately timed formative feedback to medical

students the following policy defines the requirements for course directors, clerkship directors and faculty to submit

formative feedback at the Cooper Medical School of Rowan University (CMSRU).

SCOPE:

Candidates for the Doctor of Medicine Degree (M.D.)

PROCEDURE:

RESPONSIBILITY:

It is the responsibility of the course and clerkship directors to ensure that all students receive formative mid-course/mid-

clerkship feedback early enough in each required course and clerkships to permit remediation prior to the awarding of final

grades. The assessment subcommittee of the curriculum committee reviews and approves all assessment activities within

courses and clerkships and ensures that formative assessment activities appropriate to the course or clerkship are provided

for. Courses and clerkships less than four weeks use meetings with students to provide formative feedback.

All course and clerkship assessments are monitored by the Office of Medical Education. Course or clerkship directors who

are not compliant with these assessments will be reported to the Senior Associate Dean for Medical Education. The Senior

Associate Dean for Medical Education can ask the department chairperson to complete assessments for a course or

clerkship to ensure timely compliance.

Grading, Promotions, and Appeals Policy

POLICY: Grading, Promotions, and Appeals Policy

PURPOSE:

The faculty and academic administrators of CMSRU (CMSRU, School) recognize their responsibility to maximize the

probability that graduates of the school are qualified and have the maturity and emotional stability to assume the

professional responsibilities implicit in the receipt of the degree of Doctor of Medicine. Therefore, they have established

these policies to guide themselves and medical student colleagues in pursuing a level of academic and professional

excellence required for the conferral of that degree. Specific procedures have been established to provide uniformity and

equity of process in all situations requiring administrative action.

SCOPE: Candidates for the Doctor of Medicine Degree (M.D.)

DEFINITIONS:

This document deals with those students who are candidates for the MD degree.

Remediation: A defined process created by a course or clerkship director to ensure that a student who fails a course or

clerkship has subsequently gained the knowledge and skills required. The process is tailored to the student and consists of

activities to improve competency through reassessment.

Appeal: A petition filed by a student challenging a course or clerkship grade, a clinical assessment in the M3 year, time in

program, and promotional decisions. An action in favor of a student does not imply wrongdoing by the faculty or the

administration.

Promotional

decisions: The Academic Standing Committee reviews students annually or on an as-needed basis to advance

them in the medical education program, certify them for graduation, or consider them for dismissal.

Academic or performance improvement plan:

A defined plan developed by the Office of Medical Education and/or the

CMSRU Executive Deans for students whose appeal regarding a promotional decision has been upheld by the Academic

Standing Committee or the Ad Hoc Committee for Student Appeals. The improvement plan is developed to ensure that a

student who fails to complete the courses and/or clerkships in a medical education program year will have successfully

completed the failed courses and/or clerkships and demonstrated competence in the knowledge or skills required to move

to the next level in the medical education program. The process is tailored to the student and addresses academic or other

deficiencies related to their academic or professional performance. A student may be required to meet special conditions

or take an extra academic year as part of their plan. An academic improvement plan is not an adverse action and, therefore,

not subject to appeal.

Final grade: A grade entered into the academic transcript at the end of a course or clerkship or at the resolution of a grade

appeal.

I. RESPONSIBILITY

Implementation

1. Faculty

The faculty is responsible for implementing grading policies, regulations and procedures. For the courses or clerkships for

which they are responsible, faculty members:

a. establish standards to be met for attaining course or clerkship credit and criteria for assigning

specific grades, and

b. assign final grades for the course or clerkship within six weeks of the last day of the course or

clerkship.

2. The senior associate dean for medical education

The senior associate dean for medical education administers the grading and promotion policy regulations and procedures

with the support of the assistant dean for curriculum for phase 1 and the assistant dean for curriculum for phase 2, as

appropriate.

3. Academic Standing Committee

The Academic Standing Committee hears student grade appeals and communicates its decision to the senior associate dean

for medical education. The Committee reviews student progress and makes decisions regarding the placement on and

removal from academic and non-academic probation. The Committee makes recommendations for certification of the

graduating class to the departmental chairs, who review and approve on behalf of the faculty. The Committee also makes

recommendations to the dean about student promotions and decisions regarding dismissal. Students have the right to

appeal all promotional decisions made by the Academic Standing Committee. Committee members who have a significant

relationship with a CMSRU student who is under review for a potential adverse action by the Academic Standing

Committee, must recuse themselves from hearing that particular case.

4. Ad Hoc Committee for Student Appeals

The Ad Hoc Committee for Student Appeals is convened by the senior associate dean for medical education to hear

appeals of promotional decisions by the Academic Standing Committee. It is composed of five members of the faculty

who are not advisory college directors, members of the Academic Standing Committee, or the Curriculum Committee.

This committee is advisory to the dean.

5. Executive Cabinet of Deans

The Executive Cabinet of Deans at CMSRU are composed of all the associate and assistant deans at CMSRU. This group

may develop Academic Improvement or Performance Improvement Plans for students.

II. COURSE REQUIREMENTS, SEQUENCING, AND GRADUATION

All required courses of all curricular years, including the required number of elective weeks, must be completed

satisfactorily in the prescribed sequence before a student can be certified for graduation. A student may not repeat a course

or clerkship more than once, and no more than three distinct academic years may be utilized to fulfill the requirements of

either the first and second years (Phase 1), or the third and fourth years (Phase 2) of the curriculum. Students enrolled in

the Student Scholar Year opportunity or an Independent Study are considered to be enrolled in the academic program, and

this year counts as completed time in Phase 1 or 2 of the curriculum. Total time in each Phase cannot exceed four years,

allowing a maximum degree completion time of eight years. This includes any time spent in a leave of absence or

independent study. Students who perform scholarly work or enroll in dual degree programs (e.g., MD/PhD) may extend

their MD degree total time completion limit from six distinct academic years to ten distinct academic years upon the

approval of the Academic Standing Committee. Students pursing a PhD or other combined degree programs after their 2

year must have passed all Phase 1 courses/clerkships and taken Step I prior to starting their PhD/additional degree

program.

The medical school curriculum builds on the essential knowledge and skills required for the practice of medicine and

therefore certain courses/clerkships must be taken in a particular sequence. In Phase 1, the successful completion of both

Molecular Basis for Medicine (MBM) and Microbiology, Immunology and Infectious Disease (MIID) is a pre-requisite for

all other basic science block courses. In addition, successful completion of the Neuro-psych basic science block is a pre-

requisite for the SMS basic science block. Foundations of Medical Practice (FMP), must be taken with their corresponding

basic science blocks and Scholars Workshop must be taken in sequence. Students must complete and Pass Phase 1 of the

curriculum, as well as take USMLE Step 1 prior to starting Phase 2. Student must complete and pass all required clinical

clerkships before starting 4

year required courses. A grade of UR, U, I or W (see below) is not considered a Passing

grade.

Of important note, most state licensing boards require the completion of USMLE Steps 1, 2, and 3 within a seven-year

period. Step 3 is usually taken during the first or second year of postgraduate training. All students should be familiar

with the medical licensing requirements for the States where they intend to practice medicine, and if a waiver of the seven-

year requirement is possible.

Any requests to extend the academic program beyond the time limits noted above and for any reason, must be approved by

the Academic Standing Committee. Appeals of these decisions may be made to the Ad Hoc Committee for Student

Appeals.

Students returning from a Leave of Absence, Independent Study, or Student Scholar research experience of equal to or

greater than one academic year, will need to document their ability to resume patient care within the CMSRU medical

education curriculum. A student with significant degradation of clinical skills may need remediation prior to returning to

the medical education curriculum.

The Academic Standing Committee reviews all students to ensure that all graduation requirements have been met. The

graduation list is forwarded to the CMSRU Executive Council of departmental chairs for approval. Students are approved

for graduation in May of their M4 (final) academic year. A student who will complete all of their degree requirements

after the month of May can be awarded the M.D. degree at a later time in limited, special circumstances and as approved

by the Academic Standing Committee and the CMSRU Dean. If granted approval, students may graduate in August or

December of that same calendar year as the May graduation date. In limited circumstances, students, in their final year of

matriculation, may need to extend their expected date of graduation. Students will remain active in the Rowan University

system up to 18 months after their expected graduation date. No medical degree will be conferred more than 18 months

past the student’s expected graduation date, determined in the student’s fourth and final year, unless the student is on a

medical leave of absence. If the student does not meet all requirements for graduation within this 18 month period, the

student will no longer be eligible to receive the CMSRU Medical Degree (M.D.) (See the CMSRU Graduation Policy).

III. ASSESSMENT AND STANDING OF STUDENTS

A. Grading

All courses or clerkships, whether required or elective, and all research experiences specifically approved as part of an

individual student's curriculum must be graded according to the grading system for Phase 1 or Phase 2. Final grades must

be submitted to the registrar within six weeks of the completion of a course or clerkship. If the final grade for a course or

clerkship is a UR (unsatisfactory remediable) or a U (unsatisfactory), the assistant dean for assessment and CQI in the

Office of Medical Education informs the appropriate assistant curricular dean promptly by phone or email and submits that

information in writing within three weeks.

1. The CMSRU Grading System

Phase 1

The grading system for Phase 1 provides two levels of credit (Pass [P] and Remediated Pass [RP]) and four levels of non-

credit (Unsatisfactory [U], Unsatisfactory Remediable [UR], Incomplete [I], and Withdrawn [W]). Unsatisfactory is

equivalent to failure.

Phase 2

The grading system for Phase 2 provides four levels of credit (Honors [H], High Pass [HP], Pass [P], and Remediated Pass

[RP]) and four levels of non-credit (Unsatisfactory [U], Unsatisfactory Remediable [UR], Incomplete [I], and Withdrawn

[W]). The grading mechanism for each course will be detailed in the syllabus of that course or clerkship.

Incomplete (I)

Grades of Incomplete are applied at the school as described below:

• A course/clerkship director, following consultation with the appropriate phase dean, may assign the grade of I to

indicate that a student has been unable to complete all of the course requirements for a reason(s) beyond his/her control

(e.g., death in the family, significant illness or injury, etc.).

• When the grade of I is assigned to a course/clerkship, the student must complete the course/clerkship requirement

before progressing in any course that requires this course/clerkship as a prerequisite.

• Once the student has completed all course/clerkship requirements, the course/clerkship director must assign a final

grade (Phase 1 = P, UR, or U, Phase 2 = H, HP, P, UR or (U) in place of the I grade. If the requirements for the

incomplete course/clerkship have not been met within the appropriate final grade of U will be assigned.

Withdrawn (W)

If the student has withdrawn from a course or clerkship, the appropriate phase dean for medical education will assign a W

(Withdrawn) grade to the student's record.

M3 Courses/Clerkships:

Clerkship grades are based on student clinical performance and other components as noted in the individual syllabi for

each clerkship, including NBME examination scores. Each clerkship defines the score ranges for each of the grades listed

below.

Honors (H): is a clearly superior performance that reflects comprehensive achievement of course/clerkship objectives.

High Pass (HP): a performance well beyond minimum achievement of course/clerkship requirements.

Pass (P): a satisfactory performance that meets basic course/clerkship requirements including showing up on time,

knowing your patients, and demonstrating a desire to learn.

Remediated Pass (RP): a satisfactory performance that meets basic course/clerkship requirements upon the successful

completion of the remediation plan, following an unsatisfactory course grade (UR).

Unsatisfactory Remediable (UR): a temporary grade for a performance below acceptable minimum standards (grade less

than 70.00) which the student has been granted the opportunity to remediate. This grade can only be replaced by either an

RP or a U (see below).

Unsatisfactory (U): a final grade for student performance below acceptable minimum standards (grade less than 70.00)

• If a student repeats a curricular year, the final grade recorded on the transcript for the repeated course/ clerkship shall be

the actual grade earned (H, HP, P, or U). The original grades earned in previous academic years remains on the transcript

(including U grades).

M4 Courses/Clerkships:

The M4 courses and clerkships provides for grades of Honors (H), High Pass (HP), Pass (P), Unsatisfactory

Remediable (UR), and Unsatisfactory (U), except in the case of one and two-week electives which are graded as Pass

(P), Unsatisfactory Remediable (UR), and Unsatisfactory (U).

When written confirmation of a final grade for an M4 course/clerkship has not been received within seven days prior to the

student's scheduled graduation date from the school, the course or clerkship director in consultation with the appropriate

departmental chairperson, may assign an administrative Pass and have duly recorded on the student’s academic transcript

a final grade of P, if the student has met all requirements for that course/clerkship.

Leave of Absence Grading (M1 through M4):

If a student takes a leave of absence, the following policies will apply regarding grading courses/clerkships at the time of

the leave:

1. The student will receive a final grade for all courses/clerkships for which they have met all requirements in the course

or clerkship syllabus.

2. For courses/clerkships for which the student has not completed all requirements, the student will receive one of the

following grades.

Incomplete (I): Grades of incomplete are applied at CMSRU as described below:

a) Incomplete (I) if the student is assigned an I grade to a course/clerkship, that is a pre-requisite for progression, the

student must complete the course/clerkship requirement before progressing in the curriculum. The completion of

the course/clerkship cannot exceed one year from the completion date of the course/clerkship. If here is a

compelling reason that the course/clerkship can’t be completed within the timeframe above, the exception must be

approved by the academic standing committee.

b) Unsatisfactory Remediable (UR): If the student is assigned a UR grade for a course/clerkship and then begins a

Leave of Absence later in the same semester, the student must complete remediation of the course/clerkship before

returning to the curriculum. Any exceptions must be approved by the academic standing committee.

Withdrawn (W): Grades of W are applied for a course or clerkship and remain on the student's record. The Withdrawn

(W) will be issued if the student will not be completing the course/clerkship requirements and had not completed enough

work to determine performance at the time of the leave. The W grade remains permanently on the transcript.

3. No “credit” will be given for completion of a partial term’s work. A student who leaves in the middle of a term

without completing all course/clerkship requirements will receive a Withdrawn (W). The W grade will remain

permanently on the transcript. The student will be required to repeat and complete the course starting at the beginning

of the course when the student returns from leave. The course will be listed a second time on the transcript with the

final grade the student earns in that course in the academic year that it is taken.

Grading for students changing to Independent Study after a semester commences:

a) Incomplete (I): If the student is assigned an I grade to a course/clerkship, the student must complete the

course/clerkship requirement before returning to the curriculum. If there is a compelling reason that the

course/clerkship can’t be completed, the exception must be approved by the academic standing committee.

b) Unsatisfactory Remediable (UR): If the student is assigned a UR grade for a course/clerkship and then begins an

Independent Study later in the same semester, the student must complete remediation before returning to the

curriculum.

c) Withdrawn (W): For courses that the student has started but has not completed, a Withdrawn (W) grade will be

assigned. The W grade remains permanently on the transcript.

Narrative Assessments (M1 – M4)

When the teacher-student interaction permits, students will receive a narrative assessment as part of their evaluation in a

course or clerkship. In phase 1, students will receive a formative narrative assessment at the conclusion of each course,

lasting greater than or equal to four weeks. This formative narrative must be submitted to the office of medical education

within 6 weeks of the conclusion of the course/clerkship. Students will receive a summative narrative assessment at the end

of Phase 1. In Phase 2, students will receive a summative narrative assessment after all M3 clerkships, and after the

required clerkships in M4. This narrative assessment of each student’s performance must be submitted to the Office of

Medical Education within 6 weeks of the end of the clerkship. These narrative comments will become part of the academic

record and all summative narrative assessments will be included in the medical student performance evaluation (MSPE). In

Phase 1, narrative assessments are written by the active learning group (ALG) and Scholar’s Workshop (SW) facilitators

and by the course faculty for the Foundations of Medical Practice Course and Ambulatory clerkship. M3 and M4 clerkship

directors provide the narrative assessment in phase 2.

Errors in Statements of Fact in Narratives

If any student feels that there are errors of fact in their narrative, a request to have that narrative amended must be

submitted through the grade appeal process within three days of receiving the final course or clerkship grade.

Mid-course and Mid-Clerkship Feedback

Interim feedback from the ALG, SW, and FMP facilitators, clinical preceptors, and/or clerkship directors made directly to

the student are required during all courses and clerkships. Such interim feedback must be given at approximately the mid-

point of each course or clerkship when faculty communicate to each student information concerning the student's

performance to date and, as appropriate, recommendations for improvement.

B. Standing of Students

Students are placed into one of the following two categories by the Academic Standing Committee based upon their

academic performance:

1. In good standing

The status of “good standing” indicates that the student is eligible to continue at CMSRU, to return to CMSRU, or to

transfer elsewhere. It implies good academic progress as well as good citizenship.

2. Not in good standing

The status of “not in good standing” indicates that the student is not eligible to progress in the CMSRU medical education

program due to an academic or citizenship issue. If a student is on probation, they are “not in good standing” and must

successfully complete the requirements to be removed from probation to be able to have their status changed to “in good

standing”. Students who have been dismissed from CMSRU are unable to re-enroll at CMSRU.

All decisions made by the Academic Standing Committee regarding the standing of students are final. See Satisfactory

Academic Progress (SAP) policy regarding financial aid implications.

IV. THE PROMOTIONAL SYSTEM

A. Phase 1

Students are required to achieve final grades of Pass (P) or Remediated Pass (RP) in all prerequisite courses in order to

progress to the subsequent courses. Students must pass all Phase 1 courses/clerkships and take the USMLE Step 1

examination prior to beginning Phase 2.

• The passing grade for all courses in Phase 1 is 70.00 and minimal competency for all summative written and practical

examinations in a course is set at a score of 60.00. Any score on a summative written or practical examination below

60.00 will result in an unsatisfactory grade (U or UR) in the course, regardless of the overall course score.

• In M1 and M2 Foundations of Medical Practice, students must pass each end-of-year OSCE domain with a score of

greater than or equal to 60.00. A score below 60.00 will result in an unsatisfactory grade (U or UR), regardless of the

overall course score.

• A student who receives an unsatisfactory/remediable grade in 1or 2 courses in an academic year will be permitted the

opportunity to remediate the course(s)/clerkship(s) during the remediation period.

• A student who receives an unsatisfactory grade in 3 courses in an academic year in Phase I will be reviewed by the

Academic Standing Committee for probation, removal from the curriculum, repeat of the academic year, or dismissal

notwithstanding their remediation. A third remediation can take place only after the Academic Standing Committee

grants the student the ability to continue in the program.

• A student who chooses to repeat a year without having successfully completed all the academic requirements for that

year will be placed on academic probation since he/she has not successfully remediated the courses and is choosing to

repeat them.

• A student who fails to remediate an unsatisfactory grade in 1or 2 courses/clerkships will be placed on academic

probation and must repeat the course/clerkship in the subsequent year. A student may not advance to any course that

requires the uncompleted courses/clerkships as a prerequisite. If the student is unsuccessful in their repeated

course/clerkship, they will not be permitted to remediate the repeated course/clerkship and they will be reviewed for

dismissal by the Academic Standing Committee.

• A student who receives a final grade of unsatisfactory remediable (UR) grade in 3 or more courses/clerkships within

the same academic year will be reviewed by the Academic Standing Committee for dismissal. This is notwithstanding

any successful remediation of the courses or clerkships in which a UR grade was awarded.

• If a student is found to have been absent from a mandatory session and did not log/report the absence, was not

approved for an absence and/or did not inform OSA and OME about their needed absence, their grade in their enrolled

course or clerkship will result in an Unsuccessful Remediable (UR). A course or clerkship director cannot overturn this

grade. The student will need to meet with the Assistant Dean of Phase 1 to discuss remediation plans. In addition, a

Professionalism Form will also be submitted for an unexcused absence.

• A student with an identified area of concern about their professionalism in their course narratives may be referred to

the director of professionalism for review and action, which may include non-academic or academic probation and/or

review for dismissal.

Phase 1

Event

Outcome

UR in 1 or 2 courses/clerkships

Remediate the failures, if unsuccessful, placed on academic

probation and repeat the non-remediated courses. If

unsuccessful in any of the repeated courses/clerkships,

remediation is not permitted. The student is reviewed for

dismissal by the academic standing committee.

UR in 3 courses/clerkships

All students with UR in 3 courses/clerkships are reviewed by

the Academic Standing Committee for consideration of

remediation, removal from the curriculum, probation and/or

dismissal, notwithstanding remediation. Remediation of a

third course failure can take place only after the Academic

Standing Committee grants the student the ability to continue

in the program. Students receiving subsequent failing grades,

will be reviewed for dismissal after grades are finalized and

any applicable grade appeals have been completed.

UR in 3 or more exams in Molecular Basis

for Medicine and

Microbiology/Immunology/Infectious

Disease

The student may not progress in the basic science block

curriculum until the courses are remediated. They are placed

on academic probation pending a successful outcome. If the

student is unsuccessful in their remediation, they must repeat

the course(s). If unsuccessful in their repeated course(s), they

will be reviewed for dismissal.

B. Phase 2

• Students are required to pass all courses and clerkships in Year 3 to be promoted to Year 4 and take the USMLE Step 2

CK examination.

• In the M3 year, a student must successfully complete all assessment components of his/her course and clerkship

requirements. A student who needs to remediate assessment components for courses or clerkships during the M3 year

must do so before starting the 4

year. Remediation may delay the start of the M4 year and therefore may delay

graduation. A student who needs to remediate any portion of an M3 course or clerkship can only receive a final grade

of Remediated Pass (RP) in those courses or clerkships. A student who fails to remediate a course/clerkship will be

placed on academic probation, must repeat the course/clerkship, and cannot advance in the curriculum. If the student is

unsuccessful in their repeated course/clerkship, they will not be permitted to remediate the repeated course/clerkship

and they will be reviewed for dismissal by the Academic Standing Committee.

o In the M3 year, minimal competency for all clerkship NBME Subject examinations is set at 2 standard deviations

below the national mean for the most recent published national means for each of the subject examinations. Any

score below the posted pass score will result in an unsatisfactory grade (U or UR) in the clerkship regardless of the

overall clerkship score.

o In the M3 year, minimal competency for all clerkship summative clinical assessments is set as the mean score for

all competency domains at greater than or equal to 2. Any mean score below 2 will result in an unsatisfactory

grade (U or UR) in the clerkship regardless of the overall clerkship score.

o In the M3 summative OSCE, students must pass each OSCE domain with a score of greater than or equal to 60.00.

• Students are required to pass all M4 clerkships and electives, USMLE Step 2 CK, and satisfactorily complete their

Scholar’s Workshop capstone project to be eligible for graduation.

• A student who receives a final grade of UR in three M3 courses or clerkships or three M4 courses or clerkships in an

academic year will be reviewed by the Academic Standing Committee for dismissal. They will be permitted to

remediate up to two of the unsatisfactory courses or clerkships before being reviewed for dismissal by the Academic

Standing Committee, notwithstanding their remediation.

• A student with an identified area of concern in their clerkship narrative assessments may be referred to the director of

professionalism for review and action, which may include academic or non-academic probation and/or review for

dismissal.

• Unexcused absences in the M3, PC3, and M4 year are unacceptable. If a student is found to be absent from their

educational activities and did not log/report the absence, was not approved for the absence and/or did not inform OSA

and OME about their needed absence, their grade in their enrolled clerkship will immediately result in an Unsuccessful

Remediable (UR). A course or clerkship director cannot overturn this grade. The student will need to meet with the

Assistant Dean of Phase 2 to discuss remediation plans. In addition, a Professionalism Form will be submitted for the

unexcused absence.

Phase 2

Event

Outcome

Fail 1or 2 M3 course/elective/clerkship

Remediate the failed course(s), elective(s), or clerkship(s), if

unsuccessful, placed on academic probation and repeat the

course/elective/clerkship. If unsuccessful in the repeated

course/elective/clerkship, remediation is not permitted. The

student is reviewed for dismissal by the academic standing

committee.

Fail 3 M3 courses/electives/clerkships

Repeat entire M3 year and placed on academic probation.

Students will be allowed to complete Scholar’s Workshop and

Ambulatory Clinic so that they do not have to remediate those

two courses when repeating the M3 Year. If unsuccessful in

any of the repeated courses/electives/clerkships, remediation is

not permitted. The student is reviewed for dismissal by the

academic standing committee.

Fail 1 M4 course/elective/clerkship

Immediately stop progression in the M4 year. Remediate the

failed course, elective, or clerkship, if unsuccessful, placed on

academic probation and repeat the course/elective/clerkship. If

unsuccessful in the repeated course/elective/clerkship,

remediation is not permitted. The student is reviewed for

dismissal by the academic standing committee.

Fail 2nd M4 courses/electives/clerkships

Immediately stop progression in the M4 year. Remediate the

failed course, elective, or clerkship, if unsuccessful, placed on

academic probation and repeat the course/elective/clerkship. If

unsuccessful in the repeated course/elective/clerkship,

remediation is not permitted. The student is reviewed for

dismissal by the academic standing committee.

Fail 3rd M4 courses/electives/clerkships

Review for dismissal. All students are reviewed immediately

upon receipt of the third unsatisfactory grade. Students may

remediate no more than 2 of the failed courses/clerkships.

Review for dismissal is notwithstanding remediation.

C. USMLE Examinations:

• All students studying for the MD degree at CMSRU are required to pass Step 1 and Step 2 CK of the U.S. Medical

Licensure Examination (USMLE) as a condition of continued matriculation and of graduation.

 Step 1 shall be taken prior to beginning Phase 2 of the medical school curriculum and no later than

the Sunday before

the beginning of the M3 year orientation. There will be no extensions of this deadline.

o Students must successfully complete all academic requirements of Phase 1 before they will be permitted to take the

Step 1 examination and enter Phase 2. Students will receive a conditional permit to register for the Step 1

examination in October of the M2 year.

o Rising M2 students are conditionally promoted to Phase 1 M3 pending the results of the Step 1 Examination.

o M2 students who do not matriculate to the M3 year, for any reason (eg, students who are on Independent Study

and/or Leave of Absence before taking or re-taking Step 1) are required to take the Step 1 examination prior to

April 15

of the year they will matriculate to the M3 year.

 Step 2 CK (Clinical Knowledge) shall be taken no later than August 1

of the calendar year in which medical students

are enrolled in Year 4 of the medical school curriculum. If a student has to miss M3 Block 1, their deadline will be

moved to August 15

. There will be no exceptions of these deadlines.

• A student who fails to pass Step 1 on the initial attempt will have two choices:

1. Complete the first block of the M3 year. The student will then enter a temporary Step 1 Prolonged Absence for up to 6

weeks in Block 2 of the M3 year and develop a Step 1 remediation plan approved by the Assistant Dean for

Curriculum - Phase 2 which must be completed during block 2 of the M3 year.

 Take Step 1 again within 40 days after completing the first block of the M3 year.

 Resume the third-year program following the remediation time by entering the next block in the M3 curriculum.

 Completion of the M3 year will require an extension of time (a minimum of four weeks) to complete all

requirements, thus delaying the start of the fourth year.

2. At their request, students may choose to take an Independent Study or a leave of absence for the remainder of the M3

year and begin the M3 year with the subsequent class. Step 1 must be taken by March 1

prior to the return to the M3

curriculum.

• A student who fails to pass Step 1 on his/her second attempt shall:

 Stop all activities in the M3 year and be placed on academic probation by the Academic Standing Committee.

 Be automatically registered in an independent study program or take a leave of absence. The independent

study program will be monitored by the Office of Medical Education.

 Take Step 1 for the third time no later than May 1

of the original third academic year.

 If the student successfully completes the Step 1 examination, the student may reenter the medical education

program.

• A student whose M3 year may have been extended for the above reasons and has met all requirements of the Year

3 program may begin his/ her Year 4 program. The student will have the option of starting the M4 curriculum late,

or choosing a leave of absence or independent study and re-entering the Year 4 program with the subsequent class.

The amount of time extended into the M4 year may have an impact on a student’s ability to graduate on-time.

A student who fails the Step 1 examination a third time shall be reviewed for dismissal by the Academic Standing

Committee.

• A student who does not take Step 2 CK by August 1

of the fourth year (or August 15

if had to miss M3 Block 1)

shall not be permitted to continue clinical rotations until he/she takes the Step 2 examination(s).

• A student who fails to pass Step 2 CK shall:

 Take Step 2 CK prior to January 30

in their M4 academic year.

 Complete the fourth-year curriculum.

• A student who fails to pass Step 2 CK for the second time can continue in the M4 year and will be placed on academic

probation by the Academic Standing Committee. They must:

• Take Step 2 CK for the third time, no later than

March 15

and receive a passing score in time to graduate with their

current class. A passing score for Step 2 CK must be reported to the Office of Medical Education no later than one

week prior to graduation in order for the student to be awarded a diploma with his/her class.

 The student may choose to take a Leave of Absence or an Independent Study to finish out the current academic year.

They must take Step 2 CK by May 31

in order to move to the next academic year and finish with the next academic

class. A passing score must be received by July 1

in order to continue their academic program. If needed, the student

may be registered for an M4 independent study program at some point in the new M4 academic year, to allow for a

potential May graduation date of the next year.

 A student who fails the Step 2 CK examination three times shall be reviewed for dismissal by the Academic Standing

Committee.

D. Promotional Decisions

The Academic Standing Committee is responsible for assessing the overall academic performance of each student and the

decision for promotion.

For issues related to professionalism within the curriculum, a student’s case is referred to the director of professionalism by

the associate dean for professional development. The student is entitled to a meeting with the director of professionalism

prior to his/her rendering a decision about the case. The director of professionalism determines if the case should be

referred to the Academic Standing Committee for review and possible promotional decision.

Remediation of a Failing Performance

Phase 1 Remediation:

Only one attempt is permitted to remediate by reexamination or other course assessment a UR grade in any

course/clerkship. Remediation examinations are subject to minimal competency scores of greater than or equal to 60.00 in

addition to a remediated overall score of 70.00. The final remediation plan and assessments are at the discretion of the

course/clerkship directors. Students who fail remediation cannot progress in the curriculum, cannot take the USMLE Step

1 examination, and must repeat the course or clerkship in the following academic year. Students who are unsuccessful in

their remediation attempts will be placed on academic probation until they have successfully repeated the failed courses or

clerkships. If unsuccessful in their repeated course or clerkship in Phase 1 of the curriculum, the student will be reviewed

by the Academic Standing Committee for dismissal.

Phase 2 Remediation:

Remediation for courses and clerkships in the M3 and M4 year occurs on a case by case basis. within 21 days of the

posting of the final grade.

• Only one attempt is permitted to remediate by reexamination or other course assessment a UR grade in any assessment

component in the M3 or M4 year. The highest grade a student can earn with successful remediation in any M3 or M4

course or clerkship is a remediated/pass (RP). A student who is unsuccessful in remediation will be placed on

Academic Probation, cannot take the USMLE Step 2 CK examination, and must repeat the course/clerkship as soon as

possible. If the student is successful, they will be removed from Academic Probation and proceed in the curriculum.

If unsuccessful, the student will be reviewed by the Academic Standing Committee for dismissal. Remediation is not

permitted for second course/elective/clerkship failures.

• A student who fails three courses, electives, and/or clerkships in the M3 year will be placed on Academic Probation

and must repeat the entire M3 year. If the student is successful, they will be removed from Academic Probation and

enter the medical education program for the M4 year. If the student fails one or more courses or clerkships in the

repeated year, the student will be reviewed by the Academic Standing Committee for dismissal. Remediation is not

permitted for second course/elective/clerkship failures.

• A student who fails three courses, electives, and/or clerkships in the M4 year will reviewed by the Academic Standing

Committee for dismissal. All students are reviewed immediately upon receipt of the third unsatisfactory grade.

Students may remediate no more than 2 of the failed courses/clerkships. Review for dismissal is notwithstanding

remediation.

Remediation Process:

Students will follow a plan developed for course/clerkship/elective remediation by the course director(s)/clerkship

director(s). The plan will be developed, regardless of the student’s intent to appeal the final grade, within fourteen (14)

days of student notification of unsuccessful performance in a course/clerkship/elective, except in the last course,

elective, or block in an academic year when the plan is developed within 3 days. The course/clerkship/elective

director(s) will:

1. Within seven (7) days of notification of unsuccessful performance, meet with the student to help identify obstacles to

achieving satisfactory performance

2. Meet with course/clerkship/elective faculty, as necessary, to discuss the student’s learning needs and plan remedial

experiences

3. Work with the Phase 1 or Phase 2 assistant dean to create a written plan for remediation, including:

a. goals

b. method(s) of study/practice

c. duration of the program

d. frequency of meetings between the student and designated faculty or course/clerkship director

e. planned assessments

4. Share the proposed program with the assistant dean for assessment and CQI for review and written approval. In the

event the student is in Year 3, the M3 director will be required to review and approve the plan. For students in Year 4,

the M4 director will be required to review and approve the plan.

5. Review the plan with the student within one week of the original meeting.

6. Present the student with the written plan, which will be signed by the student.

7. If the student successfully remediates, the grade is changed from a UR to an RP.

8. If the student fails to remediate, the grade is converted to a U and the student is referred to the Academic Standing

Committee for promotional review.

V. PROBATION

A. Academic

A student shall be placed on academic probation by the Academic Standing Committee:

• when the student has unsuccessfully completed the remediation process for a course/clerkship and/or is required to

repeat a course /clerkship due to unsatisfactory academic performance;

• when a student is repeating an academic year; or

• When a student fails a USMLE Step 1 or Step 2 CK examination for the second time.

• See Satisfactory Academic Progress (SAP) Policy regarding financial aid implications.

A student shall be removed from academic probation by the Academic Standing Committee:

• when the student has successfully completed a repeated course/clerkship due to unsatisfactory academic performance;

• when a student has successfully completed all courses and clerkships in a repeated academic year; or

• when a student passes a USMLE Step 1 or Step 2 CK examination on the third attempt.

All decisions made by the Academic Standing Committee regarding the academic status of students are final.

A student who is on probation in either Phase 1 or Phase 2 of the curriculum and fails a course or

clerkship for the second time shall be reviewed by the Academic Standing Committee for dismissal.

B. Non-Academic

Professionalism is a core competency of the CMSRU curriculum. All matters related to professionalism within the

curriculum are reviewed by the director of professionalism. When, in narrative comments evaluating a student, or any other

formal communication such as a Professionalism Intervention Report, faculty members express concern about a student’s

professionalism, the director of professionalism may, after discussion with the faculty, and/or course/clerkship director,

and/or the associate dean for professional development, the senior associate dean for medical education, and/or the

assistant dean for student affairs, refer the student to the Academic Standing Committee for review. If the Academic

Standing Committee places a student on non-academic probation, the chair of the Academic Standing Committee will

forward the decision to the director of professionalism. The Executive Cabinet of Deans at CMSRU will provide the

conditions for removal from non-academic probation. The director of professionalism will notify the student of their status

and will state in writing the specific duration and conditions of the probationary status. The director of professionalism is

responsible for monitoring the student’s adherence to the conditions of the probation. The director of professionalism will

inform the Academic Standing Committee of the student’s progress. If a student completes the requirements of their

probation, they will be removed from probationary status and informed in writing by the Academic Standing Committee.

If a student does not complete the requirements of their probation, they will be reviewed for dismissal by the Academic

Standing Committee. All decisions made by the Academic Standing Committee regarding the academic status of students

are final.

Students who are currently on academic probation, and are subsequently reviewed for and placed on non-academic

probation, or vice versa, will be reviewed for dismissal.

VI. GRADE APPEALS

A grade appeal may be made only on the basis of a Procedural Irregularity: a documented error in, or divergence from,

the prescribed or customary process of evaluating and grading students. Appeals will be acted upon favorably only when

real, clear and convincing evidence of a procedural irregularity. Testing conditions that are not identical to prior testing

conditions are not necessarily a procedural irregularity. The student should include all relevant information in the first

level of the appeal, as this will constitute the basis for the appeal from the course or clerkship director through the

Academic Standing Committee. The basis of the appeal cannot be modified once the appeal is submitted.

Extenuating circumstances will not be accepted as the basis for a grade appeal. Extenuating circumstances may represent

the basis for a postponement of an assessment event. Students must present evidence for extenuating circumstances related

to course or clerkship assessments to the Assistant Dean for Student Affairs before an assessment event. Excuses will not

be accepted after the assessment event and are not considered procedural irregularities associated with the course or

clerkship requirements or assessment activities.

Students may begin remediation during a grade appeals process for courses or clerkships with unsatisfactory grades and

not involved in the appeal. A student who receives a final grade of UR in three courses or clerkships in an academic year

in Phase 1 will be reviewed by the Academic Standing Committee for dismissal. A student who receives a final grade of

UR in four M3 courses or clerkships or three M4 courses or clerkships in an academic year will be reviewed by the

Academic Standing Committee for dismissal. This is notwithstanding any successful remediation of the courses or

clerkships in which a UR grade was awarded.

Appealing a Course or Clerkship Assessment Score or Grade

1. Appeal to the Course/Clerkship Director

A student who believes that there is a procedural irregularity with his/her course/clerkship grade including course and

clerkship data (e.g., examination performance or narrative assessments) must first appeal the grade to the course/clerkship

directors within three (3) working days of having been notified of the grade. The student submits the Grade Appeal Form

to the course/clerkship directors with a copy to the Office of Medical Education administrative assistant. The Office of

Medical Education administrative assistant monitors and documents the process so that all steps in the appeal process are

followed correctly. The course/clerkship directors, in consultation with the course/clerkship teaching faculty, will review

the grade appeal and notify the Office of Medical Education administrative assistant of the decision within five (5) working

days of the appeal. The Office of Medical Education will then notify the student of the appeal outcome.

2. Appeal to the Office of Medical Education

If the student believes that the decision reached by the course/clerkship directors is unjustified, s/he may appeal that

decision, in writing, to the director of medical education in the Office of Medical Education. The written appeal must be

made within three (3) working days of receiving notice upholding the original grade from the course/clerkship directors.

The administrative assistant in the Office of Medical Education monitors and documents this process. The director of

medical education in the Office of Medical Education reviews the appeal and offers a decision within five (5) working

days. If the director of medical education in the Office of Medical Education upholds the grade as recorded by the faculty,

the student may then appeal the grade to the Academic Standing Committee.

3. Appeal to the Academic Standing Committee

If the student is dissatisfied with the decision reached by the director of medical education in the Office of Medical

Education, they may appeal that decision, in writing, to the Academic Standing Committee. The written appeal must be

made within three (3) working days of receiving notice upholding the original grade and is monitored and documented by

the Office of Medical Education administrative assistant. The Academic Standing Committee reviews the appeal and offers

a decision within seven (7) working days. The decision of the Academic Standing Committee is final. The decision is

communicated to the student, the course/clerkship directors, and the Office of Medical Education by the Academic

Standing Committee. The course/clerkship directors implement the decision of the Academic Standing Committee.

4. Actions: An action in favor of a student does not imply wrongdoing by the course or clerkship directors, faculty, or

the administration.

VII. PROMOTIONAL APPEALS

Appealing Promotional Decisions

All information pertaining to a student's academic promotion and professional attributes, including that contained in

departmental files, may be utilized in the appeals processes described below. Appeals may be based upon procedural

irregularity or extenuating circumstances.

Extenuating Circumstances are severe and documented situations which were beyond the student's control and which

prevented the student from performing in a manner truly reflective of his/her knowledge and skills.

Students may begin remediation during a promotional appeals process for up to two courses/clerkships. A student who

receives a final grade of UR in three courses or clerkships in Phase 1, or UR in four courses or clerkships in M3, or three

courses or clerkships in M4 during an academic year will be reviewed by the Academic Standing Committee for dismissal.

This is notwithstanding any successful remediation of the courses or clerkships in which a UR grade was awarded.

