Intermediate Sanctions

Very Important:  All individuals listed below should have a basic knowledge of the Intermediate Sanctions rules to protect themselves from IRS penalty taxes. These individuals include Penn's:

Trustees, Overseers, President, Executive VP &VP's, Senior Executives in the Health System, Deans & Vice Deans, Department Chairs, Basic Science Chairs, Physicians, Faculty, and anyone else deemed to have substantial influence over the affairs of Penn or UPHS.

Failure to comply with these IRS rules could result in substantial, personal penalty taxes being imposed on key members of Penn's leadership and management. It may also cause adverse press for Penn and resulting financial harm.

It is your responsibility to determine if you meet the definition