1. Academic Performance Appeals to the Ad Hoc Committee for Student Appeals

Process of Appeal

• A student may appeal the promotional decision of the Academic Standing Committee by requesting that the senior

associate dean for medical education or his/her designee convene an Ad Hoc Committee for Student Appeals within 10

working days of the notice from the Academic Standing Committee decision. The appeal is made through the senior

associate dean for medical education in the Office of Medical Education. The process is monitored and documented by

the administrative assistant in the Office of Medical Education.

• The senior associate dean for medical education or designee convenes an Ad Hoc Committee for Student Appeals that

shall be composed of five members of the faculty who are not advisory college directors, members of the Academic

Standing Committee, or the Curriculum Committee. Potential members are queried by the senior associate dean for

medical education regarding conflicts of interest. The chair will be elected from among the Ad Hoc Committee for

Student Appeals committee members.

• The Ad Hoc Committee for Student Appeals shall hear the appeal and provide a decision within fifteen (15) working

days of receiving written notice of intent to appeal.

• The student shall be given at least 72 hours’ notice of the time and place of the committee’s hearing. The student may

provide a written and/or an oral statement to the committee at the hearing.

• At the discretion of the student making the appeal, one individual may accompany him/her to the hearing in the capacity

of advisor and/or advocate. The advisor/advocate has no voice in the appeal process. All other advocacy efforts must be

in the form of written communications to the committee, and must be received by the committee no later than 48 hours

preceding the time scheduled for the start of the appeals hearing.

• The decision of the ad hoc committee shall be communicated orally and in writing to the dean or designee and will be

final. The dean shall communicate this final decision to the student.

• If the appeal is successful, an Academic Improvement Plan to address the student’s academic deficiencies will be

developed by the Executive Cabinet of Deans. This academic plan is not appealable and may include a repeat of all

courses/clerkships in the academic year including courses/clerkships where foundational knowledge is deemed poor even

if there was a passing grade.

• An action in favor of a student does not imply wrongdoing by the faculty or the administration.

2. Non-academic Performance Appeals to the Ad Hoc Committee for Student Appeals

Promotional decisions based solely on non-academic issues related to professionalism, when other competencies within the

curriculum are not an issue, are made by the Academic Standing Committee. A student may appeal the decision of the

Academic Standing Committee for reasons of procedural irregularity or extenuating circumstances.

Process of Appeal

• A student may appeal the non-academic performance promotional decision of the Academic Standing Committee by

requesting that the senior associate dean for medical education or designee convene an Ad Hoc Committee for Student

Appeals within 10 working days of the notice from the Academic Standing Committee decision. The appeal is made

through the senior associate dean for medical education in the Office of Medical Education. The process is monitored

and documented by the Office of Medical Education administrative assistant.

• The senior associate dean for medical education or designee convenes an Ad Hoc Committee for Student Appeals that

shall be comprised of five members of the faculty who are not advisory college directors, members of the Academic

Standing Committee, or the Curriculum Committee. Potential members are queried by the senior associate dean for

medical education regarding conflicts of interest. The chair will be elected from among the Ad Hoc Committee for

Student Appeals committee members.

• The Ad Hoc Committee for Student Appeals shall hear the appeal and provide a decision within fifteen (15) working

days of receiving written notice of intent to appeal.

• The student shall be given at least 72 hours’ notice of the time and place of the committee’s hearing. The student may

provide a written and/or an oral statement to the committee at the hearing.

• At the discretion of the student making the appeal, one individual may accompany him/her to the hearing in the capacity

of advisor and/or advocate. The advisor/advocate has no voice in the appeal process. All other advocacy efforts must be

in the form of written communications to the committee, and must be received by the committee not later than 48 hours

preceding the time scheduled for the start of the appeals hearing.

• The decision of the ad hoc committee shall be communicated orally and in writing to the dean or designee and will be

final. The dean shall communicate this final decision to the student. If the appeal is successful, a Performance

Improvement Plan to address the student’s professionalism deficiencies will be developed by the Executive Cabinet of

Deans. The performance plan is not subject to appeal.

• An action in favor of a student does not imply wrongdoing by the faculty or the administration.

ACCELERATED THREE YEAR CURRICULUM

A student in the accelerated three-year curriculum (referred to in this section as student) may change to the four-year track

if it is felt to be in the student’s best interest academically or professionally.

• COURSE REQUIREMENTS AND SEQUENCING

• The curriculum of this program is divided in three curricular years that must be completed in the prescribed sequence.

Phase 1 comprises the M1 and M2 curricular years. Phase 2 comprises the M3 year and Sub-internship. All courses

and academic requirements of a particular year must be completed satisfactorily before a student may begin any course

or clerkship in the ensuing curricular year. All required courses of the curriculum, including the required number of

elective weeks, must be completed satisfactorily before a student may be certified for graduation.

• ASSESSMENT AND STANDING OF STUDENTS

• Identical to the applicable portions of Section III. ASSESSMENT AND STANDING OF STUDENTS

• THE PROMOTIONAL SYSTEM

• Phase 1

1. Identical to Section IV.A. Phase 1 with the following conditions for mandatory conversion from the three-year

curriculum to the four-year curriculum:

a. A student who receives an unsatisfactory grade in 2 courses in an academic year in Phase 1, regardless of

successful remediation.

b. A student who fails to remediate an unsatisfactory grade in one course/clerkship

c. A student who chooses to repeat a year without having successfully completed all the academic requirements for

that year

d. A student who decides not to pursue their specialty track in PC3

• Phase 2

1. Identical to Section IV.B. Phase 2 with the following conditions for mandatory conversion from the three-year

curriculum to the four-year curriculum:

a. Based on NBME subject exam performance in an accelerated three-year curriculum clerkship:

i. A student who receives an unsatisfactory grade in 2 clerkships, or one clerkship and the Scholar’s Workshop,

regardless of successful remediation.

ii. A student who fails to remediate an unsatisfactory grade in one course/clerkship

b. Based on global clinical assessment in an accelerated three-year curriculum clerkship:

i. A student who fails one clerkship.

c. A student who receives an unsatisfactory grade in the sub-internship

d. A student who receives an average of less than 4 on any summative CLOC assessment.

e. A student who chooses to repeat the year without having successfully completed all the academic requirements for

the year

i. This decision must be communicated to the Director of the PC3 Curriculum no later than January 1 of the M3

year.

f. A student who decides not to pursue their specialty track in PC3

i. This decision must be communicated to the Director of the PC3 curriculum no later than January 1

of the M3

year.

• USMLE Examinations

1. Identical to Section IV.C. USMLE Examinations with the following special conditions:

a. Students must achieve a passing score in Step 1 and Step 2 CK before June 1

of the accelerated M3 year to begin

residency training at the completion of the accelerated M3 year.

b. Step 1:

i. A student who fails Step 1 may be allowed one other attempt:

1. Step 1 must be retaken before September 30

of the M3 year

ii. A student who fails Step 1 on the second attempt must convert from the three-year curriculum to the four-year

curriculum

1. The student will get credit for M3 courses and clerkships successfully completed

a. Any P grade will be converted to the H/HP/P system by interpolation with the grades of the standard

M3 cohort at the end of the academic year.

c. Step 2:

i. Students must take USMLE Step 2 CK by March 1

of the M3 year

ii. Students who fail Step 2 must convert from the three-year curriculum to the standard four-year curriculum.

The student

1. will get credit for the M3 courses and clerkships successfully completed

a. Any P grade will be converted to the H/HP/P system by interpolation with the grades of the standard M3

cohort at the end of the academic year.

2. will enroll in the M4 year in the following academic year

3. will retake the failed Step 2 component(s) no later than August 31

of the M4 year.

• PROMOTIONAL DECISIONS

• Identical to Section IV.D. Promotional Decisions, except

1. Students will begin the remediation process for a failed M3 clerkship, based on NBME subject exam performance

only, after PC3 Block 7, notwithstanding any ongoing appeal of the grade.

a. Remediation must be completed no later than March 8

2. A student who leaves the accelerated three-year curriculum during the M3 year, either by mandate or by choice, will

get credit for the clerkships successfully completed (including the associated NBME subject examinations).

a. The P grade will be converted to the H/HP/P system by interpolation with the grades of the standard M3 cohort at the

end of the academic year.

• PROBATION

• Identical to Section V. PROBATION.

• GRADE APPEALS

• Identical to Section VI. GRADE APPEALS.

• PROMOTIONAL APPEALS

• Identical to Section VII. PROMOTIONAL APPEALS.

The medical school may change the deadlines for grades, promotional appeals, and graduation requirements as necessitated

by natural disasters or other events outside of the control of the medical school. During these circumstances, the medical

school will ensure that changes are reviewed by the appropriate faculty committee such as Curriculum Committee and/or

Academic Standing Committee.

Academic Workload Policy for Pre-Clinical Years

POLICY:

Academic Workload Policy for Pre-Clinical Years

PURPOSE:

A primary goal of CMSRU is to provide a quality education for medical students. In doing so, CMSRU recognizes the

importance of creating an atmosphere that encourages students to maintain a healthy balance between required academic

activity and a lifestyle focused on wellness. Therefore, it is important to develop policies that define limitations of

scheduled educational sessions within the curriculum, so as to simultaneously maximize educational benefits and limit

fatigue which may impair the student's ability to learn. A current duty hour policy exists for the educational program

during the clinical years at CMSRU (M3 and M4). This policy will specifically address academic workload during the pre-

clinical years (M1 and M2) and will also provide for allotment of time on a weekly basis for students to engage in self-

directed, independent learning. The method of oversight and monitoring of the effectiveness of this policy by the

Curriculum Committee and Office of Medical education is also discussed.

SCOPE:

Candidates for the Doctor of Medicine degree (M.D.)

DEFINITIONS:

In-class activity: An in-class activity refers to an educational session that appears on the weekly academic schedule and

involves presentation of curricular content through direct interaction between medical students and faculty. Although these

sessions appear on the weekly academic calendar, not all sessions are considered mandatory (e.g. attendance is required).

Required out-of-cl

ass activity: A required out-of-class activity refers to an educational activity that is required to be

completed outside of scheduled class time, generally in preparation for a scheduled in-class activity. Examples of required

out-of-class activities include, but are not limited to, case preparation for Active Learning Group, reading of assigned

literature for Scholars’ Workshop sessions, and review of material (e.g. a recorded lecture) prior to an in-class flipped

lecture. Required out-of-class activities do not include time to study material presented in in-class activities.

Self-directed learning time: Self-directed learning time refers to blocks of time built into the weekly academic calendar to

allow students to identify, analyze, and synthesize information relevant to their own learning needs. Self-directed learning

time also allows students the time required to complete required out-of-class activities or to prepare for in-class activities.

The actual activities that occur during self-directed learning time are at the discretion of the student.

Mandatory educa

tional session: A mandatory educational session refers to an educational session that appears on the

weekly academic calendar, at which student attendance is required. Some educational sessions, because of their interactive

nature (e.g. Active Learning Groups, Scholars’ Workshop, Foundations of Medical Practice, Ambulatory Clerkship), are

always considered mandatory. Other sessions, such as lectures, are not mandatory. Specific descriptions of which

educational sessions are designated as mandatory are contained within the syllabus for each course and are at the discretion

of the course directors.

PROCEDURE:

The structure of each course within the Phase 1 (pre-clinical) curriculum is developed by the faculty course directors and

then approved and subsequently monitored by the Curriculum Committee. The average weekly total academic workload,

which includes in-class educational sessions and required out-of-class activities, shall not exceed 40 hours. In the pre-

clinical (Phase 1) curriculum at CMSRU, the weekly academic calendar consists of total of 40 hours. These 40 hours are

divided between scheduled in-class sessions and self-directed learning time.

The weekly schedule includes no more than 30 hours of scheduled in-class sessions and for most weeks this ranges from

27.5 to 29.5 hours (Note: this excludes attendance to Week-On-the-Wards activities). The format for scheduled in-class

sessions includes lectures, small group or team-based learning activities, laboratory or practical sessions, simulation

activities and clinical experiences. These scheduled educational sessions generally occur Monday through Friday between

the hours of 8AM and 5PM, although occasionally an Ambulatory Clinic session may extend beyond this time frame, and

Week-On-the-Wards activities may include night “floats”. No more than nine hours of scheduled in-class sessions will

occur in a single day.

In addition to in-class educational sessions, the weekly academic calendar contains at least ten hours of designated self-

directed learning time, although for most weeks this ranges from 10.5 to 12.5 hours. Self-directed learning time is present

on most days and generally occurs in blocks of at least two hours. The allotted self-directed learning time will allow

sufficient time for students to address their own learning needs, which may include required out-of-class activities or other

activities necessary for preparation for in-class sessions. Self-directed learning time is not intended to include additional

discretionary study time.

Monitoring: On-going central monitoring of the academic workload, including in-class sessions and required out-of-class

activities for each pre-clinical course, will be performed by the Office of Medical Education to ensure that the established

workload guidelines are appropriate and that the actual workload prepared by faculty course directors is in compliance with

this policy. The monitoring data collected by the Office of Medical Education will be forwarded to the Curriculum

Committee upon the completion of each semester. If individual courses are found to be out of compliance with this policy

or the overall policy guidelines are deemed to be inappropriate, the Curriculum Committee will take action to remedy the

situation and re-establish compliance.

PRIME Policy

POLICY:

Preparing Residents as Instructors in Medical Education (PRIME) Program

PURPOSE:

The PRIME program is a mandatory, centrally-monitored program designed to ensure that all residents and

fellows (GME trainees) who interact with medical students in educational settings are adequately prepared as

educators. Specifically, the PRIME program provides GME trainees the following: 1) knowledge and

understanding of the learning objectives of the course or clerkship; 2) understanding of key school policies

pertinent to their role as educators; 3) preparation for their roles in teaching and assessment; and 4) resources

to enhance teaching and assessment skills as provided by CMSRU. The PRIME program is monitored by the

Office of Medical Education (OME), both UME and GME divisions; participation by all trainees is

mandatory and is monitored by OME (GME division), by the designated institutional official (DIO), and the

Associate Dean of Medical Education. Departments and divisions may have supplementary programs. This

program replaces the previous Resident as Teacher program.

BACKGROUND:

Medical education is a continuum from Undergraduate Medical Education (UME) to Graduate Medical Education

(GME) to practice. GME trainees spend a significant amount of their time teaching near peers, including medical

students. GME trainees also play a significant role in the professional identity formation of medical students. To

do their work most effectively, GME trainees need to have received, reviewed, and understood the objectives of

the course or clerkship they are involved with and provided education in methods of teaching and assessment.

Accordingly, CMSRU has developed this policy.

SCOPE: All GME trainees (residents and fellows) who interact with CMSRU medical students in educational

settings.

DEFINITIONS:

Resident: A graduate of medical school program who is actively enrolled in specialty medical training.

Fellow: A graduate of an accredited medical school program and, who has successfully completed residency

training and is now enrolled in subspecialty or advanced training.

GME trainee: A resident or a fellow.

PROCEDURE:

All GME trainees receive the CMSRU institutional medical education objectives during orientation and on an

annual basis. All GME trainees are required to attest to receiving and reviewing and agreeing to abide by the

Compendium of Student Policies for Faculty, Residents and Staff on an annual basis.

All GME trainees receive the course or clerkship syllabus from the course/clerkship director and the

course/clerkship director reviews the syllabus with the GME trainees to ensure understanding and an opportunity

to ask questions.

It is the responsibility of the course/clerkship director to ensure that the trainees receive the syllabus and they work

with the residency or fellowship program director (PD) to ensure that a review session is organized. The

course/clerkship director sends a copy of the attendance record to the Associate Dean for Medical Education.

All GME trainees must complete basic education from the PRIME curriculum (2 on-line modules on teaching

and assessment), review of the institutional and course/clerkship objectives, and review of the Compendium of

Student Policies for Faculty, Residents and Staff before engaging in teaching. It is the responsibility of the PD to

ensure that the GME trainees have completed the education. This is monitored centrally by the OME and the DIO

for GME.

The DIO prepares a report of compliance and non-compliance for the Associate Dean for Medical Education.

PD and the DIO address issues of non-compliance. If non-compliance persists, the Associate Dean for Medical

Education addresses it with the departmental chair.

The PD assess the performance of their trainees as teachers, as part of their regular assessment program using

the milestones.

The CMRSU OME (UME division) is responsible for soliciting and compiling the medical students' evaluation of

the teaching effectiveness of the GME trainees they have worked with, and for sending those evaluations to the

DIO who reviews and disseminates the evaluations to the appropriate PD.

The PD review teaching performance with their trainees. If necessary, a remediation plan is prepared by the PD

and approved and monitored by the DIO.

Notices of faculty development programs that may be of interest to GME trainees, but are not mandatory, are

sent by the Office of Faculty Affairs to the director of GME/DIO for dissemination to the trainees.

Compliance with review of the Compendium of Student Policies for Faculty, Residents and Staff is monitored by

the Associate Dean for Faculty Affairs.

GME trainees who are non-compliant with the PRIME program and /or compendium review will be

removed from teaching and may face disciplinary action from the PD, the departmental chair, or the

DIO.

Student Clinical Assignment Policy

POLICY:

Student Clinical Assignment

PURPOSE:

The faculty and academic administrators of CMSRU recognize their responsibility to maximize the fair and equitable

assignment of CMSRU students during their clinical clerkship education. This policy guides the assignment and as

needed, the reassignment, of clinical supervisors to third and fourth year medical students.

SCOPE:

Candidates for the Doctor of Medicine Degree (M.D.)

DEFINITIONS:

Clinical assignment: Students are assigned preceptors and supervising physicians who are responsible for teaching and

assessing students in the clinical clerkship education program.

PROCEDURE:

I. RESPONSIBILITY

Student Clinical Assignment: A medical student will have clinical preceptors and supervising physicians assigned

as part of their clinical clerkship education program. Assignments will be carried out by clerkship directors in

conjunction with the office of medical education staff. Whenever possible, a lottery system will be used to provide for

fair and equitable assignment of CMSRU medical students to their clinical clerkships. Students may request a change

in their clinical assignment location, preceptor or supervising physician. These requests are reviewed on a case-by-

case basis.

1. M3 Block courses

The Office of Medical Education assigns each student to a block schedule for the M3 year based upon a lottery held

prior to the M3 orientation. M3 students are assigned to preceptors and supervising physicians on duty in the inpatient

setting during their assigned M3 block. A student may request a change in preceptor or supervising physician for

extenuating circumstances. The clerkship director, in conjunction with the M3 director and the Assistant Dean for

Phase 2, reviews the request and makes the change, if appropriate, within 48 hours. If the request for change is denied,

the Assistant Dean for Phase 2 meets with the student to explain the rationale for not making the change. The student

may appeal the decision to the senior associate dean for medical education, who reviews the request and makes the

final decision within 48 hours

M3/PC 3-Cooper Longitudinal Outpatient Clerkship (CLOC) placements

Similarly, M3 students are randomly assigned to Cooper Longitudinal Outpatient Clerkship (CLOC) outpatient based

clinical offices in the M3 year. A student may request a change in preceptor or clinical learning site with the Cooper

Health System for extenuating circumstances. The clerkship director, in conjunction with the M3 director and the

Assistant Dean for Phase 2, reviews the request and makes the change, if appropriate, within 48 hours. If the request

for change is denied, the Assistant Dean for Phase 2 meets with the student to explain the rationale for not making the

change. The student may appeal the decision to the senior associate dean for medical education, who reviews the

request and makes the final decision within 48 hours.

2. M4 Clinical education placements

Students have considerable control over the sequence of required clerkships and elective courses in their M4 year. The

preceptors to whom they are assigned for a particular rotation are largely determined by their schedule. Some

rotations may have alternative assignment options in a given block (e.g., internal medicine sub-internship), but others

may not. M4 students may request a change in preceptor or clinical learning site in the M4 clinical education program

for extenuating circumstances. The clerkship director, in conjunction with the M4 director and the Assistant Dean for

Phase 2, will review the request and make the change, if appropriate and available, within 48 hours. If there is no

alternative preceptor or site during that block, the student may have to schedule the rotation at a different time during

the year. If an alternative site/preceptor is available, but the change request is denied, the Assistant Dean for Phase 2

will meet with the student to explain the rational for not making the change. The student may appeal the decision to

the senior associate dean for medical education, who will review the case and make the final decision within 48 hours.

Medical Student Supervision During Required Clinical Activities Policy

POLICY:

Medical student supervision during required clinical activities

PURPOSE:

In its efforts to ensure excellent medical education and to guard patient and student safety, CMSRU has developed the

following policy with the goal of providing guidance for faculty physicians when supervising medical students during

clinical activities. The following policy defines the supervision of medical students during clinical activities.

SCOPE:

Candidates for the Doctor of Medicine Degree (M.D.)

PROCEDURE: (specific outline/details of the policy/procedure)

RESPONSIBILITY:

It is the responsibility of the supervising faculty member to ensure policy standards are followed for all students

participating in clinical activities.

Medical students participating in patient care must be supervised at all times. The primary supervising physician is an

attending physician employed by Cooper University Health Care, or a volunteer physician with a CMSRU faculty

appointment, practicing within the scope of his/her discipline as delineated by the credentialing body of the health system.

When resident physicians, clinical post-doctoral fellows or other healthcare professionals are actively involved in medical

student supervision during clinical activities, it is the responsibility of the supervising faculty physician to ensure all those

personnel are appropriately prepared for their roles for supervision of medical students and are acting within the scope of

their practice.

When the attending physician is not physically present in the clinical area, the responsibility for supervising CMSRU

medical students will be delegated to the appropriately prepared resident physician or clinical post-doctoral fellow at the

discretion of the primary attending physician. Students are provided with rapid, reliable systems for communicating with

faculty and resident physicians.

Clinical supervision is designed to foster progressive responsibility as students’ progress through the curriculum. The

intensity of medical student supervision in any given situation will depend on the medical student’s level of education and

experience, demonstrated competence, and the learning objectives of the clinical experience. Course/clerkship directors

will provide specific faculty members and other preceptors with guidance for each clinical experience, including the

students’ level of responsibility and scope of approved activities and procedures during the rotation. Clinical faculty

preceptors will be knowledgeable about CMSRU Institutional Educational Objectives, clerkship-specific objectives,

supervisory recommendations, and access to educational resources, including assessment instruments. Relevant resources

will be emailed to faculty prior to the start of the medical student’s clinical experience and reviewed with them by the

clerkship director. They will also be available remotely on the CMSRU Blackboard® and one45®.

First- and second-year medical students will be directly supervised, with the supervising physician present or immediately

available, and prepared to take over the care of the patient if needed. Under the direct supervision of the supervising

physician, first- and second-year students may participate in history taking, physical examinations and critical data

analysis, performing procedures, and may have access to the medical record.

Third-

and fourth-year medical students will be directly supervised, with the supervising physician available to provide

direct supervision. Students may participate in the care and management of patients, including performing procedures,

under the direct supervision of the supervising physician at all times, with patient permission. Clinical interventions are

never to be executed by medical students without a supervising physician’s awareness and permission.

Medical student participation in invasive procedures requires direct supervision by the supervising attending physician or

credentialed resident physician at all times during the procedure. The supervising physician must have the credentials to

perform the procedure being supervised. A student may assist in procedures only when the supervising attending

physician agrees that the student has achieved the required level of competence, maturity and responsibility to perform the

procedure.

Supervising physicians and other preceptors are expected to provide opportunities for students to demonstrate

responsibility for patient care. These opportunities may be in the form of history-taking; physical examination; reporting

and entering findings in the patient’s medical record with the explicit approval of the patient’s supervising attending

physician. In all patient care contacts the patient shall be made aware that the individual providing the care and/or

performing the procedure is a student. Patients have the right to decline to have a student participate in their care.

The supervising physician will be responsible for reviewing student chart documentation and providing constructive

feedback. Medical student findings entered in the medical record of the patient will be for educational and student

evaluation purposes only and cannot be used in lieu of any required attending staff or house staff documentation. Students

must clearly sign all entries in the medical record, along with the designation that they are medical students. Supervising

attending physicians or graduate medical trainees must review student notes. Fourth-year students may enter orders in the

electronic medical record but those orders cannot, by virtue of an electronic “hard stop,” be executed until they are

countersigned by the supervising attending physician or senior resident.

Note: For billing purposes, the teaching physician must personally verify and redocument the history of present illness

(HPI) and personally perform and redocument the physical examination and medical decision-making activities of the

service. The teaching physician may refer to the student’s documentation only with respect to Review of Systems and

Fast/Family/Social History. (See Cooper Health System Policy 1.220 Teaching Physician Billing Policy.)

Supervising faculty physicians or residents must provide medical students with regular, timely and specific feedback

based on their supervision. Supervising faculty will notify the clerkship or course director if there is concern for any

potential academic and/or professional gaps in student performance. Should students have any concern regarding clinical,

administrative, professional, educational or safety issues during their rotation, they will be encouraged to immediately

contact the supervising physician, clerkship/course director or the Associate Dean for Student Affairs.

A CMSRU faculty physician who provides medical and/or psychiatric care, psychological counseling, or other sensitive

health services to a medical student, or who has a close personal relationship with a medical student, must recuse

himself/herself from the supervisory role. In such cases, the faculty physician must have no involvement in assessing or

evaluating the medical student’s academic performance or participating in decisions regarding his/her promotion and/or

graduation. The faculty physician and the medical student are advised to immediately contact the appropriate

clerkship/course director and/or Associate Dean for Student Affairs should the potential for these conflicts of interest

arise.

Teacher-Learner Interaction Policy

POLICY:

Teacher-Learner Interaction

CMSRU acknowledges that the profession of medicine is a moral enterprise in which practicing physicians engender the

development of virtues, integrity, sense of duty and ethical framework in medical students. CMSRU faculty, residents,

fellows, teaching staff and students will abide by the following compact which serves both as a pledge and as a reminder

to teachers and learners that their conduct in fulfilling their mutual obligations is the medium through which the

profession inculcates its ethical values.

PURPOSE:

To establish guidelines for interactions between medical students and CMSRU faculty and instructors.

SCOPE:

Candidates for the Doctor of Medicine Degree and all those who act in the role of teacher for these students at CMSRU.

DEFINITIONS:

Teacher - any individual serving in a capacity as teacher or mentor that a student will interact with in a classroom, small

group or clinical setting over all four years.

PROCEDURE:

GUIDING PRINCIPLES: (AAMC’s Compact Between Teachers and Learners of Medicine)

DUTY - Medical educators have a duty, not only to convey the knowledge and skills required for delivering the

profession's contemporary standard of care, but also to inculcate the values and attitudes required for preserving the

medical profession's social contract across generations.

INTEGRITY - The learning environments conducive to conveying professional values must be suffused with integrity.

Students learn enduring lessons of professionalism by observing and emulating role models who epitomize authentic

professional values and attitudes.

RESPECT - Fundamental to the ethic of medicine is respect for every individual. Mutual respect between learners, as

novice members of the medical profession, and their teachers, as experienced and esteemed professionals, is essential for

nurturing that ethic. Given the inherently hierarchical nature of the teacher/learner relationship, teachers have a special

obligation to ensure that students and residents are always treated respectfully.

COMMITMENTS OF FACULTY

● “We pledge our utmost effort to ensure that all components of the educational program for students and residents are

of high quality.

● As mentors for our student and resident colleagues, we maintain high professional standards in all of our interactions

with patients, colleagues, and staff.

● We respect all students and residents as individuals, without regard to gender, race, national origin, religion, or

sexual orientation; we will not tolerate anyone who manifests disrespect or who expresses biased attitudes towards

any student or resident.

● We pledge that students and residents will have sufficient time to fulfill personal and family obligations, to enjoy

recreational activities, and to obtain adequate rest; we monitor and, when necessary, reduce the time required to

fulfill educational objectives, including time required for “call” on clinical rotations, to ensure students' and residents'

wellbeing.

● In nurturing both the intellectual and the personal development of students and residents, we celebrate expressions of

professional attitudes and behaviors, as well as achievement of academic excellence. We do not tolerate any abuse or

exploitation of students or residents.

● We encourage any student or resident who experiences mistreatment or who witnesses unprofessional behavior to

report the facts immediately to appropriate faculty or staff; we treat all such reports as confidential and do not

tolerate reprisals or retaliations of any kind.”

COMMITMENTS OF STUDENTS AND RESIDENTS

● “We pledge our utmost effort to acquire the knowledge, skills, attitudes, and behaviors required to fulfill all

educational objectives established by the faculty.

● We cherish the professional virtues of honesty, compassion, integrity, fidelity, and dependability.

● We pledge to respect all faculty members and all students and residents as individuals, without regard to gender, race,

national origin, religion, or sexual orientation.

● As physicians in training, we embrace the highest standards of the medical profession and pledge to conduct ourselves

accordingly in all of our interactions with patients, colleagues, and staff.

● In fulfilling our own obligations as professionals, we pledge to assist our fellow students and residents in meeting

their professional obligations, as well.”

Policies Related to Health and Safety

Alcohol and Other Drugs Policy

CMSRU adheres to the Rowan University Alcohol and Other Drugs Policy

POLICY:

Alcohol and Other Drugs Policy

PURPOSE:

The policy states the University's (CMSRU’s) expectations regarding the use of alcohol and other drugs by students,

student organizations, faculty and staff. The policy also serves to articulate compliance and obligations with local, state

and federal laws which includes the Drug-Free Schools and Communities Act.

ACCOUNTABILITY:

Under the direction of the Rowan University President, the Rowan University Vice President for Student Affairs, the

Cooper Medical School of Rowan University Associate Dean for Student Affairs and Assistant Dean for Student Affairs

or designee shall implement and ensure compliance with this policy.

SCOPE:

This policy applies to all students, faculty and staff of Rowan University and Cooper Medical School of Rowan

University.

REFERENCES

Rowan University Student Code of Conduct

POLICY:

1.Rowan University (CMSRU) is committed to the pursuit of a quality education by providing an environment which

promotes respect, safety, and optimal health and well-being to all members of the campus community. This includes

students, faculty, staff, administration, alumni, and Rowan University (CMSRU) guests. Alcohol and illicit drug use

can pose many safety and health risks. Such use may result in impaired judgment and coordination, physical and

psychological dependence, damage to vital organs, inability to learn and retain information, psychosis and severe

anxiety, unwanted or unprotected sex, injury, and death. In light of this, the Rowan University (CMSRU) Alcohol and

Other Drugs Policy prohibits all use of illegal drugs and only permits the consumption of alcoholic beverages in a

manner that is responsible and adheres to restrictions imposed by law and University (CMSRU) standards of conduct.

Rowan University (CMSRU) does not accept misuse of illicit drugs or alcoholic beverages as an excuse for violations

of any University (CMSRU) policies. Emphasis is placed on responsible and legal use of alcohol. Responsible

drinking is the use of alcohol in ways that do not have negative effects on either the individual or the community and

do not violate the law. The preparation, sale, service and consumption of alcoholic beverages must comply with the

limitations established by University (CMSRU) policies, local ordinances, state laws and federal laws. As an

institution of higher education and an employer, Rowan University (CMSRU) is obligated to abide by and enforce

provisions in the Drug-Free Workplace Act of 1988 and Drug-Free Schools and Communities Act.

2.Behavior at off-campus events, which are not sponsored or funded by Rowan University (CMSRU) or a University

(CMSRU) recognized organization, will be subject to the University (CMSRU) discipline system if the conduct

violates local, state or federal law or when the University (CMSRU) determines that the conduct has a direct impact

on the educational mission and interests of the University (CMSRU) and/or the safety and welfare of the University

(CMSRU) community.

3.Violations will result in disciplinary sanctions as specified in sections entitled “Consequences for Non-Compliance”

and “Parental Notification for Student Violations of the Alcohol and Other Drugs Policy.”

4.Rowan University (CMSRU) Regulations

a. In compliance with the Drug Free Schools and Communities Act and the Drug-free Workplace Act, Rowan

University (CMSRU) prohibits the unlawful possession, sale, use or distribution of alcohol and illicit drugs on

campus or as part of any of its sponsored events.

b. In addition to the legal requirements from the New Jersey Statute, Title 2C, the following University (CMSRU)

regulations must be observed whenever alcoholic beverages are served, sold or consumed in approved facilities

on campus, in University (CMSRU)-owned or operated residential facilities, or at university (CMSRU)

sponsored events.

c. The Office of the Associate Vice President for Student Affairs and Dean of Students has been charged with

overall responsibility to administer, support, and enforce the Alcohol and Other Drugs Policy. This office also

reserves the right to suspend alcohol privileges temporarily when it is in the best interest of the University

(CMSRU) community. Additional personnel involved in the administration, support, and/or enforcement of the

policy include, but are not limited to, Greek Affairs, Community Standards, Athletics, Student Affairs,

Residential Learning and University Housing, Public Safety, Dining Services, Faculty, Staff, Human Resources

and Counseling and Psychological Services. The Associate Vice President for Student Affairs and Dean of

Students may convene an ad hoc board to review policy details of process and educational approach.

5.Illegal Drugs

a. The intent of, actual distribution of, sale of or manufacturing of drugs, narcotics, barbiturates, hallucinogens,

marijuana, steroids, amphetamines or any other controlled substance is prohibited.

b. The possession or use of controlled dangerous substances, marijuana, steroids or narcotics, including, but not

limited to: opium (morphine, codeine, heroin), prescription drugs in possession of someone other than the

prescribed individual, misuse of prescribed drugs and every other substance not chemically distinguishable from

them (i.e. imitation products, such as bath salts and/or K2) as well as any drug paraphernalia, on campus or in

any University (CMSRU)-related premises is prohibited.

6.Medical Marijuana

a. Medical marijuana, while legally permitted in New Jersey under the “New Jersey Compassionate Use Medical

Marijuana Act,” is prohibited on Rowan (CMSRU) campuses.

b. Rowan (CMSRU) is subject to the Controlled Substances Act, which classifies marijuana as a Schedule I drug.

Accordingly, the use, possession, cultivation or sale of marijuana violates federal policy. Importantly, Federal

grants are subject to Rowan’s (CMSRU’s) compliance with the Drug Free Communities and Schools Act, and

the Drug Free Workplace Act, which also prohibit the university (CMSRU) from allowing any form of

marijuana use on campus.

c. Thus, although students, staff and faculty who legally obtain a medical marijuana “ID card” from the New

Jersey Department of Health and Senior Services are allowed to possess and consume certain quantities of

marijuana, doing so is not permitted on Rowan’s (CMSRU’s) property or at university (CMSRU)-sponsored

events (either on or off campus).

d. Sharing medical marijuana with individuals who do not have a medical marijuana prescription is prohibited.

Given that the use and/or possession of medical marijuana is prohibited on Rowan (CMSRU) property, any

student, staff or faculty member who legally obtains a medical marijuana ID card should contact the Academic

Success Center – Disability Resources (students) or the Office of Employee Equity and Labor Relations

(staff/faculty) to discuss any possible on-campus accommodations (excluding the ability to use or possess

medical marijuana on Rowan (CMSRU) property).

7.Alcohol at Campus Events

a. Rowan University (CMSRU) students, faculty, staff, guests, and facilities users, who are 21 years and older,

may only possess, purchase, and consume alcoholic beverages at locations which are licensed to sell alcohol or

where consuming it is legal and authorized.

b. The University (CMSRU) and/or management of the facility in use have the right to request identification and

proof of age from all persons seeking admission to an event on campus at which alcohol will be served.

c. Intoxication is prohibited, regardless of age. Behavioral symptoms frequently associated with intoxication will

be considered in determining intoxication. These symptoms may include, but are not limited to, the following:

impaired motor skill coordination, difficulty communicating, vomiting, glazed/red eyes, the smell of alcohol on

one's breath, verbal and/or physical aggressiveness, destructive and/or disruptive behavior, and engaging in any

behavior which may endanger oneself or others.

d. Carrying open containers of alcohol is strictly forbidden in public areas of the University (CMSRU), i.e.

academic buildings, the Chamberlain Student Center, parking lots and common grounds, regardless of age.

e. Any marketing, advertising and promotion of alcoholic beverages on campus is prohibited. All advertisements

for social events at which alcohol is served will not make reference to the amount of alcohol available. There

will be no publicity distributed or posted indicating the availability of alcoholic beverages, except to indicate

legal age requirements for admission.

f. Non-alcoholic beverages must also be served whenever alcohol is served/sold and must be displayed as openly

as the alcohol. Food must be served in adequate amounts when alcoholic beverages are served or sold.

g. Except in authorized designated areas, alcohol is strictly prohibited in athletic facilities, at athletic events and at

any "tailgating."

h. No event will include any kind of a “drinking contest” or “drinking game,” or feature any inducements to

consume excessive amounts of alcohol.

i. For a listing of consequences for noncompliance, please refer to Sections VI. – “Consequences for Non-

Compliance” and VII. – "Parental Notification for Student Violations of the Alcohol and Other Drugs

Policy.

8.Alcohol in University Housing (Living Units)

a. Designated “Dry” Living Units

i. Alcohol is not permitted within undergraduate living units serving predominately underage students

(Chestnut, Evergreen, Holly Pointe Commons, Magnolia, Mimosa, Mullica, or Willow halls- excluding

graduate and professional staff living units). These areas are designated "dry" living units. No one,

regardless of age, is permitted to possess, consume or be in the presence of alcohol in these areas.

ii. All other living areas (Edgewood Park, International House, Nexus Apartments, Rowan Blvd., Triad,

Townhouses, Whitney Center or any temporary University housing such as a hotel) in which any assigned

resident is under the age of twenty-one is a designated “dry” living unit. No one, regardless of age, is

permitted to possess, consume or be in the presence of alcohol in these areas. It is the responsibility of

each resident to know if alcohol is permitted within their living unit.

b. “Wet” Living Units

i. Alcohol is permitted only in living units in which all assigned residents are of legal drinking age. These

are considered “wet” living units. It is the responsibility of each resident to know if alcohol is permitted

within their living unit.

c. Presence in any living unit (room, apartment or townhouse) where an alcohol policy violation is taking place,

even if not actually in possession of or consuming alcoholic beverages may result in disciplinary action.

d. Residents holding a gathering in their living unit where an alcohol violation is taking place will be considered

the hosts. Hosts may be held responsible for injury or damage occurring to any person or property in which the

consumption of alcohol was a contributing Hosts will be subject to disciplinary action and may receive harsher

sanctions.

e. At the time of an alcohol violation, all alcohol and containers will be confiscated and properly disposed of

regardless of the age of the occupant(s) or the designation of the living unit as “wet” or “dry.”

f. Kegs and beer balls are prohibited in all living units at all times.

g. Possession of grain alcohol is prohibited at all times.

h. Students of legal drinking age may transport an alcoholic beverage as long as it is in its original closed

container.

i. Consumption of any form of alcohol in an open container, including but not limited to cups, cans, plastic

containers or bottles, is prohibited outside a student's living unit and/or any outside campus area.

j. Games or activities that encourage excessive drinking of alcohol (e.g. beer pong, flip cup, beer funnels, etc.) or

the serving of alcohol that leads to the endangerment of an individual's well-being or property damage will not

be tolerated.

k. Consumption of alcohol to the point of intoxication, regardless of age, is prohibited. Behavioral symptoms

frequently associated with intoxication will be considered in determining intoxication. These symptoms may

include, but are not limited to, the following: impaired motor skill coordination, difficulty communicating,

vomiting, glazed/red eyes, the smell of alcohol on one's breath, verbal and/or physical aggressiveness,

destructive and/or disruptive behavior and engaging in any behavior which may endanger oneself or others. A

person in this condition may be asked to leave the campus. If the person is a student, the student's family or

emergency contact may be called to assist. Other guests may have a taxi/ride called (at the intoxicated person's

expense) to take them to their permanent residence.

l. Alcoholic beverage containers and paraphernalia, including but not limited to empty cans and bottles, are not

permitted as room decorations in any living unit.

9.Alcohol in University Housing Regulations state:

a. Persons under the age of twenty-one MAY NOT:

i. Be in possession of or in the presence of alcohol in any living unit.

ii. Permit persons to bring in or consume alcohol in their living unit.

iii. Carry opened or unopened alcoholic beverage containers any place on campus.

iv. Provide alcohol to any persons on campus.

v. Possess alcohol displays made up of empty alcoholic beverage containers.

b. Persons twenty-one and older MAY NOT:

i. Consume alcohol outside of a living unit (lobby, hallways, stairwells, grounds, etc.).

ii. Possess/Consume alcohol in a "dry" living unit.

iii. Permit underage persons to possess or be in the presence of alcohol in their living unit.

iv. Provide alcohol to others under the age of twenty-one.

v. Charge in any way for alcohol consumption by others.

vi. Possess kegs, beer balls, or paraphernalia that promotes excessive consumption of alcohol.

vii. Possess alcohol displays made up of empty alcoholic beverage containers.

c. Persons twenty-one and older MAY:

i. Possess/Consume alcohol in their living unit if it is designated “wet” and all those present are of legal

drinking age.

ii. Possess/Consume alcohol in another living unit if it is designated “wet” and all those present are of

legal drinking age.

iii. Transport unopened alcoholic beverage containers within University housing areas that are packaged

and out of plain view.

iv. Provide alcohol in their living unit to others of legal drinking age.

d. Persons who are present, within University housing, where alcohol is being consumed by those over or under

the legal drinking age will be presumed to have been drinking or in possession of alcohol if Public Safety, RAs,

RDs, or other University officials are called to the scene. This is because it is not possible to distinguish who is

actually consuming or possessing alcohol on an individual basis where a number of persons are present.

e. Off-Campus Events

i. University-affiliated events are covered by this policy, even though they may take place off campus. A

University affiliated event is defined as an off-campus gathering of members of the Rowan University

(CMSRU) community (and/or their guests) which is sponsored or funded in whole or in part by Rowan

University (CMSRU). This includes Study Abroad, field trips and professional meetings attended by

employees. Private off-campus events which are not sponsored or funded by Rowan University

(CMSRU) will also be subject to the University discipline system if the conduct violates University

regulations or local, state, or federal law, or when the University determines that the conduct has a

direct impact on the educational mission and interests of the University and/or the safety and welfare of

the University community. Please be aware that the University reserves the right to hold a student

responsible for actions at their residence even if they were not present at the time of the incident. In

such a case, the student would be required to produce confirming evidence that s/he was not involved.

ii. Sponsors, coaches and/or organization advisers are expected to ensure that their respective student

organizations/groups take reasonable precautions in their activities in order that policies and laws

governing alcohol/illegal drugs are not violated and that the welfare of their members is not

endangered. The Associate Vice President for Student Affairs and Dean of Students in conjunction with

the sponsors, advisers or coaches may designate an event as non-alcoholic and/or determine the

conditions under which the consumption of alcohol may be permitted by students of legal drinking age.

Therefore, a sponsor, adviser or coach may prohibit the service, possession, or consumption of alcohol

by any person, regardless of age, at University-affiliated or University-funded activities (e.g., retreats,

conferences, intercollegiate athletic events, etc.). Sponsors, advisers or coaches will inform the student

organizations of their decision(s) regarding the nature of the event prior to the scheduled date of the

activity.

iii. The University expects that the existing state, local or premises regulations which prohibit illegal drugs

or regulate the service, sale, possession, or consumption of alcohol will be supported and enforced at

University-sponsored events.

iv. Under New Jersey Statute, it is unlawful for any operator or passenger in a motor vehicle to possess an

open container of an alcoholic beverage, regardless of age. In addition, the University prohibits the

service, sale, or consumption of alcoholic beverages while in transit in any motor vehicle, to or from

any University-affiliated event. This applies to all students, faculty, staff, alumni and their guests,

regardless of legal drinking age.

v. Alcoholic beverages will not be permitted at intercollegiate athletic events.

CONSEQUENCES FOR NON-COMPLIANCE

1. The University (CMSRU) is concerned that individuals make responsible decisions regarding the use of legal and

illegal substances. All members of the campus community found in violation of the Rowan University (CMSRU)

Alcohol and Other Drugs Policy will be subject to disciplinary action.

2. A student found violating the Alcohol and Other Drugs Policy will be considered to have violated the Student Code

of Conduct and be subject to sanctions commensurate with the offense consistent with local, state and federal law,

up to and including expulsion from the university (CMSRU), as well as the possibility of revocation of the privilege

to consume alcohol on campus and/or to attend University (CMSRU) affiliated events at which alcohol will be

served or consumed. Referrals to educational and other sanctioned programs sponsored by the Wellness Center at

Winans or CMSRU may be required.

3. Organizational sanctions for violations of the Alcohol and Other Drugs Policy by campus groups may include

written reprimand, restriction or loss of privileges, and loss of official recognition. In addition, the campus group

may be mandated to participate in educational programs. Individual members of the group may also be individually

sanctioned for their involvement in the violations pursuant to this section.

4. Violations of the University (CMSRU) Alcohol and Other Drugs Policy by a University (CMSRU) employee will

be referred to the individual's supervisor for the appropriate administrative action consistent with the state

regulations and applicable agreements between the state and employee bargaining units. An employee may be

disciplined for violation of this policy consistent with local, State, and Federal law up to and including termination

of employment and referral for prosecution.

5. Violations of the University (CMSRU) Alcohol and Other Drugs Policy by persons who are not members of the

University (CMSRU) community may result in their being banned from the Rowan University (CMSRU) campus or

from specific facilities and/or subject to arrest for trespass. Contractors are subject to all University (CMSRU) rules

and regulations.

6. Any violation which occurs while an event is in progress may subject the violator to immediate removal from the

area.

7. When violations or other circumstances occur at events which, in the judgment of University (CMSRU) officials,

constitute a threat to life or property or which create a substantial risk thereof, the event may be terminated. It is

expected that such authority will be exercised only in extraordinary and/or emergency circumstances.

8. This policy does not supplant or supersede statutory or administrative law at the federal, state, county, or municipal

level. Strict compliance with such laws will be the responsibility of all organizations and individuals. Violators of

the law may be subject to penalties imposed by a court or other empowered board, agency, or commission, in

addition to any action taken by Rowan University (CMSRU).

PARENTAL NOTIFICATION FOR STUDENT VIOLATIONS OF THE ALCOHOL AND OTHER DRUGS

POLICY

Rowan University (CMSRU)'s Alcohol and Other Drugs Policy outlines the University's (CMSRU’s) position regarding

the unauthorized possession, use or distribution of alcohol and controlled substances on campus. A 1998 amendment to

The Family Education Rights and Privacy Act of 1974 authorizes higher education institutions to inform a parent or

guardian of any student under age 21, who has been found in violation of any federal, state or local law or any rule or

policy of the institution governing the use or possession of alcohol or controlled substances. The Office of Community

Standards may notify parents/guardians of students under 21 years of age when a student is found responsible for a

violation of the Alcohol and Other Drugs Policy. Please note: Citations given by the law enforcement unit of a university

are not covered by FERPA. Therefore, Rowan Public Safety may notify parents/legal guardians when citations have been

issued by law enforcement officials, without waiting for a hearing or any other due process.

ATTACHMENTS

1. Attachment 1 - Summary of Applicable State and Local Laws Regarding Alcohol Offenses and Penalties

2. Attachment 2 - Summary of Applicable State and Federal Laws Regarding Drug Offenses and Penalties

3. Attachment 3 - State of New Jersey Drug-Free Workplace Act - Executive Order No. 204

4. Attachment 4 - Commonly Abused Drugs

5. Attachment 5 - Education and Prevention - Important Telephone Numbers

6. Attachment 6 - Biennial Review of Policy and the Alcohol and Drugs Education Program

Anti-Violence Policy

POLICY:

Anti-Violence Policy

PURPOSE:

To ensure an environment of respect and safety that is free from intimidation, threats and acts of violence.

SCOPE:

All individuals and activities on CMSRU property or on any property used for CMSRU activities or by CMSRU student

groups.

DEFINITIONS:

Inappropriate behaviors covered by this policy include but are not limited to:

● Name calling

● Profanity

● Sexual comments

● Obscene language or gestures

● Blatantly disregarding university and/or CMSRU policies and procedures

● Ethnic, racial, religious or gender epithets

● Stealing

● Making verbal threats or conveying threats by note/letter and/or electronically

● Physical abuse or attack

● Inappropriate touching

● Destroying property or any vandalism, arson, or sabotage

● Throwing objects

● Possession of a weapon

⮚ Weapons: An instrument of offensive or defensive combat or something that is used to cause injury to an

individual. Under New Jersey statutes, “Weapons” are defined as “Anything readily capable of lethal use

or of inflicting serious bodily injury.” The term includes, but is not limited to air guns, spring guns or

pistols or weapons of a similar nature in which the propelling force is from an elastic band, carbon

dioxide, compressed or other gas or vapor, air or compressed air or ignited by compressed air and ejecting

a bullet or missile, knives, clubs, night sticks, metal knuckles, firearm silencers, armor piercing

ammunition, zip guns, chemical substances, i.e. pepper spray over ¾ oz and Tasers. (See N.J.S.A.2C:39-6

setting out permissible conditions for carrying chemical substances for personal self-defense.)

PROCEDURE:

Cooper Medical School of Rowan University (CMSRU) does not tolerate threatening or violent behavior of any kind.

Identification of early indicators of a potentially violent behavior as well as other behaviors that are clearly violent will be

acted on as necessary.

Any individual, who believes they have been subjected to, has observed or has knowledge of actual or potential violence

should immediately notify Public Safety, the Associate Dean for Student Affairs or designee and/or local police. Incident

reports should be completed with CMSRU Security or local police as required. If any imminent physical threat or danger

exists, students should contact CMSRU Security (856-361-2880), or dial the emergency number 911. CMSRU will

respond promptly to threats or acts of violence. This response may include local law enforcement agencies, if appropriate.

CMSRU students who commit threats or acts of violence will be subject to strong disciplinary action, up to and including

academic dismissal. Qualifying events will be reported as required by Clery Act compliance. For more information on the

Clery Act, please refer to: https://sites.rowan.edu/publicsafety/clery/

Rowan University will support criminal prosecution of those who threaten or commit violence against its employees,

students, or visitors within its facilities, programs, and activities.

CMSRU will attempt to reduce the potential for internal violence through student wellness and educational programs.

Individual counseling will be utilized as needed. CMSRU will work to positively affect the attitudes and the behavior of

its students and faculty.

Possession, use or display of weapons, or ammunition is prohibited on property owned by or under the control of

CMSRU. For more information, please refer to Rowan University’s Weapons and Prohibition. on Campus Policy.

(https://confluence.rowan.edu/display/POLICY/Weapons+Prohibition+on+Campus

)

For more information, please refer to Rowan University’s General and Safety and Security

Policy.(https://confluence.rowan.edu/display/POLICY/General+Safety+and+Security

)

COVID-19 Exposures and Testing Policy

POLICY:

This policy addresses known or suspected COVID-19 exposures and testing.

PURPOSE:

To create procedural guidelines for students who have experienced COVID-19 exposure or have symptoms consistent

with COVID-19.

SCOPE:

This policy applies to all CMSRU students.

DEFINITIONS:

SARS-COV-2 is a virus that infects humans and spreads primarily through droplets of saliva or discharge from the nose or

mouth when an infected person coughs or sneezes.

COVID-19 is an infectious disease caused by a new strain of coronavirus that may cause mild to severe illness, including

death.

Quarantine: separates someone who might have been exposed to COVID-19 away from others to see if they become sick.

Isolation: separates someone infected with COVID-19 from those who are not infected or sick.

Boosted: Student has received all recommended COVD-19 vaccine doses including the booster dose. A student is

considered boosted 7 days after the booster dose is received. Students are required to send a copy of their vaccine card to

Student Health if the vaccine was not given at Cooper University Health Care (CUHC).

Vaccinated: Student is ≥2 weeks following receipt of the second dose in a 2-dose series, or ≥2 weeks following receipt of

one dose of a single-dose vaccine.

Unvaccinated: Student does not fit the definition of vaccinated, include those whose vaccination status is unknown.

Close contact : Defined by the CDC as someone who was less than 6 feet away from the infected person (laboratory-

confirmed or a clinical diagnosis) for a cumulative total of 15 minutes or more over a 24-hour period.

Personal Protective Equipment (PPE): Equipment designed to protect the wearer from injury or the spread of illness or

infection. CMSRU and CUHC will determine the appropriate PPE to be worn in the buildings, labs and clinical settings.

Students may be further instructed by their preceptor and clinical rotation. PPE is available to all students. When in the

Medical Education Building, students should follow guidelines from the Center for Disease Control, New Jersey

Department of Health, and Rowan University regarding face coverings indoors. For aerosolizing generating procedures,

students should wear eye protection as a face shield or indirect ventilated goggles with a fitted respirator.

VACCINATION:

COVID-19 vaccination and booster are no longer required. Vaccination requirements will be based upon Rowan

University, CMSRU and CUHC guidelines.

Students are required to send a copy of their vaccine card to Student Health if the vaccine was not given at CUHC.

PROCEDURE:

Following CUHC’s COVID-19 Policy, and in accordance with related Rowan University policies, students should not

report to class or the clinical environment if they have:

• Respiratory symptoms alone (cough, shortness of breath or difficulty breathing)

OR at least two of these symptoms

• Fever (100.0 degrees F or higher)

• Chills

• Muscle pain

• Headache

• Sore throat

• New loss of taste or smell

• GI symptoms such as nausea/vomiting and diarrhea

Students should report illness to their Primary Care Provider (PCP) and Student Health immediately. Students may not

return back to school or the clinical environment without first speaking with Student Health.

Symptomatic students may not return to school or the clinical environment without speaking with Student Health. Student

Health must have received the CMSRU COVID-19 Return to School/Clinical Environment/ Clearance from Primary Care

Provider form and clearance from CUHC Employee Health, if applicable (see below).

EXPOSURES:

Symptomatic Exposures:

PCR testing is required. Isolation will be determined based upon PCR results and symptoms. Students are responsible for

sending test results to Student Health as they are not sent to Student Health directly.

If a student tests positive for COVID-19 by home antigen test, PCR testing is not required. The student must send the

results to Student Health which will then be placed into their Epic chart.

Students must contact Cooper Employee Health regarding their exposure if the student has been in the clinical

environment within the past 2 days of exposure or plans to be in the next 10 days.

The student should monitor for symptoms using the CMSRU log, wear a surgical mask indoors and eat alone for the next

10 days.

Symptomatic students may not return to school or the clinical environment without speaking with Student Health. Student

Health must have received the CMSRU COVID-19 Return to School/Clinical Environment/ Clearance from Primary Care

Provider form and clearance from CUHC Employee Health, if applicable.

Asymptomatic Exposures:

For a student who has been exposed to someone with COVID-19 AND who:

• Has been boosted

- No quarantine.

- Testing is not required unless the student becomes symptomatic.

- Wear a tight-fitting mask indoors and eat alone for 10 days from the exposure.

- Wear appropriate PPE in clinical areas per CUHC guidelines.

- Monitor for symptoms using the CMSRU Monitoring Log for 10 days. The student must isolate, get PCR testing and

contact Student Health immediately if becomes symptomatic.

- Students must contact Cooper Employee Health regarding their exposure if they have been in the clinical environment

within the past two days or plan to be in the clinical environment within the next 10 days.

TESTING:

Students with symptoms consistent with COVID-19-like illness should have PCR testing.

All testing should be by PCR. If not available or the student chooses to use rapid at home testing and it is positive, this test

is considered positive and does not need follow up PCR testing. If the test is negative and the student is symptomatic,

PCR testing is required.

PCR testing is offered through CUHC. A student’s insurance may be billed for testing. Students are required to contact

Student Health if they have testing due to illness. Students are required to follow up on test results and report them to

Student Health. Test results performed at CUHC are not sent to Student Health. Students must isolate if the testing is

positive. If a student has testing outside of CUHC, a student must send these results to Student Health.

COVID-19 Negative:

If the COVID-19 testing is negative, a student may return to school and the clinical environment with a significant

reduction in symptoms and be afebrile for 24 hours without the use of antipyretic medication for 24 hours. The Return to

School/Clinical Environment Request from Primary Care Provider form must be completed and received by Student

Health. Symptomatic students may not return to school or the clinical environment without speaking with Student Health.

COVID-19 Positive:

If the COVID-19 testing is positive, the student is required to send testing results to Student Health.

If a student tests positive for COVID-19 by home antigen test, PCR testing is not required. The student must send the

results to Student Health which will then be placed into their Epic chart.

The student must isolate for 5 days with or without symptoms. Day One is the first full day after symptoms develop

or the first full day after a positive test. The student should remain in their own bedroom and bathroom, if possible away

from all household contacts. The student should wear a tight-fitting mask if they must enter common areas of the home.

The student must contact Cooper Employee Health at 856-342-2077 regarding their positive test result if the student has

been in the clinical environment within the 2 days of symptom onset, 2 days of a positive test, or plans to be in the clinical

environment in the next 10 days. Employee Health will contact the student at the end of their isolation period to discuss

date of return. Student Health must receive clearance from Employee Health for the student to return to school or the

clinical environment.

The student may return to school or the clinical environment on day 6 if there is a significant reduction in symptoms and

the student has not had fever for 24 hours without the use of antipyretics for 24 hours. If the student develops symptoms

after testing positive for COVID-19, the 5-day isolation period will start over. Day 0 is the first day of symptoms or date

of testing.

The Hospital Epidemiologist will be consulted for students with severe or critical illness or who are

immunocompromised.

Symptomatic students may not return to school or the clinical environment without speaking with Student Health. Student

Health must receive the CMSRU COVID-19 Return to School/Clinical Environment/ Clearance from Primary Care

Provider form and clearance from CUHC Employee Health.

Upon return to school or the clinical environment, the student must continue to wear a tight-fitting mask indoors and eat

alone for 5 additional days.

Notifications to Exposures if a Student Tests Positive for COVID-19:

It is the responsibility of the student to personally inform all close contacts (including other students, faculty and staff) of

their positive COVID-19 test result. Tracing is not performed by Student Health.

Cooper Employee Health will only contact trace for CMSRU students who have been in the clinical environment. They

will inform Cooper employees and CMSRU students who have had a high risk exposure in the clinical environment only.

The CMSRU Office of Student Affairs is notified that a medical student has tested positive for COVID-19 but are not

provided the student’s name. The Hospital Epidemiologist is also notified of a student testing positive for COVID-19.

Refusal of Testing:

If a student refuses testing and is symptomatic, the student must self-isolate for at least 5 days from when symptoms first

started AND for 24 hours after fever has resolved without the use of fever-reducing medications and with a significant

improvement in symptoms. Upon return to school or the clinical environment, the student must continue to wear a tight-

fitting mask indoors and eat alone for 5 additional days

POST-VACCINATION SYMPTOMS:

Students must report COVID-19-like symptoms to Student Health. PCR testing will be ordered and the student will be

excused from school/clinical environment at least until results are discussed with Student Health. Further isolation

pending testing results.

CALLING STUDENT HEALTH:

Students who have symptoms consistent with COVID-19 like symptoms should immediately isolate at home and contact

their PCP and Student Health.

Students who call Student Health must identify themselves as a CMSRU student and should ask to speak with a

nurse. The nurse will triage the student, discuss testing and also inform the student to contact their PCP if not Student

Health.

1) If the PCP is a Student Health provider, the student will be triaged and/or given an appointment.

2) If the PCP is not a CMSRU Student Health provider, the student will be asked to contact their PCP. If the student

prefers to utilize the services of Student Health, the student will be offered to change the PCP to the Student Health

provider for the evaluation and testing of COVID-19 and form completion.

If the student contacts a PCP other CMSRU Student Health, their PCP will be responsible to discuss testing, treat

symptoms, and complete all forms to return the student back to school/clinical environment. The student must utilize the

Return to School/Clinical Environment Forms by Primary Care Provider posted on Canvas. It is the student’s

responsibility to provide the forms to their PCP and ensure Student Health has received these forms. Students may not

return to school or the clinical environment without first speaking with Student Health.

Weekends and After Hours:

A CUHC PCP is on-call to speak with any student 24 hours a day and seven days a week. The student should identify

themselves as a CMSRU student and ask the message be routed to the appropriate PCP if within CUHC as well as the

Student Health provider. The on-call physician may be reached by calling the CMSRU Student Health office number at

856-968-8695 for Dr. Rozengarten’s office (Camden) or 856-536-1515 for Dr. Flaherty’s office (Cherry Hill). Students

who contact the on-call physician should contact their PCP the next business day to ensure proper evaluation. Students

should contact Student Health the next business day if the student has not received a call from the physician.

Any student experiencing acute distress should proceed to the nearest emergency department or call 911.

Students may always contact Student Health with any concerns or questions.

HOUSING FOR ISOLATION OR QUARANTINE:

Housing may be available to students who are unable to fully self-isolate when symptomatic or COVID-19 positive or if

quarantine is necessary and they cannot quarantine in their own accommodations. They should contact the Office of

Student Affairs to arrange housing.

VISITNG STUDENTS:

All visiting students from outside medical schools should inform the following of any COVID-19 exposure and/or

symptoms: their course director, their home institution’s Student Health, and Cooper University Healthcare Employee

Health.

COVID-19 RETURN TO SCHOOL/CLINICAL ENVIRONMENT CLEARANCE

Access the COVID-19 Return to School/Clinical Environment Clearance form online.

Inclement Weather Policy

POLICY:

Inclement Weather Policy

PURPOSE:

The purpose of this policy is to develop a plan of operation should there be a weather emergency causing a closure

of the Cooper Medical School of Rowan University.

SCOPE:

This policy applies to all CMSRU medical students, visiting medical students, and staff members.

PROCEDURE: CMSRU will remain open, and classes will be held during inclement weather whenever possible,

safety permitting. The decision to close Rowan University (including CMSRU) is reserved to the President of

Rowan University or their designee. The CMSRU dean or individual supervisors are not permitted to make this

decision.

Rowan University will notify the students, faculty, and staff of a university closing through the following ways:

• Rowan Alert Message System (register)

o Email (Rowan Advisory email)

o Voicemail

o Text message

The Rowan University President will make decisions for closure by 6 AM.

Instructions for M1 and M2 students:

1. Follow the Rowan Alert Message System for information on closures and/or delays.

2. Log into your Learning Management System (Canvas) and closely monitor your Rowan email for information

on adjustments to the daily/weekly schedule and other information from your course directors and the Office

of Medical Education.

3. Virtual teaching sessions will be held as scheduled.

4. Whenever possible, in-person classes will automatically convert to virtual sessions, including active learning

group, Scholars Workshop sessions, lectures in any course, and non-dissection afternoon application sessions

(whenever possible). Students should check their email or Canvas LMS for all relevant messages and specific

session instructions or cancellations.

5. Announcements related to assessment delivery (i.e., examinations, OSCEs, etc.) that coincide with inclement

weather days will be made in advance of the assessment's scheduled delivery. Be sure to monitor your Rowan

email accounts for important scheduling information.

Instructions for M3 and M4 students:

1. Follow the Rowan Alert Message System for information on closures and/or delays. If you see a Rowan

Advisory email or text message that states the following - Rowan Advisory: Due to the weather conditions

throughout the region, the majority of Rowan University's campuses and facilities are closed TODAY, that

indicates that students do not have to report to inpatient / outpatient clinical activities at Cooper University

Healthcare. As a courtesy, please contact your preceptors or clerkship directors.

2. If there is a delay, contact your outpatient preceptors to determine if their offices will be open and if you can

travel safely.

3. If you determine that you cannot travel safely (even if CMSRU is open), alert your preceptor and request an

excused absence from the CMSRU attendance system. If you are on an inpatient service, contact your

clerkship director and departmental education coordinator to inform them of your inability to travel to your

clerkship site and request an excused absence from the CMSRU attendance system. Missed clinical time will

be made-up at the discretion of the preceptor or clerkship director as appropriate.

4. Log into your Learning Management System (Canvas) for information on adjustments to the M3

transdisciplinary schedule and other information from your course and clerkship directors and the Office of

Medical Education.

5. Virtual teaching sessions and orientations will be held as scheduled.

6. Announcements related to assessment delivery (i.e., examinations, OSCEs, etc.) that coincide with inclement

weather days will be made in advance of the assessment's scheduled delivery. Be sure to monitor your Rowan

email accounts for important scheduling information.

Infectious and Environmental Hazards, Needlesticks and Bloodborne

Pathogens Exposure Policy

POLICY:

Infectious and Environmental Hazards, Needlesticks and Bloodborne Pathogens Exposure and Protection of Patients

from Blood Borne Pathogens and other Communicable Diseases

PURPOSE:

This policy is instituted to ensure appropriate education is facilitated to prevent, prepare, and protect CMSRU

students from potential infectious and environmental hazards, needlesticks and bloodborne pathogens exposure and

to provide protocols to follow in the event of these exposures. It is also to protect patients from students who are

infected with blood borne pathogens or other communicable diseases.

SCOPE:

This policy applies to all CMSRU medical students and visiting students.

DEFINITIONS:

The Cooper Learning Network (CLN) provides online training modules to students regarding safety measures

surrounding environmental risks and exposure to hazards and infectious materials. Infectious materials include

anything coming from someone's body other than your own (for example, blood and bodily fluids) and all lab

cultures.

PROCEDURE:

All CMSRU students receive annual training on infectious and environmental hazard methods of prevention and

safety, including protocols surrounding access to care and treatment after exposure. The protocols included in this

policy must be followed whenever there is the potential for exposure. Students are expected to comply with

recommended infection prevention precautions and procedures at the point of patient care at each clinical site.

1. Each student is responsible for their own safety throughout their education at CMSRU.

a. CMSRU will provide students with education and information regarding appropriate policies and

procedures to follow to protect themselves during their educational experience and when they are

potentially exposed to blood-borne pathogens, communicable diseases, and other environmental hazards.

CMSRU students are expected to comply with all infection prevention policies and procedures.

2. Education and Training

a. All students receive annual online training surrounding infection prevention and procedures to follow in

the event of an exposure.

b. All students receive annual Occupational Safety and Health Administration online training and education

regarding needle sticks, sharps, and body fluid procedures and the prevention of blood-borne pathogen

transmission.

c. All students receive annual hazard communication online training with respect to environmental hazards

and appropriate protective measures.

d. All students receive annual online safety instruction to better protect patients, members of the healthcare

team and themselves in the clinical environment.

e. Prior to their first clinical experience, students receive online and in-person instruction regarding the

prevention and understanding of all infectious diseases they may encounter in a clinical setting.

f. An exposures checklist (laminated card) detailing the steps to follow in the event of an exposure is

provided to all CMSRU students.

3. Standard Precautions

a. Consider blood, body fluids and tissue from ALL PATIENTS to be potentially infectious.

b. Perform hand hygiene before/after all patient contacts.

c. Wear gloves when exposure to blood and body fluids may occur, e.g., during phlebotomy. Change your

gloves and perform hand hygiene after each procedure and before contact with another patient.

d. Wear a gown, mask and goggles when blood or body fluids splashes may occur (e.g. during surgery,

placing nasogastric tubes, etc.).

e. Report immediately all incidents of blood and body fluid exposure of the following types:

f. Parenteral: needle stick, puncture or cut.

g. Mucous membrane: splash to eyes, nose, mouth.

h. Cutaneous: contact with blood and body fluids on ungloved hands or other skin surfaces that may be cut,

chapped, abraded, or affected by active dermatitis.

4. Immediate Response-Time Matters!

a. Clean wounds or punctures with soap and water.

b. Flush mucous membranes or skin copiously with water or saline.

c. DO NOT “force bleed” the wound.

d. DO NOT apply caustics (e.g. bleach, organic solvents, hard surface disinfectants, etc.).

e. When HIV post–exposure prophylaxis (PEP) is indicated, early treatment (within hours) is recommended.

f. Proceed Directly to Concentra Occupational Health Services or the Cooper University Health Care

Emergency Department (CUHC ED).

g. Please proceed directly to Concentra Occupational Health Services (856-338-0350) as soon as possible

and identify yourself as a CMSRU student. Concentra is located at 300 Broadway, Suite #101, Camden,

NJ, located across the street from the MEB. Concentra hours of operation are Monday-Friday, 7:30 AM to

5:00 PM. If the exposure occurs outside of Concentra’s hours of operation, please go directly to the

Emergency Department at CUHC.

5. After First Aid

a. Notify the staff and supervising resident and/attending physician and the Office of Student Affairs.

b. Carefully note the type of exposure, type of fluid/tissue involved and appropriate information about the

source patient. (risk factors, lab data)

c. Blood tests will be performed as appropriate.

d. Concentra will provide a schedule for follow up counseling and treatment, as necessary.

e. All initial costs of laboratory tests for properly reported occupational exposures or injuries are covered by

CUHC.

f. Treatment required post-exposure or for a clinical condition that develops as a result of an exposure or

injury should be covered by the student’s health insurance policy, and in addition by CUHC’s accidental

medical expense insurance, as stipulated in the Rowan University/Cooper University Health Care

Affiliation Agreement (March 8, 2016). The Office of the Dean at CMSRU will cover any residual

expenses for acute exposure or injury not covered by the medical student’s health or disability insurance.

The student will not be responsible for costs incurred as part of the treatment of an acute occupational

exposure or injury.

g. If a student is unsure whether they should participate in patient care, the student should contact the

Student Health Center or their treating PCP or specialist.

6. Learning Environment

a. Students who are potentially exposed to a patient with a communicable illness (e.g. meningitis, hepatitis,

HIV) are to be evaluated by Concentra or the CUHC ED, offered preventive medication if indicated, and

monitored for the development of illness by Concentra.

b. If a student has infection with a blood borne pathogen, they are required to confidentially discuss the

matter with the director of student health services. The goals are to protect infected students from

discrimination, protect student confidentiality, and protect patients during exposure prone procedures. The

director will assess risk to patients, educate the student about their condition, review practices, and

provide clinical care if the student does not want care from their own physician. The director may consult

an ad hoc committee including an advisory dean, the director or a designee from Concentra, an infectious

disease expert on the relevant pathogen, and a course director for whose course the student may have

restricted activities. The student may request participation from the physician overseeing their care. The

committee may recommend the student should not be in the clinical setting due to risk to

self/patients/coworkers, can be in the clinical setting with limited activities, or can be in the clinical setting

without restrictions. The committee may require a fitness for duty assessment prior to rendering a

recommendation. They may make recommendations about specific accommodations. All

recommendations will be made to the disability services provider.

c. In order to allow a student to return to the clinical setting following contraction of a communicable

disease or disability due to an exposure, the ad hoc committee will make its recommendation based on the

safety of all involved. If the disease or disability of the student can be accommodated, the student should

apply to disability services to request appropriate accommodations. If approved, the accommodations

would be reviewed and implemented by the Office of Medical Education. All information will be strictly

confidential.

d. CMSRU is dedicated to ensuring that students with chronic conditions are not discriminated against and

can continue in the educational program, despite the presence of a chronic condition, if at all possible with

or without accommodations.

7. Visiting Students

a. All students completing an away elective at CMSRU are required to complete OSHA training or

comparable environmental hazard training from their home institution.

b. In the event of an exposure, Visiting Students follow the same protocol as outlined in this policy and

should be directed to the Office of Student Affairs at studentaffairs@coopermed.rowan.edu

c. Visiting students are informed of this policy by email prior to commencing their rotations at CMSRU. In

addition, the policy is included the CMSRU Visiting Student Webpage and uploaded to the VSAS/VSLO

website. As part of the VSLO application process for visiting students who request rotations at Cooper

University Health Care, (CUHC) students must sign and attest they have read, understood and will abide

by the Infectious and Environmental Hazards, Needlesticks and Bloodborne Pathogens Exposure Policy.

d. An exposures checklist (laminated card) detailing the steps to follow in the event of an exposure is

provided to all visiting students.

Please also refer to the Student Healthcare Services Policy

REFERENCES:

29 CFR 1910 Occupational Exposure to Bloodborne Pathogens; Needlestick and Other Sharps Injuries

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=16265

29 CFR 1910.1200 Hazard Communication

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099

Impaired Student Process

POLICY:

Impaired Student Process

PURPOSE:

To identify and discourage all drug and alcohol use that can adversely affect academic or clinical performance and

has the potential to negatively impact the health and safety of peers, faculty, staff, or patients for which an impaired

student may have interaction. Cooper Medical School of Rowan University (CMSRU), in collaboration with Cooper

University Health Care (CUHC), will maintain an environment to ensure the safety of students, faculty, staff and

patients will not be compromised.

SCOPE:

Any impairment and/or related treatment efforts apply to all CMSRU students. CMSRU complies with the Rowan

University Policies General Safety and Security and Alcohol and Other Drugs Policies.

DEFINITIONS:

The term “drug” means a controlled dangerous substance, analog, or immediate precursor as listed in Schedules I

through V in the New Jersey Controlled Dangerous Substances Act, N.J.S.A. 24:21-1 and as modified in any

regulation issued by the Commissioner of the Department of Health. It also includes controlled substances in

Schedules I through V of Section 202 of the Federal Controlled Substance Act of 21 U.S.C. 812. This policy applies

to the use, possession or distribution of such items which is unlawful under the Controlled Substances Act. Such

term does not include the use of a drug taken under supervision by a licensed health care professional, or other uses

authorized by the Controlled Substances Act or other provisions of Federal law.

Impairment is defined as any physical, mental or behavioral disorder that interferes with the ability to engage safely

in professional activities.

Impairment, and the effects of the impairment on academic or clinical performance, can be acute or chronic.

● Examples of acute impairment can include, but are not limited to, the following: hallucinations, increased

agitation, paranoia, decreased level of consciousness, disorientation, loss of coordination, reduced capacity to

communicate, combative without provocation, unusual flare-ups or outbreaks of temper, verbal threats, use of

excessive profanity and odor of alcohol on the breath.

● Examples of chronic impairment can include, but are not limited to: absenteeism, tardiness, an increase in

errors made in the academic or clinical environment, a significant decrease in productivity, significant peer

problems, poor personal hygiene, sleepiness and poor judgment.

PROCEDURES:

Identifying an Acutely or Chronically Impaired Student; Returning the Student to Academic

Responsibilities; and Drug Testing

Impairment, whether acute or chronic, will be determined by the Associate Dean for Student Affairs or designee, in

collaboration with the Senior Associate Dean for Medical Education or designee, Student Support Services

Specialist and other medical consultants as necessary, based on a student's ability to adequately perform their

academic or clinical responsibilities. The process ensures an objective basis for documenting inadequate or

deteriorating performance. The respective deans and/or designees will not attempt to diagnose the cause of the

student's impairment. Based on a student’s performance, behavior, or condition, the respective deans or designees

may consult with the Student Support Services Specialist, Student Wellness Program (SWP), Student Health

Services, and/or contracted psychiatry services, as needed.

*If a student observes impaired behavior in another student colleague, a report should be made to the Associate

Dean for Student Affairs or Assistant Dean for Student Affairs or designee, who will take appropriate action.

Acutely Impaired Student

● If the Associate Dean of Student Affairs or designee and/or the Associate Dean of Medical Education and/or

designee determines a student to be unfit or unsafe to continue performing their academic or clinical

responsibilities, they should immediately relieve the student of their academic or clinical responsibilities.

● The respective deans/designees will inform the student, based on their condition/behavior/performance.

● The student based on their condition/behavior/performance, will be medically evaluated to determine their

“fitness” to perform academic and/or clinical responsibilities.

● A student experiencing acute issue of impairment will be directed to Concentra, Occupational Health Services,

between the hours of 7:30 am and 5:00 pm, Monday through Friday. Due to COVID-19 Concentra is

operating under the adjusted office hours of 8:00 AM to 3:00 PM temporarily. The Emergency Department

(ED) will be used outside of Concentra hours of operation.

● The Associate Dean for Student Affairs and/or a designee will alert Concentra or the ED that a student will be

presenting for an evaluation. The Associate Dean or designee will arrange for an escort for the impaired

student.

● In the event a student refuses to be escorted to Concentra or the ED and/or refuses to be evaluated according

to policy, no attempt should be made to force the student to do so. The Associate Dean of Student Affairs or a

designee will document the student's refusal.

● In the event a student refuses the recommendations of the Associate Dean of Student Affairs and/or designee

and Associate Dean of Medical Education and/or designee, to be evaluated at Concentra or the ED, the student

will not be permitted to return to the CMSRU academic or clinical environment until documentation regarding

impairment is provided by a treating physician or provider.

● If a student demonstrates a threat to themselves or others, the CMSRU Security Office, where applicable, will

be called to provide assistance.

● If at all possible, no student will be allowed to leave the premises unsupervised. Family and friends should be

contacted to provide transportation arrangements.

● The student should not be permitted to operate a vehicle. If the student insists or intends on driving a vehicle,

the student will be advised of police notification.

● A student consent for drug/alcohol analysis must be completed by the student prior to testing. A chain-of-

custody procedures will be followed, and the test will be performed at a certified lab.

● If the drug or alcohol test is positive or the student self discloses substance usage, Concentra will refer the

student to the Student Wellness Program (SWP). The SWP will conduct an evaluation and make a referral for

appropriate treatment. The SWP will maintain contact with the treatment provider to assure compliance with

treatment recommendations. The SWP will receive all documentation for students who are referred to them

for impairment.

Chronically Impaired Student

If based on a student’s academic performance or professional conduct, the Associate Dean of Student Affairs and/or

a designee and the Senior Associate Dean of Medical Education and/or designee determines a student may be

chronically impaired, the following steps should be taken:

● Signs of impairment reflecting a decline in a student’s academic/clinical performance or failure to meet

academic standards will be documented.

● If academic or clinical performance problems persist and the Associate Dean of Student Affairs and/or

designee and Senior Associate Dean of Medical Education and/or a designee believes professional

intervention is necessary, the following steps may be taken at any time:

o Refer the student to the student support services specialist for assessment. The student support services

specialist will refer the student, if determined as necessary, to the SWP for free and confidential counseling,

and document the referral.

o Invoke disciplinary procedures.

● If the student’s performance impacts patient/public safety, the Associate Dean for Student Affairs and/or

designee and Associate Dean of Medical Education and/or designee, in consultation with the Student Support

Services Specialist, and/or other aforementioned providers of care, may recommend immediate evaluation by

Concentra.

Returning the Student to Academic Responsibilities

● Any acutely impaired student (or chronically impaired student, as required) must have a Concentra or ED

physician's approval in order to return to CMSRU.

● The student cannot resume academic or clinical responsibilities until such time as the student is cleared by

Concentra and alcohol and/or drug tests prove negative.

● The Associate Dean of Student Affairs and Senior Associate Dean of Medical Education and/or designee,

should meet with the student to discuss their return to academic responsibilities. The Associate Dean of

Student Affairs or designee and Senior Associate Dean for Medical Education or designee will remind the

student that the academic standards/professional conduct remain unchanged.

● CMSRU will continue to monitor the student's academic and clinical performance in accordance with

CMSRU standards.

● In addition, CMSRU will monitor the student’s compliance with treatment recommendations with the SWP

and will determine a treatment plan.

● Follow-up testing will be determined as required on a case-by-case basis.

Drug Testing

● CMSRU reserves the right to require screening students for inappropriate drug and alcohol use as defined in

this policy if reasonable suspicion is established.

● Reasonable cause is defined by inappropriate behavior, appearance, or academic performance as determined

by those teaching or mentoring students, or any representative of the school.

● A standard reasonable suspicion record will be established for uniform and objective assessment necessitating

the need for drug and alcohol testing.

● CMSRU reserves the right to require random and follow-up drug screenings for students who have

participated in a Drug and Alcohol Treatment program while matriculating at CMSRU.

● All drug testing will be reviewed by Concentra prior to a student’s participation in direct patient contact.

Concentra reserves the right to review and determine whether alternative medical explanations could account

for positive findings.

● CMSRU adheres to the provisions of the Alcohol and Other Drugs Policy. A student’s participation in

prohibited conduct constitutes grounds for disciplinary proceedings and such conduct may be brought to the

attention of the appropriate criminal authorities.

● Students will have access to providers who are not faculty members of the medical school, thus assuring the

provision of services with privacy and confidentiality. In case of an emergency, students will have 24-hour a-

day access to crisis counseling.

● Each student agrees, as a condition of CMSRU enrollment, to notify the Associate Dean of Student Affairs

within five (5) days of any conviction of DUI or under a criminal drug statute for a violation that occurs

during their tenure at the CMSRU.

Student Health Provider Policy

POLICY:

Student Health Provider Policy

PURPOSE:

This policy mandates a mechanism whereby anyone who provides medical or psychological care to a student of

CMSRU will not be in a position to assess or grade that student, nor will they be involved in decisions about the

promotion of that student.

SCOPE:

Candidates for the Doctor of Medicine degree

DEFINITIONS:

Student Health Provider: Anyone in the healthcare field who interfaces with a CMSRU student in the role of care

giver, including those who provide psychological/psychiatric counseling or services.

PROCEDURE:

These rules must be followed at all times by all who provide health care to our students.

● A physician treating a CMSRU student as a patient in any health care setting will have no role in the assessment

of that student or make decisions about the promotion of that student.

● All mental health service providers will not have CMSRU faculty appointments and thereby will have no role in

student assessment.

● An advisory college director is not permitted to be a health care provider to an assigned student advisee.

● Should a faculty member serve on the Academic Standing Committee or the Hearing Body for Student Rights,

and a student they have provided care for at any time during the student’s matriculation be reviewed by the

respective group, the faculty member will recuse themselves from the meeting.

● Those who provide care for students in the Student Health Center may lecture in a large group setting at

CMSRU, but will not have a role in the assessment of any student. They cannot be appointed as a small group

facilitator, an advisory college director, a course director, or a clerkship director.

● Inpatient psychiatric care for CMSRU students will be delivered at a facility removed from the CMSRU campus

and the providers will not be faculty of CMSRU.

● Reports of care regarding CMSRU students via the Student Wellness Program, Student Health Center, or other

contracted services will be provided to the Office of Student Affairs in aggregate by numbers and events and not

include student names or other protected health information.

● Required reporting to the Office of Student Affairs in cases of immunizations and exposure related events will

be provided in accordance with HIPAA regulations.

Student Healthcare Services Policy

POLICY:

Student Healthcare Services Policy

PURPOSE:

To establish the range of healthcare services provided by CMSRU for students and to outline student responsibility

for these services.

SCOPE:

This policy applies to all CMSRU medical students.

PROCEDURE:

CMSRU provides primary medical student healthcare services to all CMSRU students in a confidential, professional

and sensitive manner. Students receive health education for prevention of illness and services for diagnosis and

treatment of routine illness and injuries. All students are required to maintain health and disability insurance.

The Student Health Center (SHC) provides students with access to diagnostic, preventive and therapeutic health

services on campus. The SHC is located on the Camden Health Sciences campus at Three Cooper Plaza, Sheridan

Pavilion, Suite 104, a short walk from the CMSRU Medical Education Building (MEB).

The SHC is open Monday–Friday, 8:30 am-4:30 pm. CMSRU students may contact the SHC reception area at 856-

968-8695 for routine appointments, sick visits, and nurse visits.

The SHC is a full-service ambulatory facility, led by the SHC director, a board-certified Internist, and is staffed by

licensed practical nurses, medical assistants, and a part-time pharmacist. The SHC oversees all health services

provided to CMSRU students, except immunizations and titers, which are offered to the students by Concentra,

Occupational Health Services.

The SHC promotes optimal wellness coverage, enables medical students to make informed decisions about health

issues, and empowers students to be self-motivated and well-informed health care consumers. The SHC focuses on

preventative care and treatment of both acute and chronic illnesses and injuries. Students have access to laboratory

and radiology services and a variety of specialists in the same building. Students with more serious disorders

requiring hospitalization and those who require immediate medical attention outside the hours of the SHC are

directed to the CUHC Emergency Department, located at One Cooper Plaza in Camden, NJ, for evaluation.

The SHC physician director is not involved in the assessment, grading or promotion of students in the academic

setting. The coverage group for this individual is also comprised of physicians who are not involved in the

assessment, grading or promotion of students in the academic setting.

1) Co-pays, deductibles, labs, and diagnostic studies are the responsibility of the student. Students are also

responsible for laboratory, radiology and specialty referrals and treatments.

2) Each student will pay a yearly student fee that will be used to cover the annual PPD, and other immunizations as

required by CMSRU and facilitated by contracted service provider, Concentra, Occupational Health Services. The

Concentra facility is located adjacent to Cooper University Hospital, 300 Broadway, Suite #101, Camden, New

Jersey.

The following services are available for CMSRU students through Concentra:

a. Annual PPD testing, immunizations, FIT testing, and appropriate follow-up care;

b. Record keeping and periodic reports to the Assistant Dean for Student Affairs regarding immunizations will be

provided as required; and

c. Management of exposures, such as blood borne pathogens*: medical students will undergo initial counseling

and will be given initial therapy at the Concentra facility or in the CUHC Emergency Department through a fast-

track process, as required. After an exposure, students are to immediately notify their attending physician and/or

resident. They are to immediately go to Concentra during their hours of operations or the ER after hours.

*Other counseling and management will be provided by Concentra as is outlined by the Infectious Disease,

Environmental Hazards, Needlestick and Bloodborne Pathogens policy.

Proof of Immunity for all CMSRU students will be required and reviewed by Concentra prior to matriculation.

Failure to comply with immunization requirements prior to matriculation may delay entry into the CMSRU

curriculum and cases will be reviewed individually by the Associate Dean for Student Affairs or designee.

Concentra will contact students as necessary to ensure proper immunization. Any student having absent or low titers

will receive the appropriate vaccine. Record keeping and periodic reports to the Office of Student Affairs regarding

immunizations will be provided by Concentra, in accordance with HIPAA regulations.

CMSRU Students may contact Concentra with any questions by telephone 856-338-0350, email at

DCinesi@concentra.com

or by visiting the facility located adjacent to Cooper University Hospital at 300 Broadway,

Suite #101, Camden, New Jersey.

*See policy on Immunization Requirements

*See policy on Infectious Disease, Environmental Hazards, Needlestick and Bloodborne Pathogens policy.

Policies Related to Matriculation

Family Educational Rights and Privacy Act (FERPA)

POLICY:

The Family Educational Rights and Privacy Act (FERPA)

PURPOSE:

FERPA protects the privacy of student education records.

SCOPE:

FERPA applies to all educational agencies and institutions that receive funding under any program administered by

the Department of Education. FERPA (20 U.S.C. § 1232g; 34 CFR Part 99) is a federal law that protects the privacy

of student education records.

In compliance with FERPA, Cooper Medical School of Rowan University (CMSRU) does not disclose personally

identifiable information contained in student education records, except as authorized by law. This policy applies to

the educational records of all students who currently attend or have attended CMSRU.

DEFINITIONS:

Educational Records: any records (with limited exceptions), maintained by the institution that are directly related to

a student or students. The records can contain a student’s name(s) or information from which an individual student

can be personally (individually) identified. Education Records do not include: sole procession notes; law

enforcement unit records; records maintained exclusively for individuals in their capacity as employees (individuals

who are employed as a result of their status as students), medical & treatment records and alumni records.

School Officials:

persons employed by the institution in an administrative, supervisory, academic research or

support position including law enforcement, health staff personnel, a trustee, outside contractors and persons

servicing as a student representative on an official committee (such as disciplinary or grievances committee) or

assisting another school official in performing his or her tasks. School officials may obtain information from a

student education record without prior written consent for legitimate educational interest. Legitimate educational

interests must demonstrate: need to know by those officials of the institution who act in the student’s educational

interest (faculty, administrators, clerical and professional employees and other persons who manage student

information). A school official has a legitimate educational interest if the official need to review is to fulfill his or

her professional responsibility.

Directory Information:

CMSRU reserves the right to disclose directory information without prior written consent

unless notified in writing to the contrary by a student by the deadline date established by CMSRU. CMSRU has

designated the following items as Directory Information: student name, CMSRU-issued identification number,

addresses (including electronic), telephone number, date and place of birth, field(s) of study or program(s),

participation in officially recognized activities, photographs, enrollment status, dates of attendance, degrees, awards

and honors received, previous schools attended and graduate medical/education placements.

POLICY:

Cooper Medical School of Rowan University will comply with the Family Educational Rights and Privacy Act

(FERPA) of 1974 and all subsequent amendments providing students with the right to inspect and review their

education record. CMSRU will respond to student requests to review records within five (5) days of the day that

CMSRU receives the request and will provide guidelines for the correction of records, rather than the forty-five (45)

day statement within the FERPA Act of 1974.

STUDENT

RIGHTS AND PROCEDURES:

A. In accordance with the Family Educational Rights and Privacy Act (FERPA)of 1974 and its subsequent

amendments, current and former CMSRU students have the right to review and inspect their education records

within forty-five (45) days of the date that CMSRU receives the request for access. CMSRU will respond to

requests within five (5) business days of the date that CMSRU receives the request for education records

review.

B. CMSRU is required by FERPA regulations to provide students with annual notification of their FERPA rights.

CMSRU may promulgate, electronically or in a hard copy format, an annual notification in such publications

as school bulletins or student handbooks, in separate statements in registration or orientation packets or on a

web site.

C. Access to Education Records

1. Procedure to Inspect Education Records

a. Students may inspect and review their educational records upon request to CMSRU. Students shall

submit to CMSRU a written request to the registrar that identifies as precisely as possible the record or

records she or he wishes to inspect.

b. CMSRU will make the needed arrangements for timely access and notify the student of the time and

place where the records may be inspected. Per Rowan University policy, access must be given within

forty-five (45) days from the receipt of the request. CMSRU will provide a response to a request for

educational records review within five (5) business days following receipt of the request.

c. When a record contains information about more than one student, the student may inspect and review

only the records that relate to the respective student making the request. Review of records may take

place only under the supervision of the CMSRU registrar and/or a CMSRU school official with a

legitimate educational interest.

2. Right of CMSRU to Refuse Access. CMSRU reserves the right to refuse to permit a student to inspect the

following records:

a. The financial statement of the student’s parents;

b. Letters and statements of recommendation for which the student has waived his or her right of access, or

which were placed in a student file before January 1, 1975;

c. Records which are part of a previous application to CMSRU if that application was unsuccessful and the

student subsequently applies and is admitted;

d. Records that are excluded from the FERPA definition of education records.

3. Right to Obtain Copies of Education Records

a. With the exceptions listed below, a student may obtain copies of their education records from the

CMSRU registrar upon submission of a written request and payment of a standard fee to cover

duplication, reasonable labor costs and postage, if applicable.

b. CMSRU reserves the right to deny copies of transcripts or education records in the following

situations:

i. The student has an unpaid financial obligation to CMSRU; or

ii. There is an unresolved disciplinary action against the student.

D. Disclosure of Education Records

CMSRU may disclose information from a student's educational record only with the original, written and signed

consent of the student, except:

1. To those CMSRU officials who have a legitimate educational interest in the records;

2. Upon request, to officials of non-CMSRU schools in which a student is enrolled or seeks or intends to

enroll, or with which CMSRU has an academic or clinical affiliation. Such officials must have a legitimate

educational interest;

3. To the comptroller of the United States, the secretary of the U.S. Department of Education, state and local

educational authorities, the attorney general of the United States, or when the attorney general of the United

States seeks disclosures in connection with the investigation or enforcement of federal legal requirements

applicable to federally supported education programs;

4. In connection with a student's request for or receipt of financial aid, as necessary to determine the eligibility,

amount or condition of the financial aid or scholarship, or to enforce the terms and conditions of the aid or

scholarship; if required by a state law requiring disclosure that was adopted before November 19, 1974;

5. To organizations conducting certain studies for or on behalf of CMSRU;

6. To accrediting organizations to carry out their functions;

7. At the discretion of CMSRU officials, to parents of an eligible student who claim the student as a dependent

for income tax purposes;

8. To comply with a judicial order or a lawfully issued subpoena, provided that CMSRU makes a reasonable

effort to notify the student of the order or subpoena in advance of compliance, when the order or subpoena

does not prohibit such notification;

9. To appropriate parties in a health or safety emergency;

10. To an alleged victim of any crime of violence or sex offense, the results (if the results were reached on or

after October 7, 1998) of any University disciplinary proceeding against the alleged perpetrator with

respect to that offense. Disclosure under this section shall include only final results of disciplinary

proceedings within CMSRU, limited to the student’s name, the violation committed and the sanction

imposed. Disclosure of final results pursuant to this section may be made regardless of whether CMSRU

determined that a violation has occurred. CMSRU may not disclose the name of any other student,

including a victim or witness, without the prior written consent of the other student;

11. To parents of students aged 18-21 who have been determined by CMSRU to have violated any CMSRU

policy governing the use or possession of alcohol or a controlled substance, or who have violated federal,

state or local law governing such use or possession;

12. To a court, with or without a court order or subpoena, education records that are relevant for the

University to defend itself in legal action brought by a parent or student, or education records that are

relevant for CMSRU to proceed with a legal action CMSRU initiated against a parent or student; and

13. To a court when relevant for CMSRU to proceed with legal action which involves CMSRU and the

student as parties.

E. Record of Requests for Disclosure of Education Records

1. The registrar at CMSRU will maintain a record of all requests for and/or disclosures of information from a

student's education records made by individuals not associated with CMSRU.

2. The record of requests for educational records will indicate the name of the party making the request and the

legitimate interest the party had in requesting or obtaining the information. Said list of those given access to

a student's record may be reviewed by the eligible student.

F. Corrections/Challenges to Content of Education Records

1. A student has a right to a hearing to challenge education records which the student believes are inaccurate,

incomplete, misleading, or otherwise in violation of the privacy or other rights of the student, but a student

does not have a right to a hearing on matters of academic judgment.

2. Following are the procedures for the correction of education records:

a. The student clearly identifies the part of the education record they want changed and specifies their

reasons why it is inaccurate or misleading.

b. If a satisfactory solution of an issue cannot be reached informally, CMSRU must hold a hearing

within sixty (60) days after receiving a student's written request for such a hearing. The hearing shall

be before a University official, designated by the associate dean for student affairs or designee.

c. A CMSRU official will prepare a written decision based solely on the evidence presented at the

hearing within twenty-one (21) days of said hearing. The decision will include a summary of the

evidence presented and the reasons for the decision.

d. If CMSRU decides that the challenged information is inaccurate, misleading or in violation of the

student's right of privacy, it will amend the record and notify the student in writing that the record has

been amended.

3. If CMSRU decides that the challenged information is not inaccurate, misleading or in violation of the

student's right of privacy, it will notify the student that they have a right to place in their education record a

statement commenting on the challenged information and/or a statement setting forth reasons for

disagreeing with the decision; the student’s statement will be maintained as part of the student's education

records as long as the contested portion is maintained. If CMSRU discloses the contested portion of the

record, it must also disclose the student’s statement.

G. Questions about FERPA and this policy concerning the release of student information should be directed to

the Office of the Registrar:

Registrar

Cooper Medical School of Rowan University

401 S. Broadway

Camden, NJ 08103

Email: cmsruregistrar@ rowan.edu

Phone: 856-361-2886

Fax: 856-361-2828

H. Students have a right to file a complaint with the U.S. Department of Education concerning alleged failures by

CMSRU to comply with the requirements of FERPA. The name and address of the Office that administers

FERPA are:

Family Policy Compliance Office

US Department of Education

600 Independence Avenue, SW

Washington, DC 20202-4605

I. Crisis situations/Emergencies

If non-directory information is needed to resolve a crisis or emergency situation, CMSRU may release that

information if CMSRU determines the information is "necessary to protect the health or safety of the student

or other individuals." Factors to be considered or questions to be asked in determining the release of such

information in these situations include the following:

1. Severity of the threat to the health or safety of those involved;

2. Need for the information;

3. Time required to deal with the emergency; and

4. Ability of the parties to whom the information is to be given to to deal with the emergency.

Policies Related to Communications; and Information

Technology and Resources

Acceptable Use Policy

CMSRU adheres to the Rowan University Acceptable Use Policy

POLICY:

Acceptable Use Policy

PURPOSE:

To establish rules of responsible electronics use in the classroom. This policy sets forth the acceptable uses

regarding the access and use of Rowan University’s (CMSRU's) electronic information and information systems.

SCOPE:

This policy applies to all members of the Rowan Community (CMSRU) who access and use the University's

electronic information and information systems.

DEFINITIONS:

Refer to the Rowan University Technology Terms and Definitions

for terms and definitions that are used in this

policy.

PROCEDURE:

CMSRU recognizes the ubiquitous nature of electronic devices in universities. Ultimately the course director and

teaching faculty members determine if the use of electronic devices is disruptive to the classroom environment, and

may require the removal of such devices during instruction.

Cellular Phone Policy: The use of cell phones is prohibited during CMSRU classroom instruction, unless directed

otherwise by the instructor. All cellular phones must be placed in silent mode before a student enters the classroom.

Laptop Computer Policy: Generally, the use of laptop computers to take notes during lectures, or perform other

authorized tasks, is permitted in instructional settings. The instructor does retain the right to limit or refuse laptop

use if the practice interferes with instruction. At no time should a laptop be used for entertainment purposes in

classrooms. Entertainment purposes may include instant messaging, playing games, emailing, using social

networking sites, online shopping or any other activity deemed inappropriate by the instructor.

Electronic Academic Integrity Policy: At no time will CMSRU students be allowed access to electronic devices

during didactic exams, except as approved accommodations for students with disabilities. Proctors who observe the

use of electronics during exams shall confiscate the device as evidence of cheating, and report the incident as

outlined in the Student Handbook.

1.The University (CMSRU) expects users will access and use the University's (CMSRU’s) electronic information

and information systems in a manner that:

a. Does not compromise the confidentiality, integrity or availability of those assets; and

b. Reflects the University's (CMSRU’s) standards as defined in the Code of Conduct and Statement of Principles

and its body of policies, and in accordance with all applicable federal, state and local laws governing the use of

computers and the Internet.

2.These obligations apply regardless of where access and use originate: Rowan (CMSRU) office, classroom, public

space, lab, at home or elsewhere outside the University (CMSRU).

3.The rules stated in this policy also govern the use of information assets provided by the State of New Jersey, other

state and federal agencies and other entities that have contracted with Rowan to provide services to their constituents

and/or clients.

4.Schools, units and departments may produce more restrictive policies. Therefore, users should consult with their

department if there are any other restrictions in place that supplement this policy.

5.This policy and Rowan's (CMSRU’s) Code of Conduct/Statement of Principles also govern access and use of the

University's (CMSRU’s) electronic information and information systems originating from non-Rowan (non-

CMSRU) computers, including personal computers and other electronic devices. The access and use of electronic

information provided by research and funding partners to Rowan (CMSRU) are also governed by this policy.

6.The use of information systems acquired or created through the use of University (CMSRU) funds, including grant

funds from contracts between the University (CMSRU) and external funding sources (public and private), are

covered by this policy. This includes University (CMSRU) information systems that are leased or licensed for use

by members of the Rowan (CMSRU) Community. Users are given access to Rowan's electronic information and

information systems specifically to assist them in the performance of their jobs and education. They are not provided

for personal use. They are responsible for all activity conducted using their computer accounts. Access and use of

the University's (CMSRU’s) electronic information and information systems is a revocable privilege.

7.Rowan (CMSRU) recognizes that all members of the Rowan (CMSRU) Community have an expectation of privacy

for information in which they have a substantial personal interest. However, this expectation is limited by Rowan's

(CMSRU’s) need to comply with applicable laws, protect the integrity of its resources and protect the rights of all

users and the property and operations of Rowan University (CMSRU). As such, Rowan (CMSRU) reserves the right

to access, quarantine or hold for further review any files or computing devices on Rowan's (CMSRU’s) network or

its information technology resources if there is just cause to believe that university (CMSRU) policies or laws are

being violated or if such access is necessary to comply with applicable law or conduct university (CMSRU) business

operations.

8.Information created, stored, or accessed using Rowan (CMSRU) information systems may be accessed and reviewed

by Rowan (CMSRU) personnel for legitimate systems purposes, including but not limited to the following:

a. Emergency Problem Resolution

b. To measure, monitor and address the use, performance or health of the University's (CMSRU’s) information

systems, or to respond to information security issues. Internet usage may also be monitored when using the

University's (CMSRU’s) network, including when using Rowan's (CMSRU’s) remote access services.

c. To create data backups of electronic information stored on Rowan's (CMSRU’s) information systems.

d. To respond to User Requests approved by the Office of General Counsel.

9.Information may be accessed, reviewed, and provided to an external party at the University's (CMSRU’s) discretion

without prior notification with adequate cause and subject to review of the Office of General Counsel to comply

with applicable law and to conduct normal university (CMSRU) operations. Examples include, but are not limited to

the following:

a. Compliance with the New Jersey Open Public Records Act ("OPRA") which requires disclosure of electronic

records and other data on the Rowan system subject to exemptions under OPRA. Requests will be reviewed by the

Records Custodian/OPRA officer in conjunction with the Office of General Counsel.

b. Compliance with a valid subpoena, court order or discovery request. Requests will be reviewed by the Office of

General Counsel.

c. Audits, investigations or inquiries undertaken by governmental entities or appropriate internal investigators or

units. Requests will be reviewed by the Office of General Counsel.

d. To conduct necessary business operations.

10.All electronic information created, stored or transmitted by use of Rowan's (CMSRU’s) information systems is the

property of the University (CMSRU), unless otherwise explicitly noted.

11.Technicians and System Administrators have greater ability to access information stored on and transmitted through

Rowan's information systems. As such, Technicians, Systems Administrators and others with privileged access shall

not access such information unless such access is necessary for the purposes outlined above, for systems purposes or

unless such access is supported by adequate cause and reviewed by the Office of General Counsel.

12.Prohibited Actions

a. The list of prohibited actions is not intended to be comprehensive. The evolution of technology precludes the

University (CMSRU) from anticipating all potential means of capturing and transmitting information. Therefore,

users must take care when handling sensitive information. Refer to Rowan's Information Classification and Data

Governance policies for types of information that are considered sensitive and/or contact Rowan's (CMSRU)

Information Security Office for guidance.

b. Users, at minimum, will ensure that they do not:

i.Distribute information classified as Confidential or Private, or otherwise considered or treated as privileged or

sensitive information, unless they are an authoritative University (CMSRU) source for, and an authorized

University (CMSRU) distributor of that information, and the recipient is authorized to receive that information.

ii.Share their passwords with other individuals or institutions (regardless if they are affiliated with Rowan or not)

or otherwise leave them unprotected.

iii.Attempt to uninstall, bypass or disable security settings or software protecting the University's (CMSRU’s)

electronic information, information systems or computer hardware.

iv.Engage in unauthorized attempts to gain access or use the University's (CMSRU’s) electronic information,

information systems or another user's account. Users with privileged access, such as Technicians and Systems

Administrators, shall not engage in unauthorized access, use or review of information or data, without

appropriate approvals.

v.Use third-party email services to conduct sensitive University (CMSRU) business or to send or receive Rowan

information classified as Confidential, Private or Internal or otherwise considered privileged or sensitive

information.

vi.Use email auto-forwarding to send University (CMSRU) information (regardless of classification) to non-

Rowan email accounts (see Restricted Services

vii.Distribute or collect copyrighted material without the expressed and written consent of the copyright owner or

without lawful right to do so, such as in the case of fair use.

viii.User understands the HIPAA Privacy Security rules, especially with regard to Sensitive Electronic Information

(SEI), Private Health Information (PHI) and Personally Identifiable Information (PII), and will abide by these

rules including understanding that they will be held accountable for the use of personal devices for conducting

University (CMSRU) business. (Refer to HIPAA policies located at www.rowan.edu/compliance

13.Restricted Services

a. This list of restricted services is not intended to be comprehensive. The evolution of technology precludes the

University (CMSRU) from anticipating all potential means of storing, capturing and transmitting information.

Therefore, when using third-party technology services not explicitly restricted in this policy, users must exercise

care to not compromise sensitive Rowan information, particularly when confirmation of receipt or the identity of

the recipient is required for business or legal purposes. Refer to Rowan's Information Classification and

Data

Governance policies for types of information that are considered sensitive and/or contact Rowan's Information

Security Office for guidance.

b. Restricted services include the following:

i. Social Media

1. Social media tools or web content platforms cannot be used to communicate or store University

(CMSRU) information classified as Confidential or Private or otherwise considered privileged or

sensitive by Rowan. Social media tools include, but are not limited to: Facebook, Twitter, LinkedIn,

Instagram, Medium, Reddit, YouTube and Flickr.

2. For additional requirements on the use of social media, see the Social Media Policy

ii. Professional Social Media

1. Professional social media cannot be used to communicate or store University (CMSRU) information

classified as Confidential or Private or otherwise considered privileged or sensitive by Rowan (CMSRU).

2. The use of professional social media tools, such as Doximity and Sermo, cannot be used:

a. To discuss patient cases in a manner that compromises patient identity or privacy, or otherwise

represents a violation of HIPAA's Privacy or Security rules, state or local privacy laws or University

(CMSRU) policies.

b. To communicate or post information that could potentially reveal information classified as

Confidential or Private or otherwise considered privileged or sensitive by Rowan, or which

compromises the privacy of a member of the University (CMSRU) community or its clients.

c. For additional requirements on the use of social media, see the Social Media Policy

iii. Cloud Services, Collaboration and Storage

1. Third-party cloud storage services cannot be used to store University (CMSRU) information classified as

Confidential.

2. Google Drive is approved for Private, Internal and Public data. For additional information on the use of

Google Drive, see Google Apps: Appropriate Data Use

3. The use of non-approved third-party cloud storage services cannot be used to store University (CMSRU)

information classified as Confidential or Private or otherwise considered privileged or sensitive by

Rowan. Cloud storage tools include, but are not limited

to: iCloud, Carbonite, OneDrive, Box, Dropbox, Evernote, OpenDrive and SugarSync.

iv. Third Party Email Services

1. Third party email services cannot be used to communicate or store University (CMSRU) information

classified as Confidential or Private or otherwise considered privileged or sensitive.

v. Email Auto-Forwarding

1. With the exception of current undergraduate and other non-medical students, members of the Rowan

(CMSRU) Community are not permitted to automatically forward or redirect messages from a Rowan

email address to a non-Rowan email address.

vi. Texting

1. Texting cannot be used to communicate or store University (CMSRU) information classified as

Confidential.

vii. Video Conferencing

1. Video conferencing services are limited to Rowan business-use only and must be conducted using Rowan

equipment. They are to be used strictly for business collaboration between members of the Rowan

Community or outside entities, or for educational purposes. Users must ensure that video communications

are done in a setting or configured to restrict the possibility of non-authorized individuals from viewing or

listening to sensitive information.

viii. Chat

1. The use of non-approved chat services cannot be used to communicate or store University (CMSRU)

information classified as Confidential or Private or otherwise considered privileged or sensitive by

Rowan. Chat tools include, but are not limited to: Slack and HipChat.

2. Jabber is approved for Private, Internal and Public data.

ix. BitTorrent Software

1. BitTorrent software (or other file sharing software) used to download and share movies, music and other

copyrighted media is strictly forbidden unless it is used for Rowan (CMSRU) business or academic

purposes. The use of this software must be approved by the Dean or Department Head/Chair and the

Information Security Office.

POLICY

COMPLIANCE:

1.Violations of this policy may subject the violator to disciplinary actions up to or including termination of

employment or dismissal from school, subject to applicable collective bargaining agreements and may

subject the violator to penalties stipulated in applicable state and federal statutes. Students who fail to adhere

to this Policy or the Procedures and Standards will be referred to the Office of Student Affairs and may be

expelled. Affiliates, contractors and vendors who fail to adhere to this Policy and the Procedures and

Standards may face termination of their business relationships with the University (CMSRU). Sanctions

shall be applied consistently to all violators regardless of job titles or level in the organization.

2.University (CMSRU) sanctions, penalties, fines and discipline for employees will be based on the severity

of the incident per below:

a. Low – retraining and to be reviewed with the employee during annual appraisal. Also, any cost shall be

borne by the Department. The Department Chair or VP will determine how these funds will be assigned;

b. Medium – retraining and to be reviewed with the employee during annual appraisal. Discipline will be

considered up to and including dismissal from the University (CMSRU). Also, all costs will be borne by

the Department. The Department Chair or VP will determine how these funds will be assigned; and

c. High – retraining and to be reviewed with employee during annual appraisal. Discipline will

be unpaid suspension for a minimum of three (3) days with a consideration of up to and including

dismissal from the University (CMSRU). Civil and criminal penalties may apply. Also, all costs will be

borne by the Department. The Department Chair or VP will determine how these funds will be assigned.

The Deans of each College, Vice Presidents and University President, with the assistance of the

Department of Human Resources, will enforce the sanctions appropriately and consistently to all

violators regardless of job titles or level within the University (CMSRU) and in accordance with

bargaining agreements for represented employees.

The general use of computers and campus technology is governed by the Rowan University Acceptable Use Policy

ADDITIONAL INFORMATION

1. Rowan University Statement of Principles

2. Breach Notification Policy

3. HIPAA Policy

4. IT Acquisition Process (ITAP)

5. Information Classification Policy

6. Data Governance Policy

POLICY:

PURPOSE:

CMSRU respects intellectual property and has made it a priority to ensure that all faculty, students and staff respect

the copyrights of others. CMSRU faculty, students and staff are required to comply with copyright law and to adhere

to the CMSRU copyright policy and guidelines. Copyright infringement through inappropriate copying or

distribution of copyrighted content is a personal and medical school liability and will result in disciplinary action.

SCOPE:

All CMSRU medical students, faculty and staff.

DEFINITIONS:

Essential definitions and key terms are outlined within the policy.

PROCEDURE:

Important Information about Copyright

What is Copyright?

The purpose of copyright law is to provide authors and other creators with an incentive to create and share creative

works by granting them exclusive rights to control how their works may be used. Among the exclusive rights

granted to those authors are the rights to reproduce, distribute, publicly perform and publicly display their work.

These rights provide copyright holders control over the use of their creations, and an ability to benefit, monetarily

and otherwise, from the exploitation of their work. Copyright also protects the right to “make a derivative work,”

such as a movie from a book; the right to include a piece in a collective work, such as publishing an article in a book

or journal; and the rights of attribution and integrity for "authors” of certain works of visual art. If you are not the

work. Acknowledging the source of a work is not a substitute for obtaining permission. However, permission

generally is not necessary for actions that do not implicate the exclusive rights of the copyright holder, such as

reviewing, reading or borrowing a book or photograph.

What is Protected by Copyright?

The rights granted under the U.S. Copyright Act (embodied in Title 17 of the U.S. Code) are intended to benefit

“authors” of “original works of authorship,” including literary, dramatic, musical, architectural, cartographic,

choreographic, pantomimic, pictorial, graphic, sculptural and audiovisual creations. This means that virtually any

creative work that you may come across in readable or viewable format, including books, magazines, journals,

newsletters, maps, charts, photographs, graphic materials; unpublished materials, such as analysts’ reports and

consultants’ advice; and non-print materials, including websites, computer programs and other software databases,

sound recordings, motion pictures, video files, sculptures and other artistic works are almost certainly protected by

What is NOT Protected by Copyright?

Not everything is protected by copyright. This includes works published by the federal government and works for

which copyright protection has expired. This also includes: works that are not fixed; titles, names, slogans; ideas,

facts and data; listings of ingredients or contents; natural or self-evident facts; and public domain works (more on

that below). Some of these things may, however, be protected under other areas of law, such as patent or trademark

law, or by contract. It is important to be sure that no other form of protection restricts the use of such materials

before using them.

How Long Does Copyright Protection Last?

In the U.S., a work created on or after January 1, 1978, is ordinarily protected for a term equal to the author’s life

span plus 70 years after the author’s death. Works created by companies or other types of organizations have a

factors.

Fair Use

Fair use is a defense under U.S. law that may be raised by the defendant in a copyright infringement case. Fair use

recognizes that certain types of use of other people’s copyright protected works do not require the copyright holder’s

authorization. The fair use doctrine is codified in Section 107 of the U.S. Copyright Act. Although there are no

absolute rules around fair use, generally the reproduction (photocopy or digital) or use of someone’s copyright-

protected work is more likely to be found to be fair use if it is for one of the following purposes: criticism, comment,

news reporting, teaching, scholarship or academic research. To determine whether a particular use qualifies as fair

use, the statute requires a fact specific analysis of the use based upon four factors:

1. The purpose and character of the use (e.g., whether for commercial or nonprofit educational use)

2. The nature of the copyright-protected work (is it primarily factual or highly creative?)

3. The amount and substantiality of the portion used

4. The effect of the use upon the potential market for or value of the copyright-protected work

All four factors must be considered and balanced against the other factors as part of each fair use analysis.

Fair use requires an appropriate risk assessment as to whether re-use under certain circumstances may be considered

fair use. Permission procedures as set out in this policy should be followed and the advice of the CMSRU Library

should be sought in instances where fair use determination may be necessary. Please be aware that all educational

use is not automatically fair use.

Any non-digital content that is protected by copyright is also protected in a digital form. For example, print books

are protected by copyright law, as are electronic books. A print letter is protected by copyright law, as is an email

letter. In both cases, the copyright is generally owned by the author, regardless of who has received the letter.

Whenever you wish to use material found on a website, it is always important to review and understand the terms of

use for that site because those terms will tell you what use, if any, you can make of the materials you find there.

Fact Finding Questions

Once you have identified the materials you want to use, ask yourself the following questions: is the work the type of

work protected by copyright? If so, are you using the work in a manner that implicates the exclusive rights of the

locate the copyright holder. Is the name of the copyright holder on the materials? Does the Copyright Clearance

Center represent that work? Locating the copyright holder may take some investigative and creative work. Consult

with the CMSRU Library to see if they can offer any guidance. The U.S. Copyright Office at the Library of

Congress (www.loc.gov

) may be of assistance in locating a copyright owner.

Requesting Permission

Permission to use copyright-protected materials should be obtained prior to using those materials. It is best to obtain

permission in writing, which may be by email. The time needed to obtain permission may vary. When possible, it is

recommended to start the permission procedure well in advance of the time that you wish to use the materials. If you

need a fast turnaround on a permission request, let the copyright owner know this and they may get back to you

faster. The information you will need:

● ISBN or ISSN, if applicable

● Date of publication, if applicable

● Purpose for which you wish to reproduce the item (research, commercial, educational)

● How the material is to be reproduced (e.g., photocopied, digitized)

● Where the reproduced material will appear (including internal vs. external use) and for how long

Guidelines for the Appropriate Use of Copyrighted Materials

CMSRU Faculty, Student and Staff Obligations Under Copyright Law

No student, faculty member or staff may reproduce any copyrighted work in print, video or digital form in violation

of the law. Works are considered protected even if they are not registered with the U.S. Copyright Office and are

assumed to be copyrighted until proven otherwise. When a work is copyrighted, you must seek out and receive

through a license or the express written permission of the copyright holder, the right to reuse the copyrighted work

in order to avoid an infringement of copyright, unless it is determined in consultation with the CMSRU Library and,

if appropriate, legal counsel that the use would constitute a fair use.

CMSRU has negotiated licenses with publishers and other copyright holders that allow employees to use and share

their materials. Faculty can point students to these materials or link to them. These licenses have restrictions and

specific terms of use. As a result, it is critical that an employee investigate what the permitted uses are before

copying or sharing any copyrighted materials. Similarly, students must investigate the permitted uses for a

copyrighted material before distributing or sharing for any purpose. Please consult and implement the procedures

outlined in this policy. Any employee or student who violates CMSRU copyright policy may be subject to

disciplinary action. All questions should be directed to Susan Cavanaugh, MS, Director of the CMSRU Medical

Library at 856-342-2523.

Social Media Policy

CMSRU Adheres to the Rowan University Social Media Policy

POLICY:

Social Media Policy

PURPOSE:

This policy sets forth the acceptable uses regarding the access and use of social media for University-affiliated

communications. It also includes professionalism requirements for the University’s medical students who, as

medical professionals in training, who must uphold the highest standards of the medical profession and protect the

privacy and confidentiality of patients.

SCOPE:

This policy applies to all members of the University (CMSRU) community who use social media for University-

affiliated communication and those who use the University (CMSRU) name in association with social media

accounts.

DEFINITIONS:

See Attachment 1 - Definitions

REFERENCES:

See Attachment 2 - References

PROCEDURE:

1. The University (CMSRU) expects members of the University (CMSRU) community will access and use social

media in a manner that follows all guidelines below:

A. Does not compromise the confidentiality, integrity or accessibility of those assets;

B. Complies with all applicable University (CMSRU) policies, procedures, and guidelines and is in accordance

with all applicable federal, state and local laws and regulations governing the use of computers and the

Internet;

C. Protects the University’s (CMSRU’s) reputation and promotes its educational mission;

D. Conforms to all policies and procedures set forth by the University (CMSRU). Nothing in this policy

supersedes standards set forth by Information Resources & Technology, the Department of Public Safety, the

Office of Emergency Management and Student Life/Student Affairs;

E. Recognizes the rights of the members of the University (CMRU) community guaranteed by the Constitution

of the United States and the State of New Jersey, including but not limited to freedom of speech, inquiry, and

expression; and

F. Complies with all Terms set forth by each respective social media network.

2. These obligations apply regardless of where access and use originate.

3. All University (CMSRU)-affiliated social media, including but not limited to the account itself, content and

audiences, are the property of the University (CMSRU). Account creators and administrators have no ownership

rights whatsoever.

4. The content contained herein is not intended to be comprehensive, as the evolution of technology precludes the

University (CMSRU) from anticipating all potential means of storing, capturing and transmitting information.

This policy will be monitored and revised as deemed necessary.

5. Requirements

A. University (CMSRU) affiliated social media account administration.

1. Any member of the University (CMSRU) community engaging in University (CMSRU)-affiliated social

media must do so using an administrative or resource University email address to which more than one

member of the University community has access.

a. A unique email must be created expressly for this purpose by submitting a request at support.rowan.edu.

b. No member of the University (CMSRU) community should be required, asked or permitted to use a

private, personal account for the purpose of creating social media account(s) on behalf of the University

(CMSRU).

c. If, for any reason, a social media account is presently linked to an individual person’s email account,

that person relinquishes all rights to the account.

2. Social media contacts shall acknowledge all of the following:

a. They have obtained permission from their supervisor/management to use social media in an official

capacity for their unit;

b. They must maintain access to and security of all social media usernames and passwords;

c. They must monitor and maintain the account(s) on a weekly basis. Inactive accounts may be subject to

deactivation or deletion;

d. Resources will be made available for their reference at www.rowan.edu/socialmedia

;

e. Other social media users may have different interests, attitudes, and opinions than those of the

University (CMSRU). Social media contacts reserve the right to remove content, block users, or refrain

from interacting with anyone for content deemed to be unlawful. Social media contacts do not reserve

the right to remove content deemed to be a difference of opinion; and

f. Social medial contacts’ administrative access to social media accounts will be terminated upon exit from

the University (CMSRU) or assignment to another job.

3. All University (CMSRU)-affiliated social media should be explicit regarding the relationship of the

platform to the University (CMSRU).

4. All social media graphics and naming conventions must abide by the University’s (CMSRU’s) Graphic

Standards policy.

a. University (CMSRU) trademarks and logos, including but not limited to the University (CMSRU) seal,

torch and athletics logo, may not be used without approval.

b. ‘Rowan University (CMSRU)’ or ‘Rowan’ should be used within the social media username and

prepend any qualifiers. ‘RU’ and other acronyms should not be used within the username unless the

expanded versions do not adhere to unique platform restrictions.

c. Units that have multiple social media accounts should use the same photo and name across all platforms.

B. Personal Use of Social Media

1. Members of the University (CMSRU) community may not use the University (CMSRU) name, email

addresses or University (CMSRU) logos/trademarks on social media to post information in a manner that

may be interpreted as representing an official position of the University (CMSRU), or which may

misrepresent the University's viewpoint. All accounts and posts in which a user identifies him/herself as a

member of the University (CMSRU) community should clearly communicate: "The views and opinions

expressed are strictly those of the author. The contents have not been reviewed or approved by Rowan

University (CMSRU)" or “Views/opinions are my own.”

2. Members of the University (CMSRU) community may not access social media in a manner that interferes

with or delays completion of their professional responsibilities.

3. The University (CMSRU) name and University (CMSRU) email addresses may not be used on social

media sites and online forums for personal communication.

4. Members of the University (CMSRU) community may be held legally liable for what they post on their

personal social media site(s) and should therefore refrain from any communications considered punishable

under state or federal law.

5. Individual students and student organizations are expected to abide by the Student Code of Conduct.

Students may be accountable to the University (CMSRU) for acts on personal social media site(s) that

violate the Student Code of Conduct.

6. Any attempt by a member of the University (CMSRU) community to obscure his/her identity as a means to

circumvent the prohibitions listed herein by representing himself/herself as another person, real or

fictitious, is strictly prohibited.

C. All University (CMSRU)-affiliated social media may not be used for any commercial business, financial

transactions or interactions that would otherwise be considered irrelevant.

D. Rights and permissions must be secured before posting, sharing or distributing copyrighted materials,

including but not limited to music, art, photographs, texts, portions of video or information considered

proprietary by a University (CMSRU) partner, vendor, affiliate or contractor. This does not include archives

from University Relations, photos taken in a public venue and photos in which individuals are not clearly

identifiable.

E. Social media tools may not be used to communicate or store information classified as confidential, private or

otherwise considered privileged or sensitive by the University (CMSRU); which compromises the privacy of a

member of the University (CMSRU) community or its clients; or is considered confidential under applicable

federal and state laws including HIPAA and FERPA.

F. Social media does not replace or otherwise eliminate the need to use the University’s (CMSRU’s) existing

recruitment systems and processes for posting positions, collecting applications, conducting background

checks, making offers of employment and other related activities.

6.Crisis Management

A. The catch-phrase, “If you see something, say something” should be a standard rule in social media monitoring.

In the event that information surfaces on social media sites that is deemed as harassing or threatening in

nature, or helpful in a crisis or investigation, it must be immediately reported to 911 and/or Public Safety at

856-256-4911 with the following if available:

1. Screenshot(s) of and link to the communication.

2. Username(s) of the person(s) involved in the communication.

3. As much information about the incident as possible.

B. In the event of a crisis on campus, emergency messaging will be issued through the Department of Public

Safety, the Office of Emergency Management and/or the Office of the President, and distributed according to

the University’s Emergency Response Team Communication Protocol. These messages will also be

distributed on official University (CMSRU) social media accounts as needed.

1. Rowan University:

a. Facebook: https://www.facebook.com/RowanUniversity/

b. Instagram: https://www.instagram.com/rowanuniversity/

c. Twitter: https://twitter.com/rowanuniversity

2. CMSRU:

a. Facebook: https://www.facebook.com/coopermedschool

b. Instagram: https://www.instagram.com/cmsru/

c. Twitter: https://twitter.com/coopermedschool

3. RowanSOM:

a. Facebook: https://www.facebook.com/RowanSOM/

b. Instagram: https://www.instagram.com/rowan_som/

c. Twitter: https://twitter.com/rowansom

4. Share verbatim only the messaging provided by the aforementioned accounts to ensure only the correct

information is disseminated. Do not share any information that does not come from any of the aforementioned

University (CMSRU) sources.

5. Postpone/delete any previously scheduled social media content and refrain from posting unrelated information

on social media until after the crisis.

6. If any social media messages could be used to help in a crisis, alert 911 or the Department of Public Safety

immediately.

7. Additional Requirements for Medical School Communities

A. Misrepresentation in any social media by any member of the CMSRU or RowanSOM communities,

regarding the status of his/her credentials as a medical student or medical professional, is strictly

prohibited.

B. Specific Restrictions under HIPAA and FERPA for Medical Students

1. Posting PHI on social media by any individual within the CMSRU or RowanSOM communities is

strictly prohibited under the HIPAA regulations, which apply to any information related to patients.

a. Never post a photograph or image of a patient to any electronic media, other than the patient’s

electronic medical record unless directly requested by a CUHC attending physician. Use of cameras or

cell phone cameras in the patient care setting shall be for the sole purpose of assisting in the care and

education of the patient for educational purposes. Any photographs taken in the patient care setting

must be posted to the patient’s electronic medical record.

b. Removal of an individual’s name does not constitute proper de-identification of PHI. Inclusion of data

such as age, gender, race, diagnosis, date of evaluation, type of treatment or the use of a highly

specific medical photograph (such as a before/after photograph of a patient having surgery or a

photograph of a patient from medical outreach trips) may still allow the reader to recognize the

identity of a specific individual.

c. Never post derogatory or defamatory remarks about any patient (either current or past) to any social

media, including any social media deemed to be “private.”

2. Posting of any student records on social media by any individual within the CMSRU or RowanSOM

community is strictly prohibited under the FERPA regulations.

a. FERPA-protected academic information of another medical student or trainee might include, but is

not limited to, course or clerkship grades, narrative evaluations, examination scores or adverse

academic actions.

3. All individuals within the CMSRU and RowanSOM communities must take steps to ensure compliance

with all federal and state laws and regulations, including HIPAA and FERPA, by ensuring that their

social media has the appropriate privacy settings to avoid the inadvertent dissemination of confidential

information, with the understanding that even if they limit the number of people who can see their

personal information, others who have access to this information may share it more broadly.

4. Medical students may not “friend/follow,” engage or connect on social media with any patients they

come in contact with in a clinical context, unless a friendship pre-dates the clinical encounter. If a

student has a friendship that predates the clinical encounter or thinks they may know the patient socially,

they must recuse themselves from patient care. At all times, the disclosure of protected health

information about patients on social media is strictly prohibited, including posts in the secure section of

social media accounts that are accessible by approved friends, only.

5. The public disclosure or negative information about CMSRU, RowanSOM or affiliated clinical rotation

sites on social media increases the risk of liability to the University (CMSRU) and is clearly

unprofessional. There are legitimate and confidential mechanisms for improving quality at a medical

facility.

6. The specific sanctions to be imposed for non-compliance with HIPAA or FERPA laws and regulations,

illegal activities, or violation of University/CMSRU/RowanSOM policies and procedures, will depend

upon the severity and legal implications of the activity under review. Action will be initiated as

appropriate in accordance with the classification of an individual (i.e., faculty, staff, medical student,

resident, house staff, etc.) and, if necessary, the requirements of the individual’s licensing boards, as set

forth in the applicable disciplinary procedures within the medical schools’ student handbooks.

Discipline may range from simple counseling/guidance up to the risk of civil and/or criminal liability

under applicable federal and state laws and regulations.

8. Non-Compliance and Sanctions

A. Violations of this policy may result in the revocation of social media contact and account privileges.

B. A disciplinary or other review may be initiated if any member of the University (CMSRU)

community’s social media activity violates law or University (CMSRU) policy or otherwise subjects the

University (CMSRU) to potential liability for such acts.

C. The purpose of this section is not intended to provide for the investigation of, or disciplinary action

against, members of the University (CMSRU) community for the legal exercise of

Attachment 1 - Definitions

1. Accessibility refers to hardware and software technologies that help visually or physically impaired people to use

the computer.

2. CMSRU means Cooper Medical School of Rowan University (CMSRU).

3. Confidentiality is the expectation that only authorized individuals, processes and systems will have access to the

University’s (CMSRU’s) information.

4. Confidential Information refers to the most sensitive information, which requires the strongest safeguards to

reduce the risk of unauthorized access or loss. Unauthorized disclosure or access may: 1) subject University

(CMSRU) to the risk of liability (for example, for violation of HIPAA and FERPA laws); 2) adversely affect its

reputation; and 3) jeopardize its mission. See the Information Classification policy for additional information.

5. Crisis refers broadly to any real or perceived emergency, imminent threat or timely warning which: 1) can

negatively impact or seriously endanger members of the University (CMSRU) community; 2) requires immediate

attention to minimize impact; 3) has significant impact on the operation or reputation of the University

(CMSRU); and 4) results in extensive news coverage and public scrutiny. Examples include but are not limited to

serious threats to life/property, hostage situations, weather, disease or health threat, natural disaster, assault and

civil unrest.

6. HIPAA refers to the Health Insurance Portability and Accountability Act, the federal law passed by Congress in

1996 that requires the protection and confidential handling of Protected Health Information (“PHI”).

7. Faculty Member means any person hired by the University (CMSRU) to conduct classroom or teaching activities

or who is otherwise considered by the University (CMSRU) to be a full- or part-time or adjunct member of its

faculty.

8. FERPA refers to the Family Education Rights and Privacy Act, a federal law that protects students' privacy by

prohibiting disclosure of students’ personally identifiable information (“PII”) within their education records,

without the student’s consent.

9. Integrity is the expectation that the University’s (CMSRU’s) information will be protected from improper,

unauthorized, destructive or accidental changes.

10. Medical Schools means CMSRU and RowanSOM

11. Medical Student includes all persons pursuing medical studies at CMSRU or RowanSOM. Medical students

who are not officially enrolled for a particular term but who have a continuing relationship with CMSRU or

RowanSOM, such as medical students who were previously enrolled, withdraw/take a leave of absence, medical

students participating in CMSRU or RowanSOM sponsored academic programs and medical students who are

serving a period of suspension, are considered “medical students.”

12. Member of the University (CMSRU) Community includes any person who is a student, faculty member,

organization, alumni, volunteer, trustee, University (CMSRU) official or any other person employed by the

University (CMSRU).

13. Organization means any number of persons who have complied with the formal requirements for University

(CMSRU) recognition. This term also applies to persons involved in petitioning for recognition. (Greek Letter

Organizations are also subject to the disciplinary procedures outlined in the Greek Handbook).

14. Personally Identifiable Information (“PII”) means data or information which includes, but is not limited to: 1)

the name of the medical student, the medical student’s parent or other family members; 2) the address of the

medical student or the medical student’s family; 3) a personal identifier such as a social security number or

student number; or 4) a list of personal characteristics or other information which would make the medical

student’s identity easily traceable.

15. Private Information refers to sensitive information that is restricted to authorized personnel and requires

safeguards, but which does not require the same level of safeguards as confidential information protected from

disclosure under federal and state laws such as FERPA and HIPAA. Unauthorized disclosure or access may

present legal and reputational risks to the University (CMSRU). See the University's Information Classification

policy for additional clarification.

16. Professionalism is a formal requirement for the education and training of both undergraduate and graduate

medical students. CMSRU and RowanSOM expect individuals within the CMSRU and RowanSOM

communities to strive to uphold the highest standards and personal behaviors, consistent with a respect for the

medical profession, commencing with the first day of medical school. The Accreditation Council for Graduate

Medical Education (“ACGME”) defines and outlines professionalism as one of the six ACGME Core

Competencies as follows: commitment to carrying out professional responsibilities, adherence to ethical

principles and sensitivity to a diverse patient population. “Professionalism is the enactment of the values and

ideals of individuals who are called, as physicians, to serve individuals and populations whose care is entrusted

to them, prioritizing the interests of those they service above their own.” AAMC Professionalism Task Force.

17. Protected Health Information (“PHI”) means information that: 1) is created or received by a health care

provider; 2) relates to the past, present or future physical or mental health or condition of an individual; the

provision of health care to an individual; or the past, present, or future payment for the provision of health care

to an individual; and (i) that identifies the individual; or (ii) with respect to which there is a reasonable basis to

believe the information can be used to identify the individual. This guideline applies even if the patient’s

information has been de-identified, so that the only person who may be able to identify the individual is the

patient himself/herself.

18. RowanSOM means Rowan University School of Osteopathic Medicine.

19. Social Media refers to any online tools and services that allow Internet users to create and publish content, or

any facility for web- and mobile-based publication and commentary, including but not limited to blogs, wikis,

RSS feeds, content-sharing services, interactive geo-location platforms and networking sites including but not

limited to Facebook, Twitter, YouTube, Instagram, LinkedIn, Snapchat, Pinterest, Google+, Periscope, Flickr

and Wordpress..

20. Social Media Contact refers to any member of the University (CMSRU) community whose responsibilities

include managing and/or maintaining a social media presence on behalf of the University (CMSRU) and/or who

uses social media to engage in University (CMSRU)-affiliated communications.

21. Social Media Officials refer to people at the University (CMSRU) who delegate responsibilities to Social Media

Contacts.

22. Student includes all persons enrolled in courses at Rowan University (CMSRU), both full-time and part-time,

pursuing undergraduate or graduate studies and/or those who live in campus living units. Persons who are not

officially enrolled for a particular term but who have a continuing relationship with the University (CMSRU),

such as students who were previously enrolled, withdraw/take a leave of absence, persons participating in

University (CMSRU) sponsored academic programs and students who are serving a period of suspension, are

considered "students."

23. University means Rowan University and its Medical Schools.

24. University-affiliated Social Media refers to any social media presence intended to represent Rowan University

(CMSRU) in any official or unofficial capacity.

25. University Official includes any person employed by Rowan University (CMSRU) to perform assigned

administrative or professional responsibilities.

Attachment 2 - References

1. Department of Public Safety

Free Speech

General Safety and Security

2. Graphic Standards

3. Human Resources

Statement of Principles

Workplace Violence Policy

4. Information Resources & Technology

Acceptable Use

Data Governance

General User Password

Information Classification

Information Security

Transmission Sensitive Information

University Mass Notification Systems

5. Medical Schools

Cooper Medical School of Rowan University (CMSRU)

Rowan University (CMSRU) School of Osteopathic Medicine

● The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), Privacy and Security Rules,

45 CFR Part 160, 45 CFR Part 162 and 45 CFR Part 164.

● The Family Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. 1232g, 34 CFR Part 99

● AMA Policy: Professionalism in the Use of Social Media

● AMA Guidelines for Physicians in Social Media

● Model Guidelines for the Appropriate Use of Social Media and Social Networking in Medical Practice:

Adopted as policy by the House of Delegates of the Federation of State Medical Boards

6. Office of Emergency Management

Emergency Preparedness

7. Social Media Sites

● Facebook – an online social utility that connects people and organizations with friends and others who

work, study, live and engage around them.

● Flickr – a photo sharing website on which users can view, upload and share photos.

● Google+ – integrated social platform that merges with other Google services including YouTube, Gmail and

Google Search.

● Instagram – a photo- and video-sharing network owned by Facebook that allows users to upload photos

taken with a mobile device, apply special filters and share with their friends.

● LinkedIn – a business-oriented online social utility that allows users to strengthen and extend their existing

network of trusted professional contacts.

● Periscope – a streaming service that lets users broadcast and explore the world through live video.

● Pinterest – a website that allows users to “pin,” or bookmark, content they find interesting from around the

web to categorized “boards” on their profiles.

● Snapchat – a mobile app that allows users to capture videos and pictures and send messages that self-

destruct.

● Twitter – a real-time, micro-blogging and social utility service that allows users to send and read messages

known as “tweets,” which are text-based posts containing no more than 140 characters.

● Wordpress – an online, open source content management system, blogging platform, and website creation

tool.

● YouTube – a video-sharing website that makes it easy to search for and watch online videos.

8. Social Media Terms

● Facebook

● Flickr

● Google+

● Instagram

● LinkedIn

● Periscope

● Pinterest

● Snapchat

● Twitter

● Wordpress

● YouTube

9. Student Life/Student Affairs

Student Code of Conduct

10. Web Content Accessibility Guidelines

Policies Related to Diversity, Equity, and Inclusion

Anti-Discrimination Policy

CMSRU Adheres to the Rowan University Policy for Anti-Discrimination

I. Purpose

Rowan University (CMSRU) is committed to providing every Rowan University (CMSRU) employee, prospective

Rowan (CMSRU) employee and student with a work and educational environment free from prohibited

discrimination or harassment. This policy has been developed to reaffirm these principles and to provide recourse

for those individuals whose rights have been violated.

II. Accountability

Supervisors and Managers are responsible for maintaining a discrimination and harassment-free work and

educational environment. The Office of Employee Equity in Human Resources and the Office of Student Equity &

Compliance in the Division of Diversity, Equity and Inclusion are responsible for the promotion and

implementation of this policy, as well as responding to any and all complaints of violations of this policy.

III. Applicability

As a New Jersey state institution, Rowan University (CMSRU) is subject to state legislation prohibiting

discrimination, described more fully at N.J.A.C. 4A:7-3. This Policy, modeled after the New Jersey State Policy

Prohibiting Discrimination in the Workplace, is applicable to all Rowan University (CMSRU) employees,

prospective employees and students bringing forth complaints against university employees for alleged

discrimination.

As a recipient of Federal financial assistance, Rowan University (CMSRU) is also subject to Title IX of the

Education Amendments of 1972. Title IX is a federal law that prohibits sex discrimination in the University’s

(CMSRU’s) programs and activities. It reads: “No person in the United States shall, on the basis of sex, be

excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education

program or activity receiving Federal financial assistance.” Student complaints of sexual misconduct against

students and University (CMSRU) employees raise Title IX concerns and are therefore governed by the

University’s (CMSRU’s) Policy Prohibiting Sexual Misconduct and Harassment.

(https://confluence.rowan.edu/display/POLICY/Student+Sexual+Misconduct+and+Harassment+Policy).

Student Discrimination Complaints Against Other Students: Complaints by students against other students for

all forms of discrimination based on protected classifications should be reported to the Associate Vice President of

Diversity, Equity and Inclusion, who retains discretion to determine the most appropriate avenue of response,

including but not limited to, coordination with other University (CMSRU) resources such as Residential Learning,

the Office of Community Standards or the Dean of Students/CMSRU Office of Student Affairs. (See:

Office of

Student Equity and Compliance, Complaint

Form: https://cm.maxient.com/reportingform.php?RowanUniv&layout_id=16). Not all such allegations will

warrant a full investigation, but the University (CMSRU) reserves the right to investigate any matter in which

discrimination based on a protected class is asserted.

IV. Definitions

1. Discrimination/Harassment in the Workplace or Educational Environment means any employment or

educational practice or procedure that treats an individual less favorably based upon any of the protected

categories referred to below or as provided under applicable law. It is also a violation of this policy to use

derogatory or demeaning references regarding the protected categories listed below or as provided under

applicable law.

2. Sexual Harassment in the Workplace means unwelcome sexual advances, requests for sexual favors and

other verbal or physical conduct of a sexual nature when, for example:

a. Submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s

employment;

b. Submission to or rejection of such conduct by an individual is used as the basis for employment decisions

affecting such individual; or

c. Such conduct has the purpose or effect of unreasonably interfering with an individual’s work

performance or creating an intimidating, hostile or offensive working environment.

3. Sexual Misconduct in the Educational Environment means the forms of sexual misconduct set forth in the

Policy Prohibiting Sexual Misconduct and Harassment.

(https://confluence.rowan.edu/display/POLICY/Student+Sexual+Misconduct+and+Harassment+Policy

). All

of the definitions and procedures set forth in that policy apply to such complaints. Prohibited conduct

includes Non-Consensual Sexual Intercourse or Penetration (Rape), Non-Consensual Sexual Contact

(Fondling), Sexual Exploitation, Intimate Partner Violence, Stalking and Sexual/Gender-Based Harassment.

4. Third Party Harassment means unwelcome behavior involving any of the protected categories referred to in

the policy below that is not directed at an individual but exists in the workplace and interferes with an

individual’s ability to do his or her job.

5. Retaliation means adverse employment or educational consequences based upon that employee or student

bringing forth a complaint, providing information for an investigation, testifying in any proceeding under

this policy or engaging in any other protected activity under this policy or under applicable law.

V. Standard of Evidence

A finding under this policy will be based on the preponderance of the evidence standard. In other words, a finding

will be made if the evidence shows that it is more likely than not that a violation of the policy occurred.

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VI. Policy Statement

1. Protected Categories

Rowan University (CMSRU) is committed to providing every employee, prospective employee and student

with a work and educational environment free from prohibited discrimination or harassment. Under this policy,

forms of discrimination or harassment based upon the following protected categories are prohibited and will

not be tolerated: race, creed, color, national origin, nationality, ancestry, age, sex/gender (including pregnancy),

marital status, civil union status, domestic partnership status, familial status, religion, affectional or sexual

orientation, gender identity or expression, atypical hereditary cellular or blood trait, genetic information,

liability for service in the Armed Forces of the United States, disability or any other protected classification

(N.J.A.C. 4A:7-3.1).

To achieve the goal of maintaining a work and educational environment free from discrimination and

harassment, Rowan University (CMSRU) strictly prohibits the conduct that is described in this policy. This is a

zero-tolerance policy. This means that the University (CMSRU) reserves the right to take either disciplinary

action, if appropriate, or other corrective action, to address any unacceptable conduct that violates this policy,

regardless of whether the conduct satisfies the legal definition of discrimination or harassment.

2. Applicability

Prohibited discrimination/harassment undermines the integrity of the employment relationship, compromises

equal employment opportunity, debilitates morale and interferes with work productivity. Thus, this policy

applies to all employees and applicants for employment at Rowan University (CMSRU). Similarly,

discrimination/harassment undermines the integrity of the educational relationship and compromises a

student’s ability to participate in and enjoy the benefits of the University’s (CMSRU’s) education program.

Thus, this policy applies to student complaints alleging discrimination against University (CMSRU)

employees, with the exception of sexual misconduct allegations, which are governed by the Policy Prohibiting

Sexual Misconduct and Harassment.

The University (CMSRU) will not tolerate harassment or discrimination by anyone in the workplace or

educational environment, including supervisors, co-workers, professors, adjunct faculty or persons doing

business with the University (CMSRU), including vendors and third-party consultants. This policy also

applies to both conduct that occurs in the workplace or educational environment and conduct that occurs at

any location which can be reasonably regarded as an extension of the workplace or educational environment

(any field location, any off-site business-related social function, or any facility where Rowan University

(CMSRU) business is being conducted and discussed).

This policy also applies to third party harassment. Third party harassment, or hostile environment harassment,

is unwelcome behavior involving any of the protected categories referred to in the section above that is not

directed at an individual but exists in the workplace or educational environment and interferes with an

individual’s ability to do his or her job or to participate in and enjoy the benefits of the education program.

Third party harassment based upon any of the aforementioned protected categories is prohibited by this

policy.

3. Prohibited Conduct

It is a violation of this policy to engage in any employment or educational practice or procedure that treats an

individual less favorably based upon any of the protected categories referred to above. This policy pertains to

all employment practices such as recruitment, selection, hiring, training, promotion, transfer, assignment,

layoff, return from layoff, termination, demotion, discipline, compensation, fringe benefits, working

conditions and career development and to all educational practices such as grading student work, providing

educational opportunities and discipline.

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It is also a violation of this policy to use derogatory or demeaning references regarding a person’s race,

gender, age, religion, disability, affectional or sexual orientation, ethnic background or any other protected

category set forth above. A violation of this policy can occur even if there was no intent on the part of an

individual to harass or demean another.

a. Examples of behaviors that may constitute a violation of this policy include, but are not limited to:

i. Discriminating against an individual with regard to terms and conditions of employment or

education because of being in one or more of the protected categories referred to above;

ii. Treating an individual differently because of the individual’s race, color, national origin or other

protected category or because an individual has the physical, cultural or linguistic characteristics of

a racial, religious or other protected category;

iii. Treating an individual differently because of marriage to, civil union to, domestic partnership with

or association with persons of a racial, religious or other protected category; or due to the

individual’s membership in or association with an organization identified with the interests of a

certain racial, religious or other protected category; or because an individual’s name, domestic

partner’s name or spouse’s name is associated with a certain racial, religious or other protected

category;

iv. Calling an individual by an unwanted nickname that refers to one or more of the above protected

categories or telling jokes pertaining to one or more protected categories;

v. Using derogatory references with regard to any of the protected categories in any communication;

vi. Engaging in threatening, intimidating, or hostile acts toward another individual in the workplace or

educational environment because that individual belongs to, or is associated with, any of the

protected categories; or

vii. Displaying or distributing material (including electronic communications) in the workplace or

educational environment that contains derogatory or demeaning language or images pertaining to

any of the protected categories.

4. Romantic Relationships with University (CMSRU) Employees

a. Romantic/sexual relationships that occur in the context of employment supervision or evaluation present

special problems. These types of romantic/sexual relationships are especially vulnerable to exploitation

due to the difference in power and the respect and trust that are often present between a supervisor and a

subordinate, or a senior and junior colleague in the same unit. Therefore, the University (CMSRU)

strongly discourages romantic/sexual relationships between individuals where there is an imbalance of

power where one individual is in a position to make decisions, which may affect the standing or

employment or career of the other. A subordinate’s “voluntary” participation in a romantic/sexual

relationship with an individual in a position of power or authority does not alone demonstrate that the

conduct was welcome. A supervisor’s display of a romantic interest in a subordinate may constitute

sexual harassment. Employees in romantic/sexual relationships must recuse themselves from decision

making when the decisions at issue may have an impact, either direct or indirect, on the employee with

whom they are romantically involved. Those in a position of power who engage in a romantic or sexual

relationship deemed unwelcome at any time by the other party may be in violation of this Policy and

subject to investigation and possible disciplinary action.

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b. Romantic/sexual relationships that occur in the student-professor context present special problems. These

types of romantic/sexual relationships are especially vulnerable to exploitation due to the difference in

power and the respect and trust that are often present between a professor and a student. Therefore, the

University (CMSRU) strongly discourages romantic/sexual relationships between individuals where

there is an imbalance of power where one individual is in a position to make decisions which may affect

the educational opportunities or standing of the other. A student's “voluntary” participation in a

romantic/sexual relationship with an individual in a position of power or authority does not alone

demonstrate that the conduct was welcome. Therefore, the attempts of a professor to show a romantic

interest in a student may constitute sexual harassment. University (CMSRU) employees in

romantic/sexual relationships must recuse themselves from decision making when the decisions at issue

may have an impact, either direct or indirect, on the student with whom they are romantically/sexually

involved. Those who abuse their power in such circumstances may be found to have violated this Policy.

An abuse of power may be, but is not limited to, inflating a student's grade, or providing preferential

academic opportunities to an individual based on a romantic or sexual relationship.

c. Any individual who engages in a consensual romantic or sexual relationship with someone over whom he

or she has supervisory responsibility in the employment context, or educational responsibility in the

educational context, must inform his or her immediate supervisor of the consensual relationship so that

the University (CMSRU) can take appropriate action to make changes that eliminate the conflict of

interest. Failure to give proper notice to the appropriate supervisor may result in the denial of legal

representation and indemnification in the event that a lawsuit based on the relationship is filed. In

addition, failure to give proper notice to the appropriate supervisor may result in disciplinary action.

5. Sexual Harassment in the Workplace

a. It is a violation of this policy to engage in sexual (or gender-based) harassment of any kind, including

hostile work environment harassment, quid pro quo harassment or same-sex harassment. For the

purposes of this policy, sexual harassment is defined, as in the Equal Employment Opportunity

Commission Guidelines, as unwelcome sexual advances, requests for sexual favors and other verbal or

physical conduct of a sexual nature when, for example:

i. Submission to such conduct is made either explicitly or implicitly a term or condition of an

individual’s employment;

ii. Submission to or rejection of such conduct by an individual is used as the basis for employment

decisions affecting such individual; or

iii. Such conduct has the purpose or effect of unreasonably interfering with an individual's work

performance or creating an intimidating, hostile or offensive working environment.

b. Examples of prohibited behaviors that may constitute sexual harassment and are therefore a violation of

this policy include, but are not limited to

i. Generalized gender-based remarks and comments;

ii. Unwanted physical contact such as intentional touching, grabbing, pinching, brushing against

another's body or impeding or blocking movement;

iii. Verbal, written or electronic sexually suggestive or obscene comments, jokes or propositions

including letters, notes, e-mail, text messages, invitations, gestures or inappropriate comments

about a person's clothing;

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iv. Visual contact, such as leering or staring at another's body; gesturing; displaying sexually

suggestive objects, cartoons, posters, magazines or pictures of scantily-clad individuals; or

displaying sexually suggestive material on a bulletin board, on a locker room wall, or on a screen

saver;

v. Explicit or implicit suggestions of sex by a supervisor or manager in return for a favorable

employment action such as hiring, compensation, promotion or retention;

vi. Suggesting or implying that failure to accept a request for a date or sex would result in an adverse

employment consequence with respect to any employment practice such as performance

evaluation or promotional opportunity; or

vii. Continuing to engage in certain behaviors of a sexual nature after an objection has been raised by

the target of such inappropriate behavior.

6. Student Responsibilities

Any student who believes that she or he has been subjected to any form of prohibited

discrimination/harassment by an employee, or who witnesses other students being subjected to such

discrimination/harassment, is encouraged to promptly report the incident(s) to the Office of Student Equity &

Compliance in the Division of Diversity, Equity and Inclusion. (Complaint

Form:

https://cm.maxient.com/reportingform.php?RowanUniv&layout_id=16).

7. Employee Responsibilities

Any employee who believes that she or he has been subjected to any form of prohibited

discrimination/harassment, or who witnesses others being subjected to such discrimination/harassment, is

encouraged to promptly report the incident(s) to a supervisor or directly to the Office of Employee Equity in

Human Resources. (Complaint Form: Civil Service Employees

–

https://sites.rowan.edu/equity/_docs/discrimination_complaint_form.pdf; non-Civil Service Employees

– https://sites.rowan.edu/equity/_docs/policies/non-discrimination-complaint-form.pdf).

Any employee who receives a complaint from a student that she or he has been subjected to any form of

prohibited discrimination/harassment by an employee, or who witnesses students being subjected to such

discrimination/harassment, is encouraged to promptly report the incident(s) to the Office of Student Equity &

Compliance in the Division of Diversity, Equity and Inclusion. (Complaint

Form: https://cm.maxient.com/reportingform.php?RowanUniv&layout_id=16

All employees are expected to cooperate with investigations undertaken pursuant to the Procedures for

Internal Discrimination/Harassment Complaints below. Failure to cooperate in an investigation may result in

administrative and/or disciplinary action, up to and including termination of employment.

8. Supervisor Responsibilities

Supervisors shall make every effort to maintain a work or educational environment that is free from any

form of prohibited discrimination/harassment. Supervisors shall immediately refer allegations of prohibited

discrimination/harassment made by employees to the Office of Employee Equity in Human Resources and

allegations made by students to the Office of Student Equity & Compliance in the Division of Diversity,

Equity and Inclusion.

A supervisor’s failure to comply with these requirements may result in administrative and/or disciplinary

action, up to and including termination of employment. For purposes of this Policy, a supervisor is defined

broadly to include any manager or other individual who has authority to control the work environment of any

other staff member (for example, a project leader).

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9. Dissemination

The University (CMSRU) shall annually distribute the policy described in this section, or a summarized

notice of it, to all of its employees and students, including part-time and seasonal employees. The policy can

be accessed on the Rowan University website

https://sites.rowan.edu/equity/policies.html or a hardcopy can

be obtained from the Office of Employee Equity in Human Resources. Rowan University (CMSRU) will

distribute the policy to vendors/contractors with whom it has a direct relationship.

10. C

omplaint Process

Rowan University (CMSRU) follows the Model Procedures for Processing Internal Discrimination

Complaints with regard to reporting, investigating and where appropriate, remediating claims of

discrimination/harassment (See Procedures for Internal Discrimination/Harassment Complaints, below,

and N.J.A.C. 4A:7-3.2).

The Office of Employee Equity in Human Resources is responsible for receiving and investigating

complaints of discrimination/harassment made by employees against employees and third parties. The Office

of Student Equity & Compliance in the Division of Diversity, Equity and Inclusion is responsible for

receiving and investigating complaints of discrimination/harassment made by students against employees and

third parties.

All investigations of discrimination/harassment claims shall be conducted in a way that respects, to the extent

possible, the privacy of all the persons involved. The investigations shall be conducted in a prompt, thorough

and impartial manner. The results of the investigations of complaints against employees shall be forwarded to

the Rowan University Vice President of Human Resources (or his/her authorized designee) to make a final

decision as to whether a violation of the policy has been substantiated.

Where a violation of this policy is found to have occurred, Rowan University (CMSRU) shall take prompt

and appropriate remedial action to stop the behavior and deter its reoccurrence. The University (CMSRU)

shall also have the authority to take prompt and appropriate remedial action, such as moving two employees

or employees and students apart, before a final determination has been made regarding whether a violation of

this policy has occurred.

The remedial action taken may include counseling, training, intervention, mediation, and/or the initiation of

disciplinary action up to and including termination of employment.

Rowan University (CMSRU) shall maintain a written record of the discrimination/harassment complaints

received. Written records shall be maintained as confidential records to the extent practicable and

appropriate.

11. Prohibition Against Retaliation

a. Retaliation against any employee or student who alleges that she or he was the victim of

discrimination/harassment, provides information in the course of an investigation into claims of

discrimination/harassment in the workplace or educational environment, or opposes a discriminatory

practice, is prohibited by this policy. No employee or student bringing a complaint, providing

information for an investigation or testifying in any proceeding under this policy shall be subjected to

adverse employment or other consequences based upon such involvement or be the subject of other

retaliation.

b. Following are examples of prohibited actions taken against an employee or student because the employee

or student has engaged in activity protected by this subsection:

i. Termination of an employee;

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ii. Failing to promote an employee;

iii. Altering an employee’s work or a student’s course assignment for reasons other than legitimate

business or educational reasons;

iv. Imposing or threatening to impose disciplinary action on an employee or student for reasons other

than legitimate business or educational reasons;

v. Ostracizing an employee or student (for example, excluding an employee or student from an activity

or privilege offered or provided to all other employees or students); or

vi. Imposing a poor grade or evaluation of a student for other than legitimate educational reasons.

12. False Accusations and Information:

An employee who knowingly makes a false accusation of prohibited discrimination/harassment or knowingly

provides false information in the course of an investigation of a complaint, may be subjected to administrative

and/or disciplinary action, up to and including termination of employment. Similarly, a student who

knowingly makes a false accusation of prohibited discrimination/harassment or knowingly provides false

information in the course of an investigation of a complaint, may be subjected to discipline under the Student

Code of Conduct. Complaints made in good faith, however, even if found to be unsubstantiated, shall not be

considered a false accusation.

13. C

onfidentiality:

All complaints and investigations shall be handled, to the extent possible, in a manner that will protect the

privacy interests of those involved, and the University (CMSRU) will strive to prevent any unnecessary

disruption to the work or educational environment. To the extent practical and appropriate under the

circumstances, confidentiality shall be maintained throughout the investigatory process. In the course of an

investigation, it may be necessary to discuss the claims with the person(s) against whom the complaint was

filed and other persons who may have relevant knowledge or who have a legitimate need to know about the

matter. All persons interviewed, including witnesses, shall be directed not to discuss any aspect of the

investigation with others in light of the important privacy interests of all concerned. Failure to comply with

this confidentiality directive may result in administrative and/or disciplinary action, up to and including

termination of employment or student discipline in accord with the Student Code of Conduct.

14. A

dministrative and/or Disciplinary Action:

Any employee found to have violated any portion or portions of this policy may be subject to appropriate

administrative and/or disciplinary action which may include, but which shall not be limited to – referral for

training, referral for counseling, written or verbal reprimand, suspension, reassignment, demotion, or

termination of employment. Referral to another appropriate authority for review for possible violation of State

and Federal statutes may also be appropriate.

15. T

raining:

Rowan University (CMSRU) shall provide all new employees with training on the policy and procedures set

forth in this section within a reasonable period of time after each new employee’s appointment date. Refresher

training shall be provided to all employees, including supervisors, within a reasonable period of time. The

University (CMSRU) shall also provide supervisors with training on a regular basis regarding their obligations

and duties under the policy and regarding procedures set forth in this section.

VII. P

rocedures for Internal Discrimination/Harassment Complaints

The following procedures are adapted from the New Jersey Model Procedures for Internal Complaints Alleging

Discrimination in the Workplace, N.J.A.C. 4A:7-3.2. Rowan University (CMSRU) will follow the procedures

below in the receipt and investigation of discrimination complaints.

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a. All employees, applicants for employment, and students have the right and are encouraged to immediately

report suspected violations of the Rowan University (CMSRU) Policy Prohibiting Discrimination in the

Workplace and Educational Environment (as adapted from N.J.A.C. 4A:7-3.1).

b. Complaints of prohibited discrimination/harassment made by employees against employees should be

reported to the Assistant Vice President of Employee Equity & Labor Relations and/or HR Investigation

Manager in Human Resources, or to any supervisory employee of Rowan University (CMSRU). (Complaint

Form: Civil Service Employees – https://sites.rowan.edu/equity/_docs/discrimination_complaint_form.pdf

;

non-Civil Service Employees – https://sites.rowan.edu/equity/_docs/policies/non-discrimination-complaint-

form.pdf). Complaints of prohibited discrimination/harassment made by students against employees should

be reported to the Associate Vice President of Diversity, Equity and Inclusion or the DEI Investigation

Manager in the Division of Diversity, Equity and Inclusion. (Complaint

Form:

https://cm.maxient.com/reportingform.php?RowanUniv&layout_id=16).

c. Every effort should be made to report complaints promptly. Delays in reporting may not only hinder a proper

investigation but may also unnecessarily subject the victim to continued prohibited conduct.

d. Supervisory employees shall immediately report all alleged violations of the Rowan University (CMSRU)

Policy Prohibiting Discrimination in the Workplace and Educational Environment. Complaints made by

employees shall be reported to the Assistant Vice President of Employee Equity & Labor Relations and/or

HR Investigation Manager in Human Resources. Complaints made by students shall be reported to the

Associate Vice President of Diversity, Equity and Inclusion or DEI Investigation Manager in the Division of

Diversity, Equity and Inclusion. Such a report shall include both alleged violations reported to a supervisor,

and those alleged violations directly observed by the supervisor.

e. If reporting a complaint to any of the persons set forth in paragraphs b. or d. above presents a conflict of

interest, Civil Service employees can file the complaint directly with the Division of EEO/AA, P.O. Box 315,

Trenton, NJ 08625, and non-Civil Service employees can file a complaint directly with the Associate Vice

President of Human Resources. An example of such a conflict would be where the individual against whom

the complaint is made is involved in the intake, investigative or decision-making process.

f. In order to facilitate a prompt, thorough and impartial investigation, all employee complainants are

encouraged to submit a Complaint Form, which can be found at: Civil Service Employees

– https://sites.rowan.edu/equity/_docs/discrimination_complaint_form.pdf

; non-Civil Service Employees

– https://sites.rowan.edu/equity/_docs/policies/non-discrimination-complaint-

form.pdf). https://sites.rowan.edu/equity/_docs/policies/non-discrimination-complaint-form.pdf. Student

complainants are encouraged to submit a Complaint Form, which can be found

https://cm.maxient.com/reportingform.php?RowanUniv&layout_id=16. An investigation may be

conducted whether or not the form is completed.

g. To the extent required, Rowan University (CMSRU) shall maintain a written record of the

discrimination/harassment complaints received. Written records shall be maintained as confidential records to

the extent practicable and appropriate. A copy of all complaints (regardless of the format in which submitted)

must be submitted to the Civil Service Commission, Division of EEO/AA, by the University’s Office of

Employee Equity, along with a copy of the acknowledgement letter(s) sent to the person(s) who filed the

complaint and, if applicable, the complaint notification letter sent to the person(s) against whom the

complaint has been filed. If a written complaint has not been filed, the Office of Employee Equity must

submit to the Division of EEO/AA a brief summary of the allegations that have been made. Copies of

complaints filed with the New Jersey Division on Civil Rights, the U.S. Equal Employment Opportunity

Commission, or in court also must be submitted to the Division of EEO/AA.

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h. During the initial intake of a complaint, the representative of the Office of Employee Equity or representative

from the Office of Student Equity & Compliance, or an authorized designee, will obtain information

regarding the complaint, and determine if interim corrective measures are necessary to prevent continued

violations of the Rowan University (CMSRU) Policy Prohibiting Discrimination in the Workplace and

Educational Environment.

i. At the discretion of the Assistant Vice President of Employee Equity & Labor Relations or Associate Vice

President of Diversity, Equity, and Inclusion, whichever is applicable, a prompt, thorough and impartial

investigation into the alleged harassment or discrimination will take place.

j. An investigatory report will be prepared by the Assistant Vice President of Employee Equity & Labor

Relations or the Associate Vice President of Diversity, Equity, and Inclusion, whichever is applicable, or his

or her designee, when the investigation is completed. The report will include, at a minimum:

i. A summary of the complaint;

ii. A summary of the parties’ positions;

iii. A summary of the facts developed through the investigation; and

iv. An analysis of the allegations and the facts.

The investigatory report will be submitted to the President’s designee, the Vice President of Human

Resources (or his/her authorized designee), who will issue a final letter of determination to the

parties.

k. The President’s designee (or his/her authorized designee) will review the investigatory report issued by the

Assistant Vice President of Employee Equity & Labor Relations or the Associate Vice President of

Diversity, Equity and Inclusion, whichever is applicable, or his or her authorized designee, and make a

determination as to whether the allegation of a violation of the Rowan University (CMSRU) Policy

Prohibiting Discrimination in the Workplace and Educational Environment has been substantiated. If a

violation has occurred, the President’s designee (or his/her authorized designee) will refer the matter to the

Assistant Vice President of Employee Equity & Labor Relations to determine the appropriate corrective

measures necessary to immediately remedy the violation.

l. The President’s designee (or his/her authorized designee) will issue a final letter of determination to both the

complainant(s) and the person(s) against whom the complaint was filed, setting forth the results of the

investigation and the right of appeal as set forth in the Paragraphs below. To the extent possible, the privacy

of all parties involved in the process shall be maintained in the final letter of determination. The Civil

Service Commission, Division of EEO/AA shall be furnished with a copy of the final letter of

determination.

i. The letter shall include, at a minimum:

1. A brief summary of the parties’ positions;

2. A brief summary of the facts developed during the investigation; and

3. An explanation of the determination, which shall include whether:

a. The allegations were either substantiated or not substantiated; and

b. A violation of the Rowan University (CMSRU) Policy Prohibiting Discrimination in the

Workplace and Educational Environment did or did not occur.

ii. The investigation of a complaint shall be completed and a final letter of determination shall be

issued no later than 120 days after the initial intake of the complaint is completed.

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iii. The time for completion of the investigation and issuance of the final letter of determination may be

extended by Rowan University (CMSRU) for up to 60 additional days in cases involving

exceptional circumstances. When applicable, the Office of Employee Equity shall provide the

Division of EEO/AA and all parties with written notice of any extension and shall include in the

notice an explanation of the exceptional circumstances supporting the extension.

m. A complainant who is in the career, unclassified or senior executive service, or who is an applicant for

employment, who disagrees with the determination of the President’s designee (or his/her authorized

designee), may submit a written appeal to the New Jersey Civil Service Commission (“NJCSC”), Division

of Merit System Practices and Labor Relations, Written Record Appeals Unit, P.O. Box 312, Trenton, NJ

08625-0312, postmarked or delivered within 20 days of the receipt of the determination from the President’s

designee (or his/her authorized designee). The appeal shall be in writing and include all materials presented

by the complainant at the University (CMSRU) level, the final letter of determination, the reason for the

appeal and the specific relief requested. Please be advised that there is a fee for appeals. Please include a

check or money order along with the appeal, payable to NJCSC. Persons receiving public assistance and

those qualifying for NJCSC Veterans Preference are exempt from this fee.

i. Civil Service employees filing appeals which raise issues for which there is another specific appeal

procedure must utilize those procedures. The Civil Service Commission may require any appeal,

which raises issues of alleged discrimination and other issues, such as examination appeals, to be

processed using the procedures set forth in this section or a combination of procedures as the

Commission deems appropriate. See N.J.A.C. 4A:2-1.7.

ii. If an appeal under this policy raises issues concerning the employee not receiving an advancement

appointment, the Commission shall decide those issues in the course of its determination.

iii. The Civil Service Commission shall decide the appeal on a review of the written record or such

other proceeding as it deems appropriate. See N.J.A.C. 4A:2-1.1(d).

iv. The appellant shall have the burden of proof in all discrimination appeals brought before the Civil

Service Commission.

n. In a case where a violation has been substantiated, and no disciplinary action recommended, the party(ies)

against whom the complaint was filed, and who are in the career, unclassified or senior executive service,

may appeal the determination to the Civil Service Commission at the address indicated above, within 20

days of receipt of the final letter of determination by the President’s designee (or his/her authorized

designee).

i. The burden of proof shall be on the appellant.

ii. The appeal shall be in writing and include the final letter of determination, the reason for the appeal,

and the specific relief requested.

iii. If disciplinary action has been recommended in the final letter of determination, the party/parties

charged, who are in the career, unclassified or senior executive service may appeal using the

procedures set forth in N.J.A.C. 4A:2-2 (Major Discipline) and 3 (Minor Discipline and

Grievances).

o. A complainant or respondent (an individual against whom the complaint was filed) who is NOT in the

career, unclassified or senior executive service, or who is NOT an applicant for employment, or who is a

student of Rowan University (CMSRU), who disagrees with the determination of the President’s designee

(or his/her authorized designee), may submit a written appeal to the Chief of Staff, postmarked or delivered

109

within 20 days of the receipt of the determination from the President's designee (or his/her authorized

designee). The appeal shall be in writing, presented by the complainant or respondent to the Chief of Staff,

with a copy to the Assistant Vice President of Employee Equity & Labor Relations in Human Resources, as

set forth below. The Chief of Staff (or his/her authorized designee) may or may not elect to review a

decision. The Chief of Staff (or his/her authorized designee) shall respond to a request for review within 15

days.

i. The complainant or respondent may request an appeal of the determination only if the complainant

or respondent is able to produce new information not previously submitted or can produce

information demonstrating that the determination was arbitrary and capricious. This means that the

determination will be considered for review only if new information exists or if information exists

demonstrating that the determination was invalid because it was made on unreasonable grounds or

without consideration of the circumstances.

ii. The complainant or respondent should send either the new information or a brief explanation of why

they believe the finding is arbitrary and capricious based upon the facts presented to the Chief of

Staff (with a copy to the Assistant Vice President of Employee Equity & Labor Relations in Human

Resources) within 20 days of receipt of the determination letter. The appeal shall be in writing and

shall include only those materials supporting the request for review and the specific relief

requested. You need not include the original materials submitted with the complaint or in response

to the complaint as these documents will be provided by the original office to whom the complaint

was submitted. The Chief of Staff (or his/her authorized designee) may elect to review the materials

only if it is believed the determination is arbitrary and capricious, or if the new materials were not

previously considered in the original determination.

iii. The appellant shall have the burden of proof in all discrimination appeals brought before the Chief

of Staff (or his/her authorized designee).

p. When required, the Division of EEO/AA shall be placed on notice of, and given the opportunity to submit

comments on, appeals filed with the Civil Service Commission of decisions on discrimination complaints,

regardless of whether or not the complaint was initially filed directly with the Division of EEO/AA.

VIII. External Agencies

Any employee or applicant for employment can file a complaint directly with external agencies that investigate

discrimination/harassment charges in addition to utilizing this internal procedure. The timeframes for filing

complaints with external agencies indicated below are provided for informational purposes only. An individual

should contact the specific agency to obtain exact timeframes for filing a complaint. The deadlines run from the

date of the last incident of alleged discrimination/harassment, not from the date that the final letter of

determination is issued by the President’s designee (or his/her authorized designee).

Division on Civil Rights

N. J. Department of Law & Public Safety (Within 180 days of the discriminatory act)

Trenton Regional Office

140 East Front Street

6th Floor, P.O. Box 090

Trenton NJ 08625-0090

(609) 292-4605

Newark Regional Office

31 Clinton Street, 3rd floor

110

P.O. Box 46001

Newark, NJ 07102

(973) 648-2700

Atlantic City Office

26 Pennsylvania Avenue

Floor

Atlantic City, NJ 08401

(609) 441-3100

Camden Regional Office

One Port Center, 4

Floor

2 Riverside Drive, Suite 402

Camden, NJ 08103

(856) 614-2550

Paterson Regional Office

100 Hamilton Plaza, Suite 800

Paterson, NJ 07505-2109

(973) 977-4500

United States Equal Employment Opportunity

Commission (EEOC)

(Within 300 days of the discriminatory act)

National Call Center – 1 800-669-4000

Newark Area Office

Two Gateway Center

Suite 1703

283-299 Market Street

Newark, NJ 07102

1-800-669-4000

The Newark Area Office has jurisdiction over the State of New Jersey Counties of Bergen,

Essex, Hudson, Hunterdon, Mercer, Middlesex, Monmouth, Morris, Passaic, Somerset,

Sussex, Union and Warren.

Philadelphia District Office

801 Market Street, Suite 1300

Philadelphia, PA 19107-3127

1-800-669-4000 / 267-589-9700 / or email PDO[email protected]

The Philadelphia District Office has jurisdiction over the State of New Jersey Counties of

Atlantic, Burlington, Camden, Cape May, Cumberland, Gloucester, Ocean and Salem.

IX. References

1. N.J.A.C. 4A:7 Equal Employment Opportunity and Affirmative Action

2. New Jersey Policy Prohibiting Discrimination in the Workplace

3. New Jersey Model Procedures for Internal Complaints Alleging Discrimination in the Workplace

4. Non-Civil Service Employee Discrimination Complaint Processing Form

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5. Civil Service Employee Discrimination Complaint Processing Form

6. Student Discrimination Complaint Processing Form

Student Mistreatment Policy

POLICY:

Cooper Medical School of Rowan University (“CMSRU”) is committed to promoting student success in an

atmosphere dependent upon mutual respect, collegiality, fairness, trust, and accountability within its respective

community. Student mistreatment, abuse, harassment, intimidation or bullying will not be tolerated. If a student

alleges mistreatment or becomes aware of an incident of mistreatment by a member of the CMSRU community,

they are encouraged to follow this policy. CMSRU adheres to the standards described in the Association of

American Medical Colleges (“AAMC”) Teacher-Learner Compact (see Teacher-Learner Interaction Policy located

in the Student Handbook, the Faculty Handbook, and the CMSRU Compendium of Policies for Faculty, Residents

and Staff). Students are expected to abide by the tenets of the CMSRU Professional Conduct Policy.

PURPOSE:

The purpose of this policy is to outline expectations of behaviors that promote a positive learning environment for

CMSRU medical students, to provide mechanisms and procedures for students to report alleged mistreatment, and to

identify procedures to address alleged violations. This policy offers a definition of these expectations, provides

examples and definitions of unacceptable treatment of medical students, describes the procedures available to report

incidents of mistreatment, and informs what actions will be taken to monitor, investigate, and respond to reports.

SCOPE:

This policy applies to all CMSRU medical students and those who serve as teachers, mentors or other CMSRU

community members with whom students interact throughout all years and areas of the educational experience.

DEFINITIONS:

Discrimination: An educational practice or procedure that treats an individual less favorably based upon any of the

following protected categories: race, creed, color, national origin/ethnicity, nationality, ancestry, age, sex/gender,

pregnancy, marital status, civil union status, domestic partnership status, familial status, religion, affectional or

sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, genetic information,

liability for service in the Armed Forces of the United States, disability or any other protected classification

(N.J.A.C. 4A:7-3.1).

Mistreatment: T

he Liaison Committee on Medical Education (“LCME”) states, “Mistreatment, either intentional or

unintentional, occurs when behavior shows disrespect for the dignity of others or unreasonably interferes with the

learning process.” It can take the form of physical punishment, harassment, psychological cruelty, and

discrimination based on race, religion, ethnicity, sex, age or sexual orientation or any other protected class. The

CMSRU End Mistreatment Task Force determined and compiled a list of mistreatment never behaviors. The

following behaviors represent mistreatment of patients, colleagues, or learners and should never occur.

Never Behaviors:

• Never make disparaging comments to or about other professionals.

• Never make disrespectful comments to or about patients, their friends, or family members.

• Never belittle, humiliate, harass, or bully a learner.

• Never subject anyone to physical harm or threat of physical harm.

• Never require learners to perform non-team-centric, non-patient-centric personal services.

• Never require learners to perform tasks intended to punish, belittle, humiliate or control the learner.

• Never subject learners to discriminatory exclusion from learning opportunities, a hostile

learning/working environment, or intentional neglect.

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• Never subject learners to offensive, sexist remarks or subject them to unwanted sexual advances

(physical or verbal).

• Never ask anyone to exchange sexual favors for rewards.

• Never engage in an intimate relationship with a learner one is responsible for supervising,

evaluating, mentoring, or coaching.

• Never deny learners opportunities for training or rewards because of gender, age, race, disability,

ethnicity, sexual orientation, or religion.

• Never subject anyone to negative or offensive comments or behaviors because of gender, age, race,

disability, ethnicity, sexual orientation, or religion.

• Never pressure a learner to perform a medical procedure for which they are insufficiently trained or

insufficiently supervised.

• Never subject anyone to inappropriate comments about their appearance.

• Never subject learners to retaliation or threats of retaliation for making a good-faith report of

mistreatment or unprofessional behavior.

Retaliation: Adverse action taken against an individual in response to, motivated by, or in connection with an

individual’s complaint of mistreatment, participation in an investigation of such complaint and/or opposition to

reported mistreatment in the educational or workplace setting.

STUDENT REPORTING PROCEDURE: It is strongly suggested that students submit an electronic Mistreatment

Report in real-time for all alleged mistreatment-related events to ensure proper follow-up and resolution. A student

can report an incident by using any of the following methods/venues of reporting:

• Office of Student Affairs

o Erin Pukenas, MD; Associate Dean for Student Affairs, pukenas@rowan.edu

o Marion Lombardi, EdD; Assistant Dean for Student Affairs, lombar[email protected]du

o Stephanie Smith, MD: Director of Student Affairs, wilsey@rowan.edu

• Office of Diversity and Community Affairs

o Guy Hewlett, MD; Associate Dean for Diversity and Community Affairs,

[email protected]

o Sue Liu, MA, MPA, Asst. Director of Community Affairs, [email protected]

o Taruna Chugeria, MEd, Asst. Director of Special Programs, [email protected]

• CMSRU Ombuds Office

o Debrah Meislich, MD; Ombudsperson, http://cmsru.rowan.edu/students/ombuds/

• Title IX Coordinator

o Marion Lombardi, EdD; Asst. Dean for Student Affairs, lo[email protected]

• Disabilities/Accommodations

o Marion Lombardi, EdD; Asst. Dean for Student Affairs, lo[email protected]

• Via Course and Clerkship Evaluations

o Issues of mistreatment can be voiced through the course and clerkship evaluations

distributed at the end of the course/clerkship

• Deans and Directors

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o To provide easier access to reporting, students may report an incident to any Dean or

Director they feel comfortable approaching

o The Dean or Director will then convey the complaint to the Associate Dean for Student

Affairs or designee

CONFIDENTIALITY OF REPORTING MECHANISMS

• As set forth above, CMSRU provides a number of mechanisms for both informally discussing and/or reporting

allegations of mistreatment. These mechanisms, whenever possible, are designed to respect the student’s wishes

in deciding how to report and respond to the incident. However, CMSRU cannot guarantee confidentiality when

there is a concern for the immediate safety of the student or the community. Students are strongly encouraged to

ask any questions about confidentiality before revealing details they prefer to keep private.

• While there are several anonymous and confidential ways to report inappropriate treatment of students, full

disclosure of the persons involved and the behaviors witnessed can lead to more effective action to correct the

problem. Therefore, CMSRU encourages full reporting of incidents of inappropriate treatment of students and

people involved in them. However, anonymous reports will also be investigated to the extent that specific

information is provided. A student can report anonymously by utilizing the CMSRU Student Mistreatment

Form. https://cmsruapps.rowan.edu/surveys/report_mistreatment

• If a student chooses not to remain anonymous, CMSRU will discuss with the reporting student whether they

want their name shared with the mistreatment source and the timing of contact (e.g., delay until relevant

course/clerkship has been completed). However, if the report concerns the safety of the student or the

community, it will need to be addressed immediately. Retaliation is prohibited at CMSRU and can result in

significant consequences for faculty members.

• CMSRU will keep confidential all records of complaints and investigations to the extent permitted by law.

However, behaviors that violate Title IX of the 1972 Education Amendments to the Higher Education Act,

which include discrimination or harassment based on sex or gender, must be reported by a CMSRU official so

that they can be promptly acted upon in order to be compliant with Federal Law.

• Behaviors that pose an immediate danger to others (e.g., violence or threats of physical violence, illegal drug use

by caregivers in a clinical setting, deliberate violation of patient safety procedures) or are illegal (e.g., stealing

narcotics, falsifying patient records) must also result in immediate reporting so that action can be taken. These

behaviors will be investigated, via Rowan University/CMSRU (RU/CMSRU) and Cooper University Health

Care (CUHC) policies and protocols (e.g. RU/CMSRU Anti-Violence, Impaired Student Process, Professional

Conduct, Student Code of Conduct, (CUHC) Prevention and Suspected Drug Diversion, Theft, Loss, and

Reporting Policy and Violence Prevention Plan).

• The Office of Student Affairs and the Office of Medical Education are responsible for the oversight of

mistreatment of students. After a mistreatment report is filed, the appropriate parties will review the complaint

and determine the course of action based on the severity and circumstances of the incident. If the event is

reported via a course or clerkship evaluation, it will be addressed with the respective departments and faculty. In

the event of an electronic mistreatment submission, the student, where identified, will be contacted within three

(3) business days confirming receipt of the complaint. The student, where self-identified, will participate in the

investigatory process. An action plan will be formulated within fourteen (14) days from the filing. The Standard

Operating Procedures for the Office of Student Affairs and Office of Medical Education are listed as appendices.

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RETALIATION: Threats, other forms of intimidation, and retaliation against a student for bringing a complaint of

mistreatment or for assisting another in bringing a complaint are prohibited. Reporting mistreatment will have no

impact on a student’s performance assessment. Retaliation against those reporting mistreatment or participating in

an investigation of mistreatment is also regarded as a form of mistreatment. Complaints of retaliation will be

investigated by OME or OSA, or if applicable, may be forwarded to the appropriate CMSRU and/or CUHC

administrator for investigation.

MALICIOUS ACCUSATIONS: A complainant or witness found to have been dishonest or malicious in making

allegations at any point during the investigation process may be subject to disciplinary action.

ADDITIONAL NOTES:

1. This process does not apply to the student’s personal preferences regarding the faculty/professional staff

members’ physical appearance, personal values, sexual orientation, or the right to academic freedom or

the freedom of expression.

2. To the extent possible, the student will be responsible for documentation of their allegations in all

grievance matters.

3. All students, faculty, professional staff, department chairs, supervisors, deans and directors are expected

to follow the steps outlined in this policy.

If not reported anonymously, the reporting student will be notified of the outcome of the investigation and when a

remediation plan has been made and the general approach that is being taken; however, the specific details of those

plans are generally protected in nature.

OTHER APPLICABLE POLICIES

CMSRU recognizes that this Mistreatment Policy is only one of a number of grievance procedures that may be used

by a student depending on the nature of their complaint. Depending on the circumstances, a student may choose to

pursue a remedy by alternative pathways for the alleged abusive conduct by filing a complaint as follows:

• Complaints of Sexual Harassment/Sexual Assault are referred to the Office of Student Equity and

Compliance, Division of Diversity, Equity and Inclusion, at Rowan University to be reviewed in accordance

with:

(i) Title IX Sexual Harassment/Sexual Assault Policy at:

https://confluence.rowan.edu/pages/viewpage.action?pageId=132646706

(addresses allegations of sexual misconduct that meet the definition of Title IX sexual

harassment/sexual assault occurring within a University program or activity); or

(ii) Student Sexual Misconduct and Harassment Policy at:

https://confluence.rowan.edu/display/POLICY/Student+Sexual+Misconduct+and+Harassment+

Policy (applies to forms of sexual misconduct against a student that do not fall within the scope

of the Title IX Sexual Harassment/Sexual Assault policy).

• Complaints of Discrimination are referred to the Office of Student Equity & Compliance in the Division of

Diversity, Equity and Inclusion to be reviewed in accordance with:

(i) Policy Prohibiting Discrimination in the Workplace and Educational Environment

https://confluence.rowan.edu/display/POLICY/Policy+Prohibiting+Discrimination+in+the+Wor

kplace+and+Educational+Environment

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(reaffirms the principles that students have the right to an educational environment free from

prohibited discrimination or harassment and provides recourse for those individuals whose

rights have been violated); or

(ii) Procedure for Resolving Student v. Student Discrimination Complaints

https://sites.rowan.edu/diversity-equity-inclusion/_docs/procedure-for-t6.pdf

Appendices

STANDARD OPERATING PROCEDURES

MISTREATMENT INVESTIGATION PROCESS FOR OFFICE OF STUDENT AFFAIRS

SOP name/title:

Mistreatment Review Process for

Office of Student Affairs

SOP originator:

Assistant Dean for Student Affairs

SOP Approval:

Associate Dean for

Student Affairs

Dean, CMSRU

Effective Date:

August 8, 2020

1. Reports of student mistreatment can initiate from a variety of reporting options including the anonymous

mistreatment system provided via the Office of Student Affairs (OSA), the direct reporting of the incident to any

member of the leadership team at CMSRU or a course/clerkship director, and via the course evaluation system

established by the Office of Medical Education (OME). The OSA addresses mistreatment events outside of

activities pertaining to the curriculum and other allegations of mistreatment deemed as appropriate to

investigate. When student mistreatment is reported, the following steps are taken to ensure proper review and

resolution:

• Allegations of student mistreatment occurring outside of the educational program are communicated to the

Asst. Dean for Student Affairs (ADSA)) and/or the Director of Student Affairs for review and investigation.

If the allegation of student mistreatment is a Title IX issue, the issue is directed to the Rowan University

Office of Student Equity and Compliance. If an allegation of student mistreatment is a Title IX issue and

involves a Cooper University Health Care (CUHC) employee, the issue is co-investigated by the Rowan

University Office of Student Equity and Compliance and the Cooper University Health Care Office of

Human Resources.

• Findings of the student mistreatment investigation are reported to the Associate Dean for Student Affairs.

• The ADSA reports all incidents of mistreatment to the CMSRU Dean. If an allegation of mistreatment

involves a CUHC employee or occurred at CUHC or a CUHC ambulatory site, the Dean notifies CUHC

leadership personnel.

• After discussion with the Dean and after presentation and discussion at the executive cabinet, a plan is

developed concerning the actions that need to be taken relative to the mistreatment incident. This plan is

formulated as soon as possible and within ten (10) days of completion of the investigational report.

Immediate action is taken if there is a threat to student safety or well-being.

• The student (if they supplied their name and were not anonymous) can participate in the investigatory

process and is made aware of the findings of the investigation and actions taken. If the student disagrees

with the final determination of the investigatory findings, the issue is directed to, and investigated by, the

Rowan University Office of Student Equity and Compliance. No further investigation is undertaken once the

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Rowan University Office of Student Equity and Compliance finalizes its investigation and conclusions,

unless new information is brought forward. The OSA carries out any required actions/recommendations.

• The Executive Cabinet of Deans reviews the mistreatment event and the investigational report, including

actions leading to resolution or appeal.

2. Information regarding the case (de-identified) is provided to the Committee for a Positive Learning Environment

in the standing Mistreatment Report that they receive on an ongoing basis.

3. All mistreatment information is kept confidential and maintained in a locked, firesafe cabinet in the Office of

Student Affairs.

STANDARD OPERATING PROCEDURES

MISTREATMENT INVESTIGATION PROCESS FOR OFFICE OF MEDICAL EDUCATION

SOP name/title:

Mistreatment Review Process for Courses

and Clerkships

SOP originator:

Sundip Patel MD

Asst Dean for Curriculum, Phase II

SOP originator:

SOP Approval:

Assoc Dean for

Medical Education

Dean, CMSRU

Effective Date:

October 7, 2020

Signature:

Last Edited Date:

July 25, 2023

When a student files a Mistreatment Report concerning activities pertaining to a Phase I or Phase II course or

clerkship or describes a mistreatment event in a course or clerkship evaluation form, the following process is

followed to review the incident, investigate it, and determine proper resolution.

1. The appropriate Assistant Dean of Phase I or Phase 2 courses or clerkships receives reports of student

mistreatment and conducts the review and investigation, supported by the Senior Associate Dean for Medical

Education (SADME). Reports of mistreatment can initiate from a variety of reporting options including the

anonymous mistreatment system provided by the Office of Student Affairs (OSA), the direct reporting of the

incident to any member of the leadership team at CMSRU or to a course/clerkship director, and via the

course evaluation system established by the Office of Medical Education (OME). (The OSA addresses

mistreatment events outside of the curriculum according to their policies.) The OME addresses all incidents

of student mistreatment related to the educational program.

2. If an allegation of mistreatment involves a CUHC employee or occurred at Cooper University Hospital or a

CUHC ambulatory site, the Dean notifies CUHC leadership, including the Senior Vice President of Human

Resources and the Chief Physician Executive. If a faculty member is involved, the Departmental Chair is

notified; if a resident or fellow is involved, the Program Director and the Designated Institutional Official

(DIO) are notified; and if a nurse is involved, the Chief Nursing Officer is notified.

3. If the allegation of student mistreatment is a Title IX issue, it is directed immediately to the Rowan

University Office of Student Equity and Compliance. If an allegation of student mistreatment is a Title IX

issue and involves a Cooper University Health Care (CUHC) employee, the issue is co-investigated by the

Rowan University Office of Student Equity and Compliance and the CUHC Office of Human Resources.

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4. For incidents within the educational program, the appropriate Assistant Dean, Phase 1 or Phase 2, notifies the

SADME.

5. The SADME reports all incidents of student mistreatment to the CMSRU Dean. After discussion, a

preliminary investigational and action plan is developed. Immediate action is taken if there is a threat to

student safety or well-being.

6. The Assistant Dean of Phase 1 or Phase 2, investigates the mistreatment event, and reports their findings to

the SADME and to the Dean.

7. After discussion with the Dean, and after presentation and discussion at the executive cabinet, the plan may

be revised concerning the actions that need to be taken relative to the mistreatment incident. This plan is

formulated as soon as possible and within ten (10) days of completion of the investigational report.

8. The student (if they supplied their name and were not anonymous) can participate in the investigatory process

and is made aware of the findings of the investigation and actions taken. If the student disagrees with the

final determination of the investigation, the issue is directed to, and investigated by, the Rowan University

Office of Student Equity and Compliance. Unless new information is brought forward, no further

investigation is undertaken once the Rowan University Office of Student Equity and Compliance finalizes its

investigation and conclusions. The OME carries out any required actions/recommendations.

9. Information regarding the case (de-identified) is provided to the Committee for a Positive Learning

Environment in the standing Mistreatment Report that they receive on an ongoing basis.

10. The mistreatment event and actions taken are recorded in the appropriate dashboard.

TIPS FOR CREATING A POSITIVE LEARNING AND WORKING ENVIRONMENT

FOR ALL FACULTY, RESIDENTS, AND FELLOWS

Before each rotation or course, please review the following guidelines:

Set the stage: how medical educators (attending physicians, residents, fellows, etc.) can form a cohesive

team:

• 5-minute orientation to goals, objectives, expectations and the mechanics of the rotation or course.

• Ask learners what they most want to learn.

• Embrace the learners as part of the patient care team.

• Affirm your shared commitment to the primacy of patient care and a positive learning environment.

• Emphasize the ethos of psychological safety.

• Frame the work of the team (crucial work, fraught with uncertainty).

• Admit that we all make mistakes and may need each other’s help.

Provide students with authentic roles: the medical educators should encourage their learners to take an

active role in patient care.

• Students learn best by doing, not by shadowing or taking a back seat.

• Encourage students to know their patients and advocate for their care.

• Students should be helpful by tracking down outside test results and by performing other important

supportive activities.

• Provide adequate space and time to debrief after emergencies and high intensity moments, so

students can learn from them and not feel neglected.

Challenge learners: medical educators should promote an environment of intellectual curiosity while

inspiring learners to apply critical thinking skills to complex patient problems:

• Encourage all team members to ask thought-provoking questions, of anyone, at any time.

• Let learners know you will ask thought-provoking questions to encourage learning.

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• Embrace the messengers: thank those who ask useful questions or bring useful information.

The CMSRU End Mistreatment Task Force determined and compiled a list of mistreatment never behaviors.

The following behaviors represent mistreatment of patients, colleagues, or learners and should never occur.

Never Behaviors

• Never make disparaging comments to or about other professionals.

• Never make disrespectful comments to or about patients, their friends, or family members.

• Never belittle, humiliate, harass, or bully a learner.

• Never subject anyone to physical harm or threat of physical harm.

• Never require learners to perform non-team-centric, non-patient-centric personal services.

• Never require learners to perform tasks intended to punish, belittle, humiliate or control the learner.

• Never subject learners to discriminatory exclusion from learning opportunities, a hostile

learning/working environment, or intentional neglect.

• Never subject learners to offensive, sexist remarks or subject them to unwanted sexual advances

(physical or verbal).

• Never ask anyone to exchange sexual favors for rewards.

• Never engage in an intimate relationship with a learner one is responsible for supervising,

evaluating, mentoring, or coaching.

• Never deny learners opportunities for training or rewards because of gender, age, race, disability,

ethnicity, sexual orientation, or religion.

• Never subject anyone to negative or offensive comments or behaviors because of gender, age, race,

disability, ethnicity, sexual orientation, or religion.

• Never pressure a learner to perform a medical procedure for which they are insufficiently trained or

insufficiently supervised.

• Never subject anyone to inappropriate comments about their appearance.

• Never subject learners to retaliation or threats of retaliation for making a good-faith report of

mistreatment or unprofessional behavior.

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Religious Observance Policy

POLICY:

Religious Observance Policy

PURPOSE:

CMSRU respects the diversity of faiths and spiritual practices in its community and recognizes the right for students

to observe religious holidays.

SCOPE:

This policy applies to all CMSRU medical students and visiting medical students.

DEFINITIONS:

Observance in this policy means a student being absent from a CMSRU class/activity in order to observe a religious

holiday.

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PROCEDURE:

CMSRU recognizes and respects the religious beliefs and practices of its students and seeks to accommodate them

reasonably within the requirements of the academic schedule. As a result, CMSRU will not penalize a student who

must be absent from a class, examination, study, or work requirement for a religious observance. Students who

anticipate being absent because of a religious observance must, as early as possible and in advance of an anticipated

absence of a day, days, or portion of a day, inform their course/clerkship director, preceptor, education coordinator

and Assistant Dean for Student Affairs as soon as possible, but not less than seven days prior to the scheduled day of

observance. CMSRU recognizes that travel intended for religious observances may be required in certain

circumstances. Excused absences for travel related to a religious observance will be evaluated on a case by case

basis by the Assistant Dean for Student Affairs or designee.

Whenever feasible, faculty should avoid scheduling examinations and assignment deadlines on religious holidays. A

student absent from a class because of religious observance shall not be penalized for any class, examination or

assignment deadline missed on that day or days and a reasonable accommodation shall be made. In the event an

examination or assignment deadline is scheduled on a day of religious observance, a student unable to attend class

shall be permitted to make up an examination or to extend any assignment deadline missed. No adverse or

prejudicial effect shall result to any student who takes advantage of the provisions of this policy.

If a student believes they are not being granted the full benefits of the policy and has not been successful resolving

the matter with the course director, the student may confer with the Associate Dean of Student Affairs. For your

convenience, please follow the link to an interfaith calendar of religious holidays.

http://www.interfaith-calendar.org/

Student Sexual Misconduct and Harassment Policy

CMSRU Adheres to the Rowan University Student Sexual Misconduct and Harassment Policy

PURPOSE

Students of the Rowan University community have the right to access and benefit from the University’s educational

and other programs, activities or services, free from any form of Sexual Misconduct. The University does not

tolerate Sexual Misconduct of any kind. This policy has been developed to reaffirm these principles and to provide

recourse for those individuals whose rights have been violated.

APPLICABILITY

This policy applies to all students of Rowan University from the time of their acceptance and admission into the

University until the date of their graduation or formal withdrawal. This policy shall not apply to allegations of

conduct that do not constitute Sexual Misconduct as defined herein. Notwithstanding, such behavior may be

addressed by the University under other policies such as the

Title IX Sexual Harassment/Sexual Assault

Policy, Student Code of Conduct or Procedure for Resolving Student v. Student Discrimination Complaints. In

addition, this policy shall not apply to allegations of Sexual Misconduct against Rowan employees and vendors –

such complaints may be handled under the Policy Prohibiting Discrimination in the Workplace and Educational

Environment, Disruptive Behavior and Workplace Violence Policy or other applicable policy.

INTRODUCTION: This Student Sexual Misconduct and Harassment Policy applies to forms of Sexual Misconduct

as defined herein, when alleged against a student Respondent. Specifically, this policy applies to forms of Sexual

Misconduct that do not fall under the scope of the Title IX Sexual Harassment/Sexual Assault Policy

, including

Sexual Exploitation. This policy also applies to complaints against student Respondents alleging certain conduct that

would otherwise be prohibited under the

Title IX Sexual Harassment/Sexual Assault Policy (e.g., Dating Violence,

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Domestic Violence, Sexual Assault and Stalking), but which must be dismissed under the

Title IX Sexual

Harassment/Sexual Assault Policy because they do not meet the jurisdictional requirements.

The University will respond to Reports or Formal Complaints (as defined below) of conduct prohibited under this

policy with measures designed to stop the prohibited conduct, prevent its recurrence and remediate any adverse

effects of such conduct on campus or in University-related programs or activities.

The University will not deprive an individual of rights guaranteed under federal and state law (or federal and state

anti-discrimination provisions; or federal and state law prohibiting discrimination on the basis of sex) when

responding to any claim of Sexual Misconduct.

Conduct that is prohibited under this policy may also constitute a violation of federal, state or local law and a student

may be charged in the criminal justice system, as well as under this policy. Alternatively, charges can occur for

violations of this policy which may not be in violation(s) of the law. The criminal justice system is different from

this Sexual Misconduct process. The University reserves the right to reach its own determination on violations of

this policy, independently of the outcome of any civil or criminal proceeding. The University retains the right to

hear a Sexual Misconduct matter before, after or during the pendency of a civil or criminal matter related to the

same incident/conduct. If a matter is going through the criminal justice system, and a Report or Formal Complaint

has also been made to the University, the Sexual Misconduct process at the University may proceed normally during

the pendency of the criminal proceedings. As the Sexual Misconduct process is an educational disciplinary process,

the legal rules related to evidence, criminal procedure, civil procedure and administrative procedure do not apply to

this process.

STANDARD

OF EVIDENCE

A finding under this policy will be based on the preponderance of the evidence standard. In other words, a finding

will be made if the evidence as a whole show that it is more likely than not that a violation of the Student Sexual

Misconduct and Harassment Policy occurred. Under this policy, there is a presumption that the Respondent is not

responsible for the alleged conduct until a determination regarding responsibility is made at the conclusion of the

Grievance Process, or the Respondent admits responsibility.

DEFINITIONS/TERMINOLOGY

● Actual Knowledge – Notice of Sexual Misconduct or allegations of Sexual Misconduct made to the

University’s AVP of the Division of Diversity, Equity and Inclusion, Office of Student Equity and

Compliance or any official of the University who has authority to institute corrective measures on behalf of

the University (such as the DEI Investigator, or Dean of Students). This standard is not met when the only

official of the University with Actual Knowledge is also the Respondent. In addition, the mere fact that a third

party who works for the University (such as a Responsible Employee) may become aware of allegations of

Sexual Misconduct, or that such individuals have the ability or obligation to report Sexual Misconduct, or to

inform another about how to report Sexual Misconduct, or having been trained to do so, does not qualify an

individual as one who has authority to institute corrective measures on behalf of the University.

● Complainant - An individual who is alleged to be the victim of conduct that could constitute Sexual

Misconduct, or on whose behalf the AVP of the Division of Diversity, Equity and Inclusion, Office of Student

Equity and Compliance has filed a Formal Compliant.

● Consent – Consent is informed, knowing, voluntarily and freely given permission to engage in mutually

agreed upon sexual activity. The University will apply a reasonable person standard in determining whether or

not consent was given, unless otherwise required by law.

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o The person giving consent must be capable of doing so freely, with the ability to understand

what they are doing and the specific details (who, what, when, where and how) of the sexual

contact to which they are consenting.

o Consent may be given by words or actions, as long as those words or actions create mutually

understandable permission regarding the conditions of sexual activity.

o It is the obligation of the person initiating sexual contact to obtain clear consent for the specific

type of sexual contact sought. A person’s use of alcohol and/or drugs shall not diminish such

person’s responsibility to obtain consent.

o Lack of protest does not constitute consent. Silence or passivity without words or actions that

communicate mutually understandable permission cannot be assumed to convey consent.

o Use of violence, threats, coercion or intimidation invalidates any consent given.

o A verbal “no” even if it may sound indecisive or insincere, constitutes lack of consent.

o Consent for one form of sexual contact does not imply consent to other forms. For example,

consent to oral sex does not imply consent to vaginal/anal sex.

o It is expected that once consent has been established, a person who changes their mind during

the sexual act or sexual contact will communicate through words or overt actions their decision

to no longer proceed.

o Past consent does not constitute consent for future sexual contact/activity.

o Persons who are unable to give valid consent under New Jersey law, (i.e. minors, individuals

with mental health disabilities) are considered unable to give consent under NJ State Policy

N.J.S.A.2C:4-2.

o Consent cannot be given by a person who is unconscious or sleeping. If consent has been given

while a person is conscious or awake, and then that person becomes unconscious or falls asleep,

consent terminates at that point.

o Persons who are incapacitated due to the use of drugs or alcohol cannot give consent.

● Disciplinary sanctions - Disciplinary Sanction(s) shall be imposed upon a Respondent where a

determination of responsibility for Sexual Misconduct has been made against the Respondent. Disciplinary

Sanctions for Respondents may range from a warning to expulsion. Respondents will also be referred to

appropriate authorities for criminal prosecution when appropriate, regardless of any Disciplinary Sanctions

under this policy.

● False report– Intentionally making a report of Sexual Misconduct to a University official, knowing at the

time the report was made, that the prohibited conduct did not occur and the report was false. A determination

regarding responsibility, alone, will not be sufficient to conclude that any party made a materially false report

in bad faith.

● False statement– Intentionally making a statement during the Grievance Process or Appeals Process to a

University official, knowing at the time the statement was made, that it was false. A determination regarding

responsibility, alone, will not be sufficient to conclude that any party or witness made a materially false

statement in bad faith.

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● Formal complaint – A document filed and signed by a Complainant, or signed by the AVP of the Division of

Diversity, Equity and Inclusion, Office of Student Equity and Compliance, alleging Sexual Misconduct

against a Respondent, and requesting that the University investigate the allegations of Sexual Misconduct. The

Formal Complaint should include in detail the nature of the complaint, dates and locations of particular events,

names/contact information of witnesses (if any), the name of the individual(s) against whom the complaint is

being made and any other relevant information. A Report of Sexual Misconduct may be filed with the AVP of

the Division of Diversity, Equity and Inclusion, Office of Student Equity and Compliance in person, by mail,

by electronic mail or by filling out the report form found HERE

. Upon receipt of a Report of possible Sexual

Misconduct, the AVP of the Division of Diversity, Equity and Inclusion, Office of Student Equity and

Compliance, or Designee, will reach out the Complainant to discuss the Complainant’s options, including the

ability to file a Formal Complaint.

● Incapacitation – The physical and/or mental inability to make informed, rational judgements and decisions.

States of incapacitation include sleep, unconsciousness and blackouts.

o Where alcohol or drugs are involved, incapacitation is determined by how the substance impacts a

person’s decision-making capacity, awareness of consequences and ability to make informed

judgements. In evaluating whether a person was incapacitated for purposes of evaluating effective

Consent, the University considers two questions:

▪ Did the person initiating sexual activity know that their partner was incapacitated?

▪ Should a sober, reasonable person in the same situation have known that their partner was

incapacitated?

If the answer to either of these questions is “yes,” effective Consent was absent.

o For purposes of this policy, incapacitation is a state beyond drunkenness or intoxication. A person is

not incapacitated merely because they have been drinking or using drugs. The standard for

incapacitation does not turn on technical or medical definitions, but instead focuses on whether a

person has the physical and/or mental ability to make informed, rational judgments and decisions.

o A person who initiates sexual activity must look for the common and obvious warning signs that show

that a person may be incapacitated or approaching incapacitation. Although every individual may

manifest signs of incapacitation differently, typical signs include slurred or incomprehensible speech,

unsteady gait, combativeness, emotional volatility, vomiting or incontinence. A person who is

incapacitated may not be able to understand some or all of the following questions: “Do you know

where you are?” “Do you know how you got here?,” “Do you know what is happening?” or “Do you

know whom you are with?”

o Because the impact of alcohol and other drugs varies from person to person, one should be cautious

before engaging in sexual contact or intercourse when either party has been drinking alcohol or using

drugs. The introduction of alcohol or other drugs may create ambiguity for either party as to whether

effective Consent has been sought or given. If one has doubt about either party’s level of intoxication,

the safe thing to do is to forgo all sexual activity.

● Remedies - Remedies may be provided to a Complainant where a determination of responsibility for Sexual

Misconduct has been made against the Respondent. Remedies are designed to restore or preserve the

Complainant’s equal access to the University’s education program or activity. Remedies may include the same

individualized services described in the Supportive/Interim Measures section below; however, unlike

Supportive/Interim Measures, Remedies need not be non-disciplinary or non-punitive, and need not avoid

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burdening the Respondent. Remedies provided may include, but not be limited to, a one-way no contact

directive; changes to housing/work arrangements; or a leave of absence.

● Report - Anyone may file a Report alleging an incident of Sexual Misconduct of which they become

aware. The Report should include as much information possible, such as details (if known) of the nature of

the incident, dates of particular events, names/contact information of any Complainant, Respondent, witnesses

(if any), and any other relevant information. A Report may be filed with the AVP of the Division of Diversity,

Equity and Inclusion, Office of Student Equity and Compliance, in person, by mail, by electronic mail or by

filling out the report form found HERE

● Respondent – An individual who has been reported to be the perpetrator of conduct that could constitute

Sexual Misconduct.

● Responsible employees – Certain employees, who under this policy, are required, after receiving information

regarding Sexual Misconduct, to report it to the AVP of the Division of Diversity, Equity and Inclusion,

Office of Student Equity and Compliance. These employees include, but are not limited to, Public Safety

Police and Security Officers, managers and supervisors, coaches, club and organization advisors, faculty,

Deans and Residential Learning staff (Resident Assistants, Community Safety Assistants, Resident Directors

and Residential Learning Coordinators). Notwithstanding, knowledge of an incident of Sexual Misconduct by

a Responsible Employee (other than those who also have authority to institute corrective measures on behalf

of the University) does not constitute Actual Knowledge by the University.

● Sanctions – See Disciplinary Sanctions.

● Supportive/interim measures – See Section X below.

PROHIBITED

CONDUCT

This policy addresses allegations of Sexual Misconduct, against student Respondents, that occur on the basis of sex

that do not fall within the definitional or jurisdictional requirements of the federal regulations underlying the

Title

IX Sexual Harassment/Sexual Assault Policy. To the extent allegations of inappropriate behavior/misconduct against

a student may not be covered by this policy or the Title IX Sexual Harassment/Sexual Assault Policy, they may still

be addressed under the

Student Code of Conduct, Procedure for Resolving Student v. Student Discrimination

Complaints or other applicable policy/procedure. Allegations against employees that do not fall under the Title IX

Sexual Harassment/Sexual Assault Policy, may be addressed under the Policy Prohibiting Discrimination in the

Workplace and Educational Environment, Disruptive Behavior and Workplace Violence Policy or other applicable

policy.

Examples of prohibited conduct under this policy, when alleged against a student, may include conduct: (i) that

occurs in the local vicinity (i.e., local restaurant) but outside a University program or activity; (ii) occurs outside the

United States when the conduct is associated with a University-sponsored program or activity; or (iii) conduct that

involves the University’s computing and network resources from a remote location, including but not limited to

accessing email accounts.

Prohibited conduct (referred to collectively as “Sexual Misconduct” throughout the policy) is the following

behaviors if they fall outside the jurisdictional requirements of the Title IX Sexual Harassment/Sexual Assault

Policy.

● Sexual harassment – Unwelcome sexual or gender based verbal or physical behavior, through any medium,

determined by a reasonable person to be so severe, pervasive and objectively offensive that it effectively

denies a person of equal access to the University’s education program or activity.

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● Sexual assault – Any sexual act directed against another person, without their consent or where they are

incapable of giving consent. An offense that meets the definition of rape, fondling, incest or statutory rape:

o Rape: The penetration, no matter how slight, of the vagina or anus with any body part or object,

or oral penetration by a sex organ of another person, without the consent of the victim.

o Fondling: The touching of the private body parts of another person for the purpose of sexual

gratification, without the consent of the victim, including instances where the victim is

incapable of giving consent because of his/her age or because of his/her temporary or permanent

mental incapacity.

o Incest: Sexual intercourse between persons who are related to each other within the degrees

wherein marriage is prohibited by law.

o Statutory Rape: Sexual intercourse with a person who is under the statutory age of consent.

● Stalking – Engaging in a course of conduct, through any medium, directed at a specific person that would

cause a reasonable person to: (a) fear for the person's own safety or the safety of others; or (b) suffer

substantial emotional distress. For the purposes of this definition:

o Course of conduct means two or more acts, including, but not limited to, acts in which the

stalker directly, indirectly or through third parties, by any action, method, device or means,

follows, monitors, observes, surveils, threatens or communicates to or about a person, or

interferes with a person's property;

o Reasonable person means a reasonable person under similar circumstances and with similar

identities to the Complainant;

o Substantial emotional distress means significant mental suffering or anguish that may, but does

not necessarily, require medical or other professional treatment or counseling.

● Dating violence – Violence committed by a person who is or has been in a social relationship of a romantic or

intimate nature with another person. The existence of such a relationship shall be determined based on a

consideration of the following factors: (a) the length of the relationship; (b) the type of relationship; and (c)

the frequency of interaction between the persons involved in the relationship.

● Domestic violence – A felony or misdemeanor crime of violence committed by: (a) a current or former spouse

or intimate partner; (b) a person with whom an individual shares a child in common; (c) a person who is

cohabitating with, or has cohabitated with, the other person as a spouse or intimate partner; (d) a person

similarly situated to a spouse of the other person under the domestic or family violence laws in which the

crime of violence occurred; or (e) any other person against an adult or youth who is protected from that

person's acts under the domestic or family violence laws of the jurisdiction in which the crime of violence

occurred.

In addition, prohibited conduct (Sexual Misconduct), shall include the following conduct which would not otherwise

fall under the Title IX Sexual Harassment/Sexual Assault Policy:

● Sexual exploitation – Any act whereby one individual violates the sexual privacy of another or takes unjust or

abusive sexual advantage of another who has not provided consent, and that does not constitute non-

consensual sexual penetration or non-consensual sexual contact. Examples may include: prostituting another

person; recording, photographing, transmitting, viewing or distributing intimate or sexual images or sexual

information without the knowledge and consent of all parties involved; voyeurism (i.e., spying on others who

are in intimate or sexual situations); allowing third parties to observe private sexual activity from a hidden

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location (e.g., closet) or through electronic means (e.g., Skype or live-streaming of images); or knowingly

transmitting a sexually transmitted infection to another person without the other’s knowledge.

REPORTING

OPTIONS – HOW TO FILE A REPORT/COMPLAINT

Students who have experienced Sexual Misconduct and those who have knowledge of Sexual Misconduct are

strongly encouraged to report this information as soon as possible. Prompt reporting of incidents greatly improves

the ability of the University and law enforcement to provide support resources to students and to address the

violations effectively. Although there is no time limit for reporting Sexual Misconduct, delays in reporting may

reduce the ability of the University and law enforcement to investigate and respond to incidents. After an incident

of Sexual Misconduct, the student should consider seeking medical attention as soon as possible. In New Jersey,

evidence may be collected even if you chose not to make a report to law enforcement.

It is a violation of this policy for anyone to make a False Report of Sexual Misconduct, or for anyone to make a

False Statement. Disciplinary Sanctions may be imposed for intentionally making a False Report or False Statement.

EPORTING TO LAW ENFORCEMENT

● Where criminal behavior is involved, the University encourages, and will assist students with,

reporting to law enforcement. However, students have the right to decline notifying law

enforcement. For criminal offenses that occur on the University campus, students should

immediately contact Rowan Public Safety, 856-256-4911. Rowan Public Safety can assist students

in contacting and filing a report/complaint with any other agency when the incident did not occur on

campus.

o Glassboro campus – Glassboro Police Department, 1 South Main Street, Glassboro, NJ 856-

881-1500; http://www.glassboropd.org/

o Camden campuses – Camden County Metro Police, 800 Federal Street, Camden, NJ 856-757-

7440; http://camdencountypd.org/

o RowanSOM campus – Stratford Police Department, 315 Union Ave., Stratford, NJ 856-783-

8616; https://som.rowan.edu/oursom/campus/safety.html

● LGBTQIA+ (Lesbian, Gay, Bisexual, Transgender, Queer/Questioning, Intersex or

Agender/Asexual) students should know that every Rowan Public Safety Officer will assist them

should they choose to report Sexual Misconduct. However, if an LGBTQIA+ student would prefer,

they can ask to speak directly with the Rowan University LGBTQIA+ police liaison.

● Behavior that constitutes a violation of this policy may also be a crime under the laws of the State of

New Jersey.

EPORTING TO THE UNIVERSITY

● A student may choose to report an incident of Sexual Misconduct to the University before they have

made a decision about whether or not to report to law enforcement. A student has the right to file a

criminal complaint and a Formal Complaint simultaneously.

● Once a Report of Sexual Misconduct has been received, whether or not a Formal Complaint has

been filed, the University will provide written notification to the Complainant about existing

counseling, health, mental health, student advocacy, legal assistance, visa and immigration

assistance, student financial aid and other services that are available at Rowan and in the

surrounding communities. For more information on these services please visit OSEC’s website

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● Reports of incidents alleging to involve Sexual Misconduct or sex discrimination in a University

program or activity should be made to the AVP of the Division of Diversity, Equity and Inclusion,

Office of Student Equity and Compliance in person, by mail, by electronic mail or by filling out the

report found HERE.

AVP of the Division of Diversity, Equity and Inclusion

Office of Student Equity and Compliance

Monise Princilus, Ed.S.

Associate Vice President and Title IX Coordinator of the Division of Diversity, Equity and Inclusion, Office

of Student Equity and Compliance

203 Savitz Hall

856-256-5440

[email protected]

In addition, prior to filing a Report or Formal Complaint, a person may reach out to the following individuals to

discuss their reporting options. The below individuals are Responsible Employees under this policy and,

therefore, should report the incident to the AVP of the Division of Diversity, Equity and Inclusion, Office of

Student Equity and Compliance. However, their knowledge of any incident does not constitute Actual

Knowledge by the University. Thus, if a student wishes to ensure a Report/Formal Complaint has been made,

the individual should also reach out to the AVP of the Division of Diversity, Equity and Inclusion, Office of

Student Equity and Compliance.

Athletics / LGBTQIA+

Penny Kempf, Associate Athletic Director

Athletics Office, Esby Gym

856-256-4679,

kempf@rowan.edu

Cooper Medical School of Rowan University

Dr. Marion Lombardi, Assistant Dean for Student Affairs

Room 409B, CMSRU Medical Education Building, Camden, NJ

856-361-2805,

lombardi[email protected]

Rowan University School of Osteopathic Medicine

Dr. Paula Watkins, Director of Enrollment Services

Suite 210 Academic Center, One Medical Center Drive, Stratford, NJ

856-566-7050,

fennerpa@rowan.edu

Graduate School of Biomedical Sciences

Dr. Diane Worrad, Director

42 East Laurel Road, UDP, Suite 2200, Stratford, NJ

856-566-6282,

worrad@rowan.edu

Graduate Medical Education

Sheila Seddon, Assistant Director

Academic Center Stratford, NJ

856-566-2742,

seddonsm@rowan.edu

POLICY OF IMMUNITY

The University will grant immunity for using alcohol and drugs to both a Complainant and/or Respondent, unless

the alcohol or drug was used knowingly to perpetrate violence. No one should be fearful of obtaining resources or

remedies from a violent crime because they were intoxicated. In addition, the University will not pursue disciplinary

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action for drug or alcohol violations, or most other violations of the Student Code of Conduct, against a party or

witness who comes forward in good faith to Report Sexual Misconduct. See

Rowan University Good Samaritan

Policy

OTHER REPORTING OPTIONS

Student may also file a complaint with the U.S. Department of Education, Office of Civil Rights.

Office of Civil Rights, U.S. Department of Education

New Jersey, New York, Puerto Rico, Virgin Islands OCR

New York Office, U. S. Department of Education

32 Old Slip, 26th Floor

New York, NY 10005-2500

Telephone: (646) 428-3800

Facsimile: (646) 428-3843

Email:

OCR.NewYor[email protected]

CONFIDENTIALITY

When the University is made aware of a report or allegation of Sexual Misconduct, the University will endeavor to

maintain the confidentiality of the matter and of all individuals involved to the extent permitted by law. The

University will balance the needs of the individuals involved (Complainant and Respondent) with its obligation to

fully investigate allegations and to protect the safety and wellbeing of the community at large. In all cases, the

University and its employees will respect the dignity and rights of all individuals involved.

● Responsible Employees: When consulting campus resources, students should be aware that certain

employees are Responsible Employees who, under this policy, are required, after receiving information

regarding Sexual Misconduct, to report it to the AVP of the Division of Diversity, Equity and Inclusion,

Office of Student Equity and Compliance. These include, but are not limited to, Public Safety Police and

Security Officers, managers and supervisors, coaches, club and organization advisors, faculty, Deans, and

Residential Learning staff (Resident Assistants, Community Safety Assistants, Resident Directors, and

Residential Learning Coordinators). Knowledge of an incident of Sexual Misconduct by a Responsible

Employee (other than those who also have authority to institute corrective measures on behalf of the

University) does not constitute Actual Knowledge by the University.|

If an individual has reported information to a Responsible Employee, but the individual would like for the

report to remain confidential, the student should contact the AVP of the Division of Diversity, Equity and

Inclusion, Office of Student Equity and Compliance, who will evaluate the individual’s request for

confidentiality. The Grievance Process will only be initiated when a Formal Complaint has been filed with or

by the AVP of the Division of Diversity, Equity and Inclusion, Office of Student Equity and Compliance.

● Confidential Resources: Students who desire that details of an incident be kept confidential can receive

confidential services through the Counseling & Psychological Services Center (856-256-4333), which is

located in the Wellness Center at Winans Hall. Counselors with specialized training are available to support

students who report Sexual Misconduct. Counselors are available to help you free of charge, and can be seen

on an emergency basis. The Student Health Center (856-256-4222) can also provide confidential consultation

with students and may offer treatment to prevent sexually transmitted infections or pregnancy. In

circumstances where the Health Center is unable to offer these services, they will provide a referral to an

appropriate medical resource. In addition, you may speak with members of the clergy, who will also keep

reports made to them confidential. LGBTQIA+ students who would like to speak with a confidential resource

should know that every counselor at the Wellness Center is committed to supporting students of all gender

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identities, gender expressions, and sexual orientations. When speaking with these resources, a student’s right

to confidentiality is legally protected. However, there are limits to this protection in specific situations. For

example, if a student discloses that the incident involved the use of a weapon or other contraband as defined

by New Jersey law, or there is an ongoing threat or danger to the safety of another person (particularly

children or the elderly), these resources may be required to report the incident to police.

● Federal Statistical Reporting and Federal Timely Warning Obligations: Certain campus officials have a

duty to report Sexual Misconduct for federal statistical reporting purposes. All personally identifiable

information is kept confidential, but statistical information must be passed along to campus law enforcement

regarding the type of incident and its general location (on or off-campus, in the surrounding area, etc. – with

addresses withheld), for publication in the annual Campus Security Report. This report helps to provide the

community with a clear picture of the extent and nature of campus crime to ensure greater community safety.

Individuals who report Sexual Misconduct should also be aware that University administrators may be

required to issue timely warnings for certain incidents reported to them that pose a substantial threat of bodily

harm or danger to members of the community, to aid in the prevention of similar occurrences. The University

will withhold the names and other personally identifiable information of individuals as confidential, while still

providing enough information for community members to make decisions related to their safety in light of the

danger.

SUPPORTIVE/INTERIM

MEASURES

Non-disciplinary, non-punitive individualized services will be offered to the Complainant and/or Respondent, as

appropriate and as reasonably available, without fee or charge, where no Formal Complaint has been filed, or before

or after the filing of a Formal Complaint. Such measures are designed to restore or preserve equal access to the

University’s education program or activity without unreasonably burdening the other party, including measures

designed to protect the safety of all parties, the University’s educational environment and/or to deter Sexual

Misconduct.

Supportive/Interim Measures may include, but are not limited to, the provision of information related to counseling,

academic support, mental health services; extensions of deadlines or other course-related adjustments; modifications

of work or class schedules; campus escort services; mutual restrictions on contact between the parties (no contact

directives); changes in work or housing locations; leaves of absence; increased security; and other similar measures.

In addition, the University may place a student on an Interim Suspension, pending the outcome of the Grievance

Process. This decision will be made in accordance with the University’s Student Code of Conduct

The University will maintain as confidential any Supportive/Interim Measures provided to the Complainant or

Respondent, to the extent that maintaining such confidentiality would not impair the University’s ability to provide

the Supportive/Interim Measure(s).

ADVISORS

A Complainant and Respondent each have the right to an Advisor of their choice during the Grievance Process

(discussed below). An Advisor may be a family member, a friend, an attorney or any third party (i.e., a trusted

employee). However, an Advisor may not otherwise be involved in the Grievance Process (i.e., a witness, co-

Complainant or co-Respondent). Advisors are present to support the parties and to provide advice on procedural

matters, but may not speak on behalf of the party.

Advisors must adhere to all conditions and obligations under this policy and as required by the University’s process.

The Advisor has the right to accompany the Complainant or Respondent to any meetings with the AVP of the

Division of Diversity, Equity and Inclusion, Office of Student Equity and Compliance, DEI Investigator (or their

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Designee) or University administrators, and the party has the right to communicate with their Advisor during any

meeting. The Advisor may also assist the Complainant or Respondent during the investigation, preparing/submitting

a response to the investigation report, attend the live hearing or assist with the filing of an appeal.

The Advisor does not have speaking privileges during the investigation/investigatory interviews. The AVP of the

Division of Diversity, Equity and Inclusion, Office of Student Equity and Compliance or designee will exercise

control over the investigation. Anyone who disrupts an investigatory interview or who fails to adhere to University

policies may be asked to leave an investigatory interview.

With respect to the Hearing, an Advisor may attend the Hearing, but may not actively participate in the Hearing.

Regardless of whether a party has an Advisor, the AVP of the Division of Diversity, Equity and Inclusion, Office of

Student Equity and Compliance, DEI Investigator or Designee will correspond and communicate directly with the

parties. If a party wishes for their Advisor to be copied on any correspondence or communications, the party should

advise the AVP of the Division of Diversity, Equity and Inclusion, Office of Student Equity and Compliance or DEI

Investigator.

GRIEVANCE

PROCESS/PROCEDURES

Upon receipt of a Report of Sexual Misconduct, the AVP of the Division of Diversity, Equity and Inclusion, Office

of Student Equity and Compliance or Designee, will contact the Complainant to: (i) discuss available

Supportive/Interim Measures while taking into consideration the Complainant’s wishes; (ii) inform the Complainant

that the Supportive/Interim Measures are available with or without a Formal Complaint; and (iii) explain the process

for filing of a Formal Complaint.

Upon receipt of a Formal Complaint, the University will initiate the Grievance Process.

The University will treat Complainants and Respondents equitably by providing Remedies to a Complainant where a

determination of responsibility for Sexual Misconduct has been made against the Respondent, and by following the

Grievance Process before the imposition of any Disciplinary Sanctions or other actions, that are not

Supportive/Interim Measures, are taken against a Respondent.

Throughout the Grievance Process, there will be an objective evaluation of all relevant evidence, including both

inculpatory (evidence implying or imputing responsibility) and exculpatory (evidence exonerating responsibility)

evidence. In addition, credibility determinations will not be based on an individual’s status as a Complainant,

Respondent or witness.

Individuals involved in the Grievance Process (AVP of the Division of Diversity, Equity and Inclusion, Office of

Student Equity and Compliance, investigator, decision-maker or any person designated by the University to

facilitate an informal resolution process) shall not have a conflict of interest or bias for or against Complainants or

Respondents generally, or an individual Complainant or Respondent. Such individuals shall also have the

appropriate training as set forth in the Training Section of this policy.

It is presumed that a Respondent is not responsible for the alleged conduct until a determination regarding

responsibility is made at the conclusion of the Grievance Process, or if a Respondent admits responsibility.

It is a violation of this policy for anyone to make a False Report of Sexual Misconduct, or for anyone to make a

False Statement during the Grievance Process. Disciplinary Sanctions may be imposed for intentionally making a

False Report or False Statement.

● Dismissal of a Formal Complaint

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o The AVP of the Division of Diversity, Equity and Inclusion, Office of Student Equity and Compliance

must dismiss the Formal Complaint, or allegations therein, at any time, if it is determined that the

conduct alleged would not constitute Sexual Misconduct, even if proved. Such a dismissal does not

preclude the University from taking action under another provision of the University’s policies.

o The AVP of the Division of Diversity, Equity and Inclusion, Office of Student Equity and Compliance,

in his/her discretion, may also dismiss the Formal Complaint, or allegations therein, if at any time during

the Grievance Process, the following occurs: (1) the Complainant notifies the AVP of the Division of

Diversity, Equity and Inclusion, Office of Student Equity and Compliance, in writing that the

Complainant would like to withdraw the Formal Complaint, or any allegations therein; (ii) the

Respondent is no longer enrolled by the University; or (iii) specific circumstances prevent the University

from gathering evidence sufficient to reach a determination as to the Formal Complaint or allegations

therein.

o Written notice of any required or permitted dismissal, including any reason(s) therefore, shall be

promptly sent to the parties simultaneously. This notice will also advise the parties of their appeal rights

in accordance with this policy.

● Consolidation of Formal Complaints – Formal Complaints as to allegations of Sexual Misconduct against

more than one Respondent, or by more than one Complainant against one or more Respondents, or by one

party against the other party, may be consolidated where the allegations of Sexual Misconduct arise out of the

same facts or circumstances.

● Notice of Allegations – Upon receipt of a Formal Complaint, the AVP of the Division of Diversity, Equity

and Inclusion, Office of Student Equity and Compliance, or Designee, will provide written notice to the

known parties, which includes:

o A link to the University’s Student Sexual Misconduct and Harassment Policy, so the parties can review

the University’s Grievance Process, including the Informal Resolution Process;

o Sufficient detail, of what is known at the time, related to the allegations of Sexual Misconduct, including

details such as the identities of the parties involved, the conduct allegedly constituting Sexual

Misconduct, and the date(s) and location(s) of the alleged incident(s);

o A statement that the Respondent is presumed not responsible for the alleged conduct, and that a

determination regarding responsibility will be made at the conclusion of the Grievance Process;

o Information that the parties may have an Advisor of their choice, who may be, but is not required to be,

an attorney;

o A statement that the parties and their Advisors will have the right to inspect and review evidence during

the investigation of a Formal Complaint; and

o Reference to the provisions within the Student Sexual Misconduct and Harassment Policy that prohibits

knowingly making False Reports or False Statements.

Such notice will be provided to the parties within a reasonable period of time prior to conducting any

investigatory interview, so that the parties have time to prepare and meaningfully respond.

If, in the course of an investigation, the University decides to investigate allegations about the Complainant

or Respondent that were not included in the initial notice, the University will provide notice of the additional

allegations to be investigated, to the known parties.

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ORMAL RESOLUTION PROCESS

● Written Notice of Meetings, Interviews, Hearings – Written notice of the date, time, location, participants

and purpose of all investigative interviews, hearings, or any other meetings, will be provided to any party

whose participation is invited or expected, with sufficient time for the party to prepare to participate.

● Investigation of a Formal Complaint – After notification of the allegations in the Formal Complaint has

been sent, the DEI Investigator, or Designee, will promptly initiate an investigation within seven (7) calendar

days. The investigation shall be completed in a reasonably prompt manner and should be completed within

ninety (90) calendar days from the time the Formal Complaint is filed.

o The investigation will include interviews of the Complainant(s), Respondent(s) and any

witnesses/individuals believed to have information relevant to the allegations, as well as the collection

of any relevant evidence.

o Each party is permitted to have their Advisor present during any investigatory interview, or other

meeting. However, while the party has the right to communicate with their Advisor during any meeting,

the Advisor does not have speaking privileges during the investigation/investigatory interviews.

o The investigator will not access, consider, disclose, or otherwise use a party’s records that are made or

maintained by a physician, psychiatrist, psychologist or other recognized professional/paraprofessional

acting in the professional/paraprofessional’s capacity, or assisting in that capacity, and which are made

and maintained in connection with the provision of treatment to the party, unless the investigator obtains

that party’s voluntary, written consent to do so for a Grievance Process.

o The parties and their Advisors are not restricted from discussing the allegations under investigation for

the purpose of gathering and presenting evidence to the investigator.

o During the investigation, the parties will be provided the opportunity to present witnesses, including fact

and expert witnesses, and other inculpatory (evidence implying or imputing responsibility) and

exculpatory (evidence exonerating responsibility) evidence.

● Investigation Report – The DEI Investigator or Designee will prepare an Investigation Report that fairly

summarizes relevant evidence and preliminary findings of fact.

o An initial Investigation Report, along with all of the evidence gathered by the investigator (any evidence

obtained as part of the investigation, that is related to the allegations in the Formal Complaint, including

information that will not be relied upon in reaching a determination and without regard to the source of

the information), will be shared with the parties and their Advisors (if any) simultaneously. Names and

other identifying information of individuals in the report/evidence may be redacted if required by the

Family Educational Rights and Privacy Act ("FERPA"). The parties and their Advisors must keep the

evidence confidential and not share it with anyone, except for the purpose of gathering and presenting

relevant evidence to provide to the investigator within the 10-day period. Failure to abide by this

confidentiality obligation may subject a party or Advisor to disciplinary action by the University.

o Each party may respond to the investigator in writing, within ten (10) calendar days of receipt of the

initial report/evidence.

o After reviewing any timely submitted responses by the parties, within fourteen (14) calendar days, the

investigator will prepare a final Investigation Report. The final Investigation Report will fairly

summarize the relevant evidence and findings of fact.

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o The parties and their Advisors (if any) will be simultaneously provided with an electronic or hard copy

of the final Investigation Report. A copy of the final Investigation Report will also be forwarded at the

same time to the Office of Community Standards, for the scheduling of a Hearing.

● Hearing – A Hearing should be scheduled by the Office of Community Standards no later than thirty (30)

calendar days after receipt of the final Investigation Report.

o Each party may have one Advisor attend the Hearing. While a party may communicate with their

Advisor, the Advisor may not actively participate in the Hearing. Prior to the scheduled Hearing, each

party will be asked to identify their Advisor, if any, who will be present for the Hearing.

o Prior to the scheduled Hearing, the parties will be provided an opportunity to make a request for

witnesses to participate in the Hearing on their behalf. The parties must notify the AVP of Civic

Involvement, or Designee, of any witnesses at least seven (7) calendar days prior to the Hearing. The

parties will also be advised of potential Hearing panelists and be provided the opportunity to object to a

panelist based on a conflict of interest.

o If the matter to be heard had originally attempted, but was unsuccessful at, the Informal Resolution

Process, any information related to the Informal Resolution Process will not be admissible during the

Hearing. In addition, the individual who facilitated the Informal Resolution Process may not be called as

a witness at the Hearing.

o A matter will be heard by a Hearing Panel consisting of three (3) voting members, one of whom will be

the Hearing Chair. The Hearing Chair will exercise control over the manner in which the Hearing is

conducted, including being responsible for managing the questioning process. The decisions regarding

responsibility and any Disciplinary Sanctions, if applicable, will be determined by a majority vote.

o Hearings may be conducted with all parties physically present in the same geographic location or, at the

University’s discretion, any or all parties, witnesses and other participants may appear at the Hearing

virtually, with technology enabling participants simultaneously to see and hear each other. For Hearings

occurring in-person, at the request of a party, the University will provide for the Hearing to occur with

the parties located in separate rooms with technology enabling the Hearing Panel, parties and their

Advisors to simultaneously see and hear the party or the witness answering questions.

o Both/all parties shall be permitted to be present during testimony of all witnesses and presentation of the

evidence throughout the Hearing.

o Hearing Panel members will be provided access to the final Investigation Report and evidence at least

twenty-four (24) hours prior to the Hearing. However, while the Hearing Panel members may consider

the final Investigation Report as evidence, the Hearing Panel will function as an independent

adjudicating body and will not be bound by any findings made by the investigator.

o At the beginning of the Hearing, the Hearing Chair, along with the other members of the Hearing Panel,

will enter their names into the recording. The parties and their Advisors (if applicable) will also enter

their names into the recording.

o The Hearing Chair will ask if the Respondent has received the original notice of allegation(s) letter and

understands the nature of the charges.

o The Hearing Chair will then confirm that the Hearing Panel members and the parties have received

copies of the Formal Complaint, notice of allegation(s) letter, list of witnesses, along with the final

Investigation Report.

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o The remainder of the Hearing will customarily proceed in the following order:

▪ Opening statement from the Complainant;

▪ Opening statement from the Respondent;

▪ Questioning of the investigator;

▪ Questioning of Complainant;

▪ Questioning of Respondent;

▪ Questioning of witnesses – each witness will be called one at a time, questioned separately

and dismissed at the conclusion of their testimony;

▪ Final questions of the Complainant(s)/Respondent(s) from the Hearing Panel;

▪ Respondent’s final statement; and

▪ Complainant's final statement.

o Each party will have the opportunity to cross examine the other party (and relevant witnesses, if any) by

submitting cross-examination questions to the Hearing Chair for consideration. Only relevant cross-

examination questions may be asked of a party or witness. The Hearing Chair has the sole discretion to

determine what questions are relevant.

o Questions and evidence about the Complainant's sexual predisposition or prior sexual behavior are not

relevant, unless such questions and evidence: (1) are offered to prove that someone other than the

Respondent committed the conduct alleged by the Complainant; or (2) concern specific incidents of the

Complainant's prior sexual behavior with respect to the Respondent, and are offered to prove Consent.

o The presentation of evidence by a party (including opening statements), cross-examination questions

proposed, and final statements may be constrained to specified time periods when cumulative or as

otherwise deemed appropriate by the Hearing Chair.

o The Hearing Panel may not draw an inference about the determination regarding responsibility based

solely on a party or witness's absence from the Hearing, or refusal to answer cross-examination or other

questions.

o Formal rules of evidence that are applicable to civil and criminal trials are not applicable to the Hearing.

o All Hearings will be closed to the public, and the only individuals who are permitted to attend are the

Complainant(s), Respondent(s), their Advisors, the Hearing Panel and any witnesses called to provide

testimony. In addition, University administrators (i.e., legal counsel) may also attend the Hearing with

prior approval from the Hearing Chair.

o All Hearings will be audio and/or video recorded. Upon request, a digital file will be made available to

the parties for inspection and review.

● Written Determination Regarding Responsibility/Disciplinary Sanctions – Within fourteen (14) calendar

days following the Hearing, the decision-maker(s) will issue a written determination regarding responsibility,

Disciplinary Sanctions and/or Remedies (if applicable).

o If a Respondent has a record of prior disciplinary violations by the University, unless otherwise

permissible, this information will not be considered by the Hearing Panel until after a determination of

responsibility has been made, to assist the Hearing Panel in determining appropriate Disciplinary

Sanctions.

o The written determination will include:

▪ A summary of the allegations of Sexual Misconduct;

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▪ A description of the procedural steps taken from the receipt of the Formal Complaint

through the determination, including any notices to the parties, interviews with parties and

witnesses, site visits, methods used to gather other evidence, evidence considered and

hearings held;

▪ Findings of fact supporting the determination;

▪ Conclusions regarding the application of the University’s Student Sexual Misconduct and

Harassment Policy to the facts;

▪ A statement of, and rationale for, the result as to each allegation, including a determination

regarding responsibility, any Disciplinary Sanction(s) the University will impose on the

Respondent, and whether Remedies designed to restore or preserve equal access to the

University’s education programs or activities will be provided by the University to the

Complainant; and

▪ Information regarding the University’s process and permissible bases for the Complainant

and Respondent to appeal.

o The University will provide the written determination to the parties simultaneously.

o The determination regarding responsibility becomes final either on the date that the University provides

the parties with the written determination of the result of an appeal, if any appeal is filed; or if an appeal

is not filed, the date on which an appeal would no longer be considered timely.

NFORMAL RESOLUTION PROCESS

At any point after a Formal Complaint has been filed, but before a determination of responsibility has been made,

the University offers the opportunity for the parties to take part in an Informal Resolution Process, as an alternative

to the Formal Resolution Process.

Informal Resolution is an opportunity for the parties to settle their matter, without going through the entire Formal

Resolution Process, and without a finding by the University related to responsibility. The University will not pursue

disciplinary action against a Respondent during the Informal Resolution Process. And, if the parties seek an

Informal Resolution after an investigation has already begun, the investigation will be suspended, pending the

outcome of the Informal Resolution.

Any party interested in pursuing an Informal Resolution should advise the AVP of the Division of Diversity, Equity

and Inclusion, Office of Student Equity and Compliance. Engagement in the Informal Resolution Process is

completely voluntary, and each party must provide their written consent prior to beginning the process. If both/all

parties do not agree to the Informal Resolution Process, the Formal Complaint will be addressed through the Formal

Resolution Process. Most matters will be eligible for the Informal Resolution Process; however, the AVP of the

Division of Diversity, Equity and Inclusion, Office of Student Equity and Compliance, in his/her discretion, may

determine, based on the allegations in the Formal Complaint, that a matter is not appropriate for Informal

Resolution.

The Informal Resolution Process will be facilitated by the AVP of the Division of Diversity, Equity and Inclusion,

Office of Student Equity and Compliance or Designee. The Informal Resolution Process will be initiated within ten

(10) calendar days of the receipt of the written consent of both/all parties. The AVP of the Division of Diversity,

Equity and Inclusion, Office of Student Equity and Compliance, or Designee, will work with the parties to complete

the Informal Resolution Process within thirty (30) days.

Prior to engaging in the Informal Resolution Process, the parties will receive written notice providing the following

information: (i) disclosure of the allegations, (ii) the requirements of the informal resolution process, including the

circumstances under which it precludes the parties from resuming a Formal Complaint arising from the same

allegations; (iii) notice that prior to agreeing to a resolution, any party has the right to withdraw from the Informal

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Resolution Process and resume the Formal Resolution Process; and (iv) the consequences resulting from

participating in the Informal Resolution Process, including the records that will be maintained or could be shared.

If the parties reach an Informal Resolution of a Formal Complaint, an agreement that outlines the terms agreed upon

by the parties will be prepared and signed by all parties. Each/all parties will be provided with a copy of the signed

agreement, and the University will retain a copy in accordance with applicable law and its recordkeeping

requirements. Agreements reached via the Informal Resolution Process shall be final and cannot be appealed. Any

agreement reached through the Informal Resolution Process will provide that a student’s failure to comply with the

terms of the signed agreement may result in disciplinary action in accordance with the Student Code of Conduct.

If the Informal Resolution Process is unsuccessful, or a party requests to end the process before a resolution is

reached, or if at any time the AVP of the Division of Diversity, Equity and Inclusion, Office of Student Equity and

Compliance, or Designee, determines an Informal Resolution is no longer appropriate, the matter will be addressed

through the Formal Resolution Process.

If a matter is unsuccessful in reaching an informal resolution, and is to be addressed through the Formal Resolution

Process, any information related to the Informal Resolution Process will not be admissible during a Hearing. In

addition, the individual who facilitated the Informal Resolution Process may not be called as a witness at a Hearing.

APPEALS

PROCESS

Complainants or Respondents may appeal the University’s dismissal of a Formal Complaint (or any allegations

therein); or a determination regarding responsibility, including any Disciplinary Sanction(s) imposed.

● Time to File an Appeal – An appeal must be in writing and filed within seven (7) calendar days of the date of

the letter informing the parties of the dismissal decision; or the determination regarding responsibility,

including any imposition of Disciplinary Sanctions, if applicable. If an appeal is not filed within seven (7)

calendar days, the dismissal decision or determination regarding responsibility (including Disciplinary

Sanctions, if applicable) will be deemed final.

● Bases for Appeal – Review of an appeal will be limited to the following bases:

o Procedural irregularity or substantive error that affected the outcome of the matter. Deviations from the

University’s policy/procedures will not be a basis for sustaining an appeal unless significant prejudice

resulted;

o New evidence that was not reasonably available at the time the determination regarding responsibility or

dismissal was made, that could affect the outcome of the matter;

o The AVP of the Division of Diversity, Equity and Inclusion, Office of Student Equity and Compliance,

investigator(s), or decision-maker(s) had a conflict of interest or bias for or against complainants or

respondents generally or the individual Complainant or Respondent that affected the outcome of the

matter; or

o The Disciplinary Sanction(s) imposed were substantially disproportionate or not appropriate in light of

the violation(s).

● Procedure for Appeal of Dismissal of Formal Complaint or Allegations – A party who wishes to appeal

the AVP of the Division of Diversity, Equity and Inclusion, Office of Student Equity and Compliance’s

decision to dismiss the Formal Complaint or an allegation therein, must submit the appeal in writing to the

Vice President for Student Affairs and Dean of Students (“VP for Student Affairs”), explaining in detail the

basis of the request, and including any supporting documentation. The VP for Student Affairs, or Designee,

will review the appeal, any submission from the other party, Formal Complaint and the AVP of the Division

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of Diversity, Equity and Inclusion, Office of Student Equity and Compliance’s decision to dismiss, and then

issue a written decision resolving the appeal, that includes the rationale for the decision, within fourteen (14)

calendar days of receipt of the appeal. The appeal decision will be issued simultaneously to both/all parties.

An assigned Designee shall not be the AVP of the Division of Diversity, Equity and Inclusion, Office of

Student Equity and Compliance, DEI Investigator (or Designee) or anyone who would be involved in the

determination regarding responsibility.

● Procedure for Appeal of Determination Regarding Responsibility/Sanctions – A party who wishes to

appeal a determination of responsibility, including any Disciplinary Sanction(s) imposed, if applicable, must

submit the appeal in writing to the Vice President for Student Affairs and Dean of Students (“VP for Student

Affairs”), explaining in detail the basis of the request, and including any supporting documentation. The VP

for Student Affairs, or Designee, will review the written appeal, any submission from the other party, and all

documentation contained in the case file. The VP for Student Affairs, or Designee, will issue a written

decision resolving the appeal, that includes the rationale for the decision, within twenty-one (21) calendar days

of receipt of the appeal. The written appeal decision will be issued simultaneously to both/all parties. An

assigned Designee shall not be the AVP of the Division of Diversity, Equity and Inclusion, Office of Student

Equity and Compliance, DEI Investigator (or Designee), or anyone who would be involved in the

determination regarding responsibility.

● Notification of Appeal – If a party files an appeal, the other party(ies) will be notified and may make their

own written submission in support of or challenging the decision of dismissal/determination of responsibility,

to the VP for Student Affairs/Designee, no later than seven (7) calendar days after receipt of such notice.

● Effect of Appeal – If there is an appeal of a determination regarding responsibility, including any Disciplinary

Sanction(s) imposed, the imposition of the Disciplinary Sanction(s), if applicable, will be deferred pending the

decision of the appeal. However, any Interim Suspension, no contact directive or other appropriate

Supportive/Interim Measure will remain in effect during the appeal process.

● Final Decision – An appeal may be resolved in the following manner:

o A dismissal or determination regarding responsibility, including any Disciplinary Sanctions (if

applicable), is affirmed;

o A determination regarding responsibility is affirmed, but the Disciplinary Sanction(s)/Remedies is/are

modified;

o A dismissal is reversed, and the matter is returned to the AVP of the Division of Diversity, Equity and

Inclusion, Office of Student Equity and Compliance to address in accordance with the policy; or

o A determination of responsibility is reversed, and a new outcome is determined, which may include

imposition of Disciplinary Sanctions/Remedies or dismissal of the charges.

The decision made on appeal shall be the final action of the University.

TIMELINES

All time frames set forth in this policy may be extended by the AVP of the Division of Diversity, Equity and

Inclusion, Office of Student Equity and Compliance, DEI Investigator, Hearing Panel Chair or their Designee for

good cause, with written notice to the Complainant(s) and Respondent(s) of the delay and the reason for the delay.

Good cause may include, but is not limited to, considerations such as the absence of a party/Advisor, or a witness;

the need for language assistance or an interpreter; or a person with disabilities requests a reasonable

accommodation.

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RETALIATION

Any harassment, intimidation, coercion, discrimination or adverse action taken against an individual for the purpose

of interfering with their rights under this policy, or because of that individual’s participation in a complaint or

investigation of Sexual Misconduct, will be treated as a separate violation of this policy and will result in immediate

action by the University to stop the retaliatory behavior, prevent further violations by the perpetrator and remedy

any adverse impact of the violation.

The University seeking appropriate disciplinary action against any individual who makes a False Report or False

Statement does not constitute retaliation.

RECORDKEEPING

The University will retain for a period of at least seven (7) years, the records related to complaints,

supportive/interim measures provided, investigations, transcripts or recordings of hearings, determinations of

responsibility, informal resolutions, disciplinary sanctions, remedies provided, appeals and training.

TRAINING

The University will provide appropriate training to University officials with responsibilities under this policy,

including the AVP of the Division of Diversity, Equity and Inclusion, Office of Student Equity and Compliance,

investigator(s), decision-makers and any person who will facilitate an informal resolution process.

REASONABLE

ACCOMMODATIONS

Any student with a disability who needs a reasonable accommodation to assist with reporting Sexual Misconduct,

responding to claims made against them, participating in the investigation and/or adjudication process, and/or

determining Supportive/Interim Measures, should advise the AVP of the Division of Diversity, Equity and

Inclusion, Office of Student Equity and Compliance as soon as possible.

REFERENCES

● File a Report

● File a Formal Complaint

● Office of Student Equity and Compliance

● Title IX of the Education Amendments of 1972

● Title IX Sexual Harassment/Sexual Assault Policy

● Policy Prohibiting Discrimination in the Workplace and Educational Environment

● Student Code of Conduct

● Disruptive Behavior and Workplace Violence Policy

● Good Samaritan Policy

Title IX Student Sexual Harassment /Sexual Assault Policy

CMSRU Adheres to the Rowan University Title IX Sexual Harassment/Sexual Assault Policy

PURPOSE

Students/Employees of the Rowan University community have the right to access and benefit from the University’s

Education Programs or Activities, free from any form of Sexual Harassment/Sexual Assault. The University does

not tolerate Sexual Harassment/Sexual Assault of any kind. This policy has been developed to reaffirm these

principles and to provide recourse for those individuals whose rights have been violated.

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APPLICABILITY

This policy applies to all students of Rowan University from the time of their acceptance and admission into the

University until the date of their graduation or formal withdrawal. This policy also applies to all employees of the

University. This policy shall not apply to allegations of sexual misconduct which do not constitute Sexual

Harassment/Sexual Assault as defined herein. Notwithstanding, such behavior may be addressed by the University

under other policies such as the Student Sexual Misconduct and Harassment Policy, Student Code of Conduct

or Procedure for Resolving Student v. Student Discrimination Complaints (for student Respondents); or the Policy

Prohibiting Discrimination in the Workplace and Educational Environment, Disruptive Behavior and Workplace

Violence Policy or other applicable policy (for employee Respondents).

INTRODUCTION

Title IX of the Education Amendments of 1972 is a federal law that prohibits sex discrimination in the University's

programs and activities. It reads: “No person in the United States shall, on the basis of sex, be excluded from

participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity

receiving Federal financial assistance.” As a recipient of Federal financial assistance, Rowan University has

jurisdiction over complaints alleging sex discrimination, including Sexual Harassment/Sexual Assault.

The University will respond to Reports or Formal Complaints (as defined below) of conduct prohibited under this

policy with measures designed to stop the prohibited conduct, prevent its recurrence and remediate any adverse

effects of such conduct on campus or in University-related programs or activities.

The University will not deprive an individual of rights guaranteed under federal and state law (or federal and state

anti-discrimination provisions; or federal and state law prohibiting discrimination on the basis of sex) when

responding to any claim of Title IX Sexual Harassment/Sexual Assault.

Conduct that is prohibited under this policy may also constitute a violation of federal, state or local law and a

student/employee may be charged in the criminal justice system, as well as under this policy. Alternatively, charges

can occur for violations of this policy which may not be violations of the law. The criminal justice system is

different from this Title IX process. The University reserves the right to reach its own determination on violations of

this policy, independently of the outcome of any civil or criminal proceeding. The University retains the right to

hear a Sexual Harassment/Sexual Assault matter before, after or during the pendency of a civil or criminal matter

related to the same incident/conduct. If a matter is going through the criminal justice system, and a Report or Formal

Complaint has also been made to the University, the Title IX process at the University may proceed normally during

the pendency of the criminal proceedings. As the Title IX process is an educational disciplinary process, the legal

rules related to evidence, criminal procedure, civil procedure and administrative procedure do not apply to this

process.

STANDARD

OF EVIDENCE

A finding under this policy will be based on the preponderance of the evidence standard. In other words, a finding

will be made if the evidence as a whole show that it is more likely than not that a violation of the Title IX Sexual

Harassment/Sexual Assault Policy occurred. Under this policy, there is a presumption that the Respondent is not

responsible for the alleged conduct until a determination regarding responsibility is made at the conclusion of the

Grievance Process or the Respondent admits responsibility.

DEFINITIONS/TERMINOLOGY

● Actual knowledge – Notice of Sexual Harassment/Sexual Assault or allegations of Sexual

Harassment/Sexual Assault made to the University’s Title IX Coordinator or any official of the University

who has authority to institute corrective measures on behalf of the University (such as the DEI Investigator,

or Dean of Students). This standard is not met when the only official of the University with Actual

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Knowledge is also the Respondent. In addition, the mere fact that a third party who works for the University

(such as a Responsible Employee) may become aware of allegations of Sexual Harassment/Sexual Assault,

or that such individuals have the ability or obligation to report Sexual Harassment/Sexual Assault, or to

inform another about how to report Sexual Harassment/Sexual Assault, or having been trained to do so, does

not qualify an individual as one who has authority to institute corrective measures on behalf of the

University.

● Complainant – An individual who is alleged to be the victim of conduct that could constitute Sexual

Harassment/Sexual Assault, or on whose behalf the Title IX Coordinator has filed a Formal Complaint.

● Consent – Consent is informed, knowing, voluntarily and freely given permission to engage in mutually

agreed upon sexual activity. The University will apply a reasonable person standard in determining whether

or not consent was given, unless otherwise required by law.

o The person giving consent must be capable of doing so freely, with the ability to understand what they

are doing and the specific details (who, what, when, where and how) of the sexual contact to which they

are consenting.

o Consent may be given by words or actions, as long as those words or actions create mutually

understandable permission regarding the conditions of sexual activity.

o It is the obligation of the person initiating sexual contact to obtain clear consent for the specific type of

sexual contact sought. A person’s use of alcohol and/or drugs shall not diminish such person’s

responsibility to obtain consent.

o Lack of protest does not constitute consent. Silence or passivity without words or actions that

communicate mutually understandable permission cannot be assumed to convey consent.

o Use of violence, threats, coercion or intimidation invalidates any consent given.

o A verbal “no” even if it may sound indecisive or insincere, constitutes lack of consent.

o Consent for one form of sexual contact does not imply consent to other forms. For example, consent to

oral sex does not imply consent to vaginal/anal sex.

o It is expected that once consent has been established, a person who changes their mind during the sexual

act or sexual contact will communicate through words or overt actions their decision to no longer

proceed.

o Past consent does not constitute consent for future sexual contact/activity.

o Persons who are unable to give valid consent under New Jersey law, (i.e. minors, individuals with

mental health disabilities, etc.) are considered unable to give consent under NJ State Policy

N.J.S.A.2C:4-2.

o Consent cannot be given by a person who is unconscious or sleeping. If consent has been given while a

person is conscious or awake, and then that person becomes unconscious or falls asleep, consent

terminates at that point.

o Persons who are incapacitated due to the use of drugs or alcohol cannot give consent.

● Disciplinary sanctions – Disciplinary Sanction(s) shall be imposed upon a Respondent where a

determination of responsibility for Sexual Harassment/Sexual Assault has been made against the Respondent.

Disciplinary Sanctions for student Respondents may range from a warning to expulsion. Disciplinary

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Sanctions for employee Respondents may range from an oral reprimand to initiation of detenuring

proceedings and termination of employment, subject to applicable laws and collective bargaining agreements.

Student/employee Respondents will also be referred to appropriate authorities for criminal prosecution when

appropriate, regardless of any Disciplinary Sanctions under this policy.

● Education program or activity – Includes any location, event, or circumstance over which the University

exercises substantial control over both the Respondent and the context in which the alleged Sexual

Harassment/Sexual Assault occurs. This includes all of the University’s education programs or activities,

whether occurring on or off-campus, and any building owned or controlled by a student organization that is

officially recognized by the University (i.e., a house owned or controlled by a University-recognized

fraternity or sorority).

● False report – Intentionally making a report of Sexual Harassment/Sexual Assault, to a University official

knowing, at the time the report was made, that the prohibited conduct did not occur and the report was false.

A determination regarding responsibility, alone, will not be sufficient to conclude that any party made a

materially false report in bad faith.

● False statement – Intentionally making a statement during the Grievance Process or Appeals Process to a

University official knowing, at the time the statement was made, that it was false. A determination regarding

responsibility, alone, will not be sufficient to conclude that any party or witness made a materially false

statement in bad faith.

● Formal complaint – A document filed and signed by a Complainant, or signed by the Title IX Coordinator,

alleging Sexual Harassment/Sexual Assault against a Respondent, and requesting that the University

investigate the allegations of Sexual Harassment/Sexual Assault. The Formal Complaint should include in

detail the nature of the complaint, dates and locations of particular events, names/contact information of

witnesses (if any), the name of the individual(s) against whom the complaint is being made, and any other

relevant information. At the time of filing a Formal Complaint, a Complainant must be either participating in

or attempting to participate in the Education Program or Activity of the University. A Report of Sexual

Harassment/Sexual Assault may be filed with the Title IX Coordinator in person, by mail, by electronic mail,

or by filling out the report form found HERE

. Upon receipt of a Report of possible Sexual

Harassment/Sexual Assault, the Title IX Coordinator, or Designee, will reach out the Complainant to discuss

the Complainant’s options, including the ability to file a Formal Complaint.

● Incapacitation – The physical and/or mental inability to make informed, rational judgements and decisions.

States of incapacitation include sleep, unconsciousness and blackouts.

o Where alcohol or drugs are involved, incapacitation is determined by how the substance impacts a

person’s decision-making capacity, awareness of consequences, and ability to make informed

judgements. In evaluating whether a person was incapacitated for purposes of evaluating effective

Consent, the University considers two questions:

▪ Did the person initiating sexual activity know that their partner was incapacitated?

▪ Should a sober, reasonable person in the same situation have known that their partner was

incapacitated?

If the answer to either of these questions is “yes” effective Consent was absent.

o For purposes of this policy, incapacitation is a state beyond drunkenness or intoxication. A person is not

incapacitated merely because they have been drinking or using drugs. The standard for incapacitation

does not turn on technical or medical definitions, but instead focuses on whether a person has the

physical and/or mental ability to make informed, rational judgments and decisions.

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o A person who initiates sexual activity must look for the common and obvious warning signs that show

that a person may be incapacitated or approaching incapacitation. Although every individual may

manifest signs of incapacitation differently, typical signs include slurred or incomprehensible speech,

unsteady gait, combativeness, emotional volatility, vomiting, or incontinence. A person who is

incapacitated may not be able to understand some or all of the following questions: “Do you know

where you are?” “Do you know how you got here?” “Do you know what is happening?” or “Do you

know whom you are with?”

o Because the impact of alcohol and other drugs varies from person to person, one should be cautious

before engaging in sexual contact or intercourse when either party has been drinking alcohol or using

drugs. The introduction of alcohol or other drugs may create ambiguity for either party as to whether

effective Consent has been sought or given. If one has doubt about either party’s level of intoxication,

the safe thing to do is to forgo all sexual activity.

● Remedies – Remedies may be provided to a Complainant where a determination of responsibility for Sexual

Harassment/Sexual Assault has been made against the Respondent. Remedies are designed to restore or

preserve the Complainant’s equal access to the University’s Education Program or Activity. Remedies may

include the same individualized services described in the Supportive/Interim Measures section below;

however, unlike Supportive/Interim Measures, Remedies need not be non-disciplinary or non-punitive, and

need not avoid burdening the Respondent. Remedies provided may include, but not be limited to, a one-way

no contact directive; changes to housing/work arrangements; or a leave of absence.

● Report – Anyone may file a Report alleging an incident of Sexual Harassment/Sexual Assault of which they

become aware. The Report should include as much information possible, such as details (if known) of the

nature of the incident, dates of particular events, names/contact information of any Complainant, Respondent,

witnesses (if any) and any other relevant information. A Report may be filed with the Title IX Coordinator in

person, by mail, by electronic mail or by filling out the report form found HERE

● Respondent – An individual who has been reported to be the perpetrator of conduct that could constitute

Sexual Harassment/Sexual Assault.

● Responsible employees – Certain employees, who under this policy, are required, after receiving

information regarding Sexual Harassment/Sexual Assault, to report it to the Title IX Coordinator. These

employees include, but are not limited to, Public Safety Police and Security Officers, managers and

supervisors, coaches, club and organization advisors, faculty, Deans and Residential Learning staff (Resident

Assistants, Community Safety Assistants, Resident Directors, and Residential Learning Coordinators).

Notwithstanding, knowledge of an incident of Sexual Harassment/Sexual Assault by a Responsible

Employee (other than those who also have authority to institute corrective measures on behalf of the

University) does not constitute Actual Knowledge by the University.

● Sanctions – See Disciplinary Sanctions.

● Supportive/interim measures – See Section X below.

PROHIBITED

CONDUCT

This policy addresses allegations of sexual misconduct that meet the definition of Title IX Sexual

Harassment/Sexual Assault, which encompasses all of the prohibited conduct defined below that occurs on the basis

of sex and meets the following requirements: (i) occurs within the United States; (ii) occurs within the University’s

Education Program or Activity; and (iii) at the time of the filing of the Formal Complaint, the Complainant was

participating in, or attempting to participate in, the Education Program or Activity.

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Allegations of sexual misconduct that do not fall under this policy because they do not constitute prohibited conduct

as defined in this section, may be addressed under the Student Sexual Misconduct and Harassment Policy,

Student

Code of Conduct or Procedure for Resolving Student v. Student Discrimination Complaints (for student

Respondents); or the Policy Prohibiting Discrimination in the Workplace and Educational Environment, Disruptive

Behavior and Workplace Violence Policy or other applicable policy (for employee Respondents).

Prohibited conduct (referred to collectively as “Sexual Harassment/Sexual Assault” throughout the policy) is:

● Sexual harassment – Conduct on the basis of sex, through any medium, that satisfies one or more of the

following:

o An employee of the University conditions the provision of aid, benefit or service of the University on an

individual’s participation in unwelcome sexual conduct; or

o Unwelcome conduct determined by a reasonable person to be so severe, pervasive and objectively

offensive that it effectively denies a person of equal access to the University’s Education Program or

Activity.

● Sexual assault – Any sexual act directed against another person, without their consent or where they are

incapable of giving consent. An offense that meets the definition of rape, fondling, incest or statutory rape:

o Rape: The penetration, no matter how slight, of the vagina or anus with any body part or object, or oral

penetration by a sex organ of another person, without the consent of the victim.

o Fondling: The touching of the private body parts of another person for the purpose of sexual

gratification, without the consent of the victim, including instances where the victim is incapable of

giving consent because of his/her age or because of his/her temporary or permanent mental incapacity.

o Incest: Sexual intercourse between persons who are related to each other within the degrees wherein

marriage is prohibited by law.

o Statutory Rape: Sexual intercourse with a person who is under the statutory age of consent.

● Stalking – Engaging in a course of conduct, through any medium, directed at a specific person that would

cause a reasonable person to: (a) fear for the person's own safety or the safety of others; or (b) suffer

substantial emotional distress. For the purposes of this definition:

o Course of conduct means two or more acts, including, but not limited to, acts in which the stalker

directly, indirectly or through third parties, by any action, method, device or means, follows, monitors,

observes, surveils, threatens or communicates to or about a person, or interferes with a person's

property;

o Reasonable person means a reasonable person under similar circumstances and with similar identities to

the Complainant;

o Substantial emotional distress means significant mental suffering or anguish that may, but does not

necessarily, require medical or other professional treatment or counseling.

● Dating violence – Violence committed by a person who is or has been in a social relationship of a romantic or

intimate nature with another person. The existence of such a relationship shall be determined based on a

consideration of the following factors: (a) the length of the relationship; (b) the type of relationship; and (c)

the frequency of interaction between the persons involved in the relationship.

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● Domestic violence – A felony or misdemeanor crime of violence committed by: (a) a current or former spouse

or intimate partner; (b) a person with whom an individual shares a child in common; (c) a person who is

cohabitating with, or has cohabitated with, the other person as a spouse or intimate partner; (d) a person

similarly situated to a spouse of the other person under the domestic or family violence laws in which the

crime of violence occurred; or (e) any other person against an adult or youth who is protected from that

person's acts under the domestic or family violence laws of the jurisdiction in which the crime of violence

occurred.

REPORTING

OPTIONS – HOW TO FILE A REPORT/COMPLAINT

Students/Employees who have experienced Sexual Harassment/Sexual Assault or sex discrimination in the

University's programs and activities, and those who have knowledge of Sexual Harassment/Sexual Assault or sex

discrimination in the University's programs and activities, are strongly encouraged to report this information as soon

as possible. Prompt reporting of incidents greatly improves the ability of the University and law enforcement to

provide support resources to students/employees and to address the violations effectively. Although there is no time

limit for reporting Sexual Harassment/Sexual Assault, delays in reporting may reduce the ability of the University

and law enforcement to investigate and respond to incidents. After an incident of Sexual Harassment/Sexual

Assault, the student/employee should consider seeking medical attention as soon as possible. In New Jersey,

evidence may be collected even if you chose not to make a report to law enforcement.

It is a violation of this policy for anyone to make a False Report of Sexual Harassment/Sexual Assault, or for anyone

to make a False Statement. Disciplinary Sanctions may be imposed for intentionally making a False Report or False

Statement.

EPORTING TO LAW ENFORCEMENT

● Where criminal behavior is involved, the University encourages, and will assist students/employees with,

reporting to law enforcement. However, students/employees have the right to decline notifying law

enforcement. For criminal offenses that occur on the University campus, students/employees should

immediately contact Rowan Public Safety, 856-256-4911. Rowan Public Safety can assist students/employees

in contacting and filing a report/complaint with any other agency when the incident did not occur on campus.

o Glassboro campus – Glassboro Police Department, 1 South Main Street, Glassboro, NJ 856-881-

1500; http://www.glassboropd.org/

o Camden campuses – Camden County Metro Police, 800 Federal Street, Camden, NJ 856-757-

7440; http://camdencountypd.org/

o RowanSOM campus – Stratford Police Department, 315 Union Ave., Stratford, NJ 856-783-

8616; https://som.rowan.edu/oursom/campus/safety.html

● LGBTQIA+ (Lesbian, Gay, Bisexual, Transgender, Queer/Questioning, Intersex, or Agender/Asexual)

students/employees should know that every Rowan Public Safety Officer will assist them should they choose

to report Sexual Harassment/Sexual Assault. However, if an LGBTQIA+ student/employee would prefer, they

can ask to speak directly with the Rowan University LGBTQIA+ police liaison.

● Behavior that constitutes a violation of this policy may also be a crime under the laws of the State of New

Jersey.

EPORTING TO THE UNIVERSITY

● A student/employee may choose to report an incident of Sexual Harassment/Sexual Assault to the University

before they have made a decision about whether or not to report to law enforcement. A student/employee has

the right to file a criminal complaint and a Title IX Formal Complaint simultaneously.

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● Once a Report of Sexual Harassment/Sexual Assault has been received, whether or not a Formal Complaint

has been filed, the University will provide written notification to the Complainant about existing counseling,

health, mental health, student advocacy, employee advocacy, legal assistance, visa and immigration

assistance, student financial aid and other services that are available at Rowan and in the surrounding

communities. For more information on these services please visit OSEC’s website

● Reports of incidents alleging to involve Sexual Harassment/Sexual Assault or sex discrimination in a

University program or activity should be made to the Title IX Coordinator in person, by mail, by electronic

mail or by filling out the report found HERE

Title IX Coordinator

Monise Princilus, Ed.S.

Associate Vice President and Title IX Coordinator of the Division of Diversity,

Equity and Inclusion, Office of Student Equity and Compliance

203 Savitz Hall

856-256-5440

[email protected]

In addition, prior to filing a Report or Formal Complaint, a person may reach out to the following individuals

to discuss their reporting options. The below individuals are Responsible Employees under this policy and

therefore, should report the incident to the Title IX Coordinator. However, their knowledge of any incident

does not constitute Actual Knowledge by the University. Thus, if a student/employee wishes to ensure a

Report/Formal Complaint has been made, the individual should also reach out to the Title IX Coordinator.

Athletics / LGBTQIA+

Penny Kempf, Associate Athletic Director

Athletics Office, Esby Gym

856-256-4679,

kempf@rowan.edu

Cooper Medical School of Rowan University

Dr. Marion Lombardi, Assistant Dean for Student Affairs

Room 409B, CMSRU Medical Education Building, Camden, NJ

856-361-2805,

lombardim@rowan.edu

Rowan University School of Osteopathic Medicine

Dr. Paula Watkins, Director of Enrollment Services

Suite 210 Academic Center, One Medical Center Drive, Stratford, NJ

856-566-7050,

fennerpa@rowan.edu

Graduate School of Biomedical Sciences

Dr. Diane Worrad, Director

42 East Laurel Road, UDP, Suite 2200, Stratford, NJ

856-566-6282,

worrad@rowan.edu

Graduate Medical Education

Sheila Seddon, Assistant Director

Academic Center Stratford, NJ

856-566-2742,

seddonsm@rowan.edu

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OLICY OF IMMUNITY

The University will grant immunity for using alcohol and drugs to both a Complainant and/or Respondent unless the

alcohol or drug was used knowingly to perpetrate violence. No one should be fearful of obtaining resources or

remedies from a violent crime because they were intoxicated. In addition, the University will not pursue disciplinary

action for drug or alcohol violations, or most other violations of the Student Code of Conduct, against a party or

witness who comes forward in good faith to Report Sexual Harassment/Sexual Assault. See

Rowan University Good

Samaritan Policy.

OTHER REPORTING OPTIONS

Individuals also have the right to file a complaint with federal/state agencies that investigate Sexual Harassment,

Sexual Assault and discrimination. An external complaint must be filed directly with the agency, and each agency

should be consulted to determine proper deadlines for filing.

Office of Civil Rights, U.S. Department of Education

New Jersey, New York, Puerto Rico, Virgin Islands OCR

New York Office, U. S. Department of Education

32 Old Slip, 26th Floor

New York, NY 10005-2500

Telephone: (646) 428-3800

Facsimile: (646) 428-3843

Email:

OCR.NewYor[email protected]

Equal Employment Opportunity Commission

Philadelphia District Office

801 Market Street, Suite 1000

Philadelphia, PA 19107-3126

Telephone: (800) 669-4000 / (267) 589-9700

Facsimile: (215) 440-2606

Email:

PDOContact@eeoc.gov

New Jersey Division on Civil Rights

Southern Regional Office

5 Executive Campus, Suite 107

Cherry Hill, NJ 08034 map

Telephone: 856-486-4080

Facsimile: 856-486-2255

CONFIDENTIALITY

When the University is made aware of a report or allegation of Sexual Harassment/Sexual Assault, the University

will endeavor to maintain the confidentiality of the matter and of all individuals involved to the extent permitted by

law. The University will balance the needs of the individuals involved (Complainant and Respondent) with its

obligation to fully investigate allegations and to protect the safety and wellbeing of the community at large. In all

cases, the University and its employees will respect the dignity and rights of all individuals involved.

● Responsible Employees: When consulting campus resources, individuals should be aware that certain

employees are Responsible Employees who under this policy are required, after receiving information

regarding Sexual Harassment/Sexual Assault, to report it to the Title IX Coordinator. These include, but are

not limited to, Public Safety Police and Security Officers, managers and supervisors, coaches, club and

organization advisors, faculty, Deans and Residential Learning staff (Resident Assistants, Community Safety

Assistants, Resident Directors and Residential Learning Coordinators). Knowledge of an incident of Sexual

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Harassment/Sexual Assault by a Responsible Employee (other than those who also have authority to institute

corrective measures on behalf of the University) does not constitute Actual Knowledge by the University.

If an individual has reported information to a Responsible Employee, but the individual would like for the

report to remain confidential, the student should contact the Title IX Coordinator, who will evaluate the

individual’s request for confidentiality. The Grievance Process will only be initiated when a Formal

Complaint has been filed with or by the Title IX Coordinator.

● Confidential Resources – Students: Students who desire that details of an incident be kept confidential can

receive confidential services through the Counseling & Psychological Services Center (856-256-4333), which

is located in the Wellness Center at Winans Hall. Counselors with specialized training are available to support

students who report Sexual Harassment/Sexual Assault. Counselors are available to help you free of charge

and can be seen on an emergency basis. The Student Health Center (856-256-4222) can also provide

confidential consultation with students and may offer treatment to prevent sexually transmitted infections or

pregnancy. In circumstances where the Health Center is unable to offer these services, they will provide a

referral to an appropriate medical resource. In addition, you may speak with members of the clergy, who will

also keep reports made to them confidential. LGBTQIA+ students who would like to speak with a confidential

resource should know that every counselor at the Wellness Center is committed to supporting students of all

gender identities, gender expressions, and sexual orientations. When speaking with these resources, a student’s

right to confidentiality is legally protected. However, there are limits to this protection in specific situations.

For example, if a student discloses that the incident involved the use of a weapon or other contraband as

defined by New Jersey law, or there is an ongoing threat or danger to the safety of another person (particularly

children or the elderly), these resources may be required to report the incident to police.

● Confidential Resources – Employees: Employees who desire that details of an incident be kept confidential

can receive confidential services through the New Jersey Employee Advisory Service (1-866-327-9133).

● Federal Statistical Reporting and Federal Timely Warning Obligations: Certain campus officials have a

duty to report Sexual Harassment/Sexual Assault for federal statistical reporting purposes. All personally

identifiable information is kept confidential, but statistical information must be passed along to campus law

enforcement regarding the type of incident and its general location (on or off-campus, in the surrounding area,

etc. – with addresses withheld), for publication in the annual Campus Security Report. This report helps to

provide the community with a clear picture of the extent and nature of campus crime to ensure greater

community safety.

Individuals who report Sexual Harassment/Sexual Assault should also be aware that University administrators

may be required to issue timely warnings for certain incidents reported to them that pose a substantial threat of

bodily harm or danger to members of the community, to aid in the prevention of similar occurrences. The

University will withhold the names and other personally identifiable information of individuals as

confidential, while still providing enough information for community members to make decisions related to

their safety in light of the danger.

SUPPORTIVE/INTERIM

MEASURES

Non-disciplinary, non-punitive individualized services will be offered to the Complainant and/or Respondent, as

appropriate and as reasonably available, without fee or charge, where no Formal Complaint has been filed, or before

or after the filing of a Formal Complaint. Such measures are designed to restore or preserve equal access to the

University’s Education Program or Activity without unreasonably burdening the other party, including measures

designed to protect the safety of all parties, the University’s educational environment and/or to deter Sexual

Harassment/Sexual Assault.

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Supportive/Interim Measures may include, but are not limited to, the provision of information related to counseling,

academic support, mental health services; extensions of deadlines or other course-related adjustments; modifications

of work or class schedules; campus escort services; mutual restrictions on contact between the parties (no contact

directives); changes in work or housing locations; leaves of absence; increased security; and other similar measures.

In addition, the University may place a student on an Interim Suspension, pending the outcome of the Grievance

Process. This decision will be made in accordance with the University’s Student Code of Conduct

. And, an

employee may be placed on an Administrative leave (paid or unpaid), pending the outcome of the Grievance

Process.

The University will maintain as confidential any Supportive/Interim Measures provided to the Complainant or

Respondent, to the extent that maintaining such confidentiality would not impair the University’s ability to provide

the Supportive/Interim Measure(s).

ADVISORS

A Complainant and Respondent each have the right to an Advisor of their choice during the Grievance Process

(discussed below). An Advisor may be a family member, a friend, an attorney or any third party (i.e., a trusted

employee for a student; or a union representative for an employee). However, an Advisor may not otherwise be

involved in the Grievance Process (i.e., a witness, co-Complainant or co-Respondent). Advisors are present to

support the parties and to provide advice on procedural matters, as well as conduct cross-examination during any

Hearing.

Other than as provided in this policy, Advisors may not speak on behalf of the party.

Advisors must adhere to all conditions and obligations under this policy and as required by the University’s process.

The Advisor has the right to accompany the Complainant or Respondent to any meetings with the Title IX

Coordinator, DEI Investigator (or their Designee), or University administrators, and the party has the right to

communicate with their Advisor during any meeting. The Advisor may also assist the Complainant or Respondent

during the investigation, preparing/submitting a response to the investigation report, attend the live hearing or assist

with the filing of an appeal.

The Advisor does not have speaking privileges during the investigation/investigatory interviews. The Title IX

Coordinator or designee will exercise control over the investigation. Anyone who disrupts an investigatory interview

or who fails to adhere to University policies may be asked to leave an investigatory interview.

With respect to the Hearing, if a Complainant or Respondent does not have an Advisor, one will be provided by the

University. The Advisor is to conduct cross examination on behalf of the party at the Hearing, as the parties may not

conduct cross-examination on their own behalf.

Regardless of whether a party has an Advisor, the Title IX Coordinator, DEI Investigator or Designee will

correspond and communicate directly with the parties. If a party wishes for their Advisor to be copied on any

correspondence or communications, the party should advise the Title IX Coordinator or DEI Investigator.

GRIEVANCE

PROCESS/PROCEDURES

Upon receipt of a Report of Sexual Harassment/Sexual Assault, the Title IX Coordinator or Designee, will contact

the Complainant to: (i) discuss available Supportive/Interim Measures, while taking into consideration the

Complainant’s wishes; (ii) inform the Complainant that the Supportive/Interim Measures are available with or

without a Formal Complaint; and (iii) explain the process for filing of a Formal Complaint.

Upon receipt of a Formal Complaint, the University will initiate the Grievance Process.

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The University will treat Complainants and Respondents equitably by providing Remedies to a Complainant where a

determination of responsibility for Sexual Harassment/Sexual Assault has been made against the Respondent, and by

following the Grievance Process before the imposition of any Disciplinary Sanctions or other actions, that are not

Supportive/Interim Measures, are taken against a Respondent.

Throughout the Grievance Process, there will be an objective evaluation of all relevant evidence, including both

inculpatory (evidence implying or imputing responsibility) and exculpatory (evidence exonerating responsibility)

evidence. In addition, credibility determinations will not be based on an individual’s status as a Complainant,

Respondent or witness.

Individual(s) involved in the Grievance Process (Title IX Coordinator, investigator, decision-maker or any person

designated by the University to facilitate an informal resolution process) shall not have a conflict of interest or bias

for or against Complainants or Respondents generally, or an individual Complainant or Respondent. Such

individual(s) shall also have the appropriate training as set forth in the Training Section of this policy.

It is presumed that a Respondent is not responsible for the alleged conduct until a determination regarding

responsibility is made at the conclusion of the Grievance Process, or if a Respondent admits to responsibility.

It is a violation of this policy for anyone to make a False Report of Sexual Harassment/ Sexual Assault, or for

anyone to make a False Statement during the Grievance Process. Disciplinary Sanctions may be imposed for

intentionally making a False Report or False Statement.

ISMISSAL OF A FORMAL COMPLAINT

● The Title IX Coordinator must dismiss the Formal Complaint, or allegations therein, at any time, if it is

determined that the conduct alleged: (i) would not constitute Sexual Harassment/Sexual Assault, even if

proven; (ii) did not occur while the Complainant was participating in, or attempting to participate in, the

University’s Education Program or Activity; or (iii) did not occur against a person in the United States. Such a

dismissal does not preclude the University from taking action under another provision of the University’s

policies.

● The Title IX Coordinator, in his/her discretion, may also dismiss the Formal Complaint, or allegations therein,

if at any time during the Grievance Process, the following occurs: (1) the Complainant notifies the Title IX

Coordinator in writing that the Complainant would like to withdraw the Formal Complaint, or any allegations

therein; (ii) the Respondent is no longer enrolled or employed by the University; or (iii) specific circumstances

prevent the University from gathering evidence sufficient to reach a determination as to the Formal Complaint

or allegations therein.

● Written notice of any required or permitted dismissal, including any reason(s) therefore, shall be promptly sent

to the parties simultaneously. This notice will also advise the parties of their appeal rights in accordance with

this policy.

Consolidation of Formal Complaints – Formal Complaints as to allegations of Sexual Harassment/Sexual Assault

against more than one Respondent, or by more than one Complainant against one or more Respondents, or by one

party against the other party, may be consolidated where the allegations of Sexual Harassment/Sexual Assault arise

out of the same facts or circumstances.

Notice of Allegations – Upon receipt of a Formal Complaint, the Title IX Coordinator, or Designee, will provide

written notice to the known parties, which includes:

● A link to the University’s Title IX Sexual Harassment/Sexual Assault Policy, so the parties can review the

University’s Grievance Process, including the Informal Resolution Process;

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● Sufficient detail, of what is known at the time, related to the allegations of Sexual Harassment/Sexual Assault,

including details such as the identities of the parties involved, the conduct allegedly constituting Sexual

Harassment/Sexual Assault, and the date(s) and location(s) of the alleged incident(s);

● A statement that the Respondent is presumed not responsible for the alleged conduct, and that a determination

regarding responsibility will be made at the conclusion of the Grievance Process;

● Information that the parties may have an Advisor of their choice, who may be, but is not required to be, an

attorney;

● A statement that the parties and their Advisors will have the right to inspect and review evidence during the

investigation of a Formal Complaint; and

● Reference to the provisions within the Title IX Sexual Harassment/Sexual Assault Policy that prohibits

knowingly making False Reports or False Statements.

Such notice will be provided to the parties within a reasonable period of time prior to conducting any investigatory

interview, so that the parties have time to prepare and meaningfully respond.

If, in the course of an investigation, the University decides to investigate allegations about the Complainant or

Respondent that were not included in the initial notice, the University will provide notice of the additional

allegations to be investigated, to the known parties.

ORMAL RESOLUTION PROCESS

● Written Notice of Meetings, Interviews, Hearings – Written notice of the date, time, location, participants

and purpose of all investigative interviews, hearings or any other meetings, will be provided to any party

whose participation is invited or expected, with sufficient time for the party to prepare to participate.

● Investigation of a Formal Complaint – After notification of the allegations in the Formal Complaint has

been sent, the DEI Investigator, or Designee, will promptly initiate an investigation within seven (7) calendar

days. The investigation shall be completed in a reasonably prompt manner, and should be completed within

ninety (90) calendar days from the time the Formal Complaint is filed.

o The investigation will include interviews of the Complainant(s), Respondent(s) and any

witnesses/individuals believed to have information relevant to the allegations, as well as the collection

of any relevant evidence.

o Each party is permitted to have their Advisor present during any investigatory interview, or other

meeting. However, while the party has the right to communicate with their Advisor during any meeting,

the Advisor does not have speaking privileges during the investigation/investigatory interviews.

o The investigator will not access, consider, disclose or otherwise use a party’s records that are made or

maintained by a physician, psychiatrist, psychologist or other recognized professional/paraprofessional

acting in the professional/paraprofessional’s capacity or assisting in that capacity, and which are made

and maintained in connection with the provision of treatment to the party, unless the investigator obtains

that party’s voluntary, written consent to do so for a Grievance Process.

o The parties and their Advisors are not restricted from discussing the allegations under investigation for

the purpose of gathering and presenting evidence to the investigator.

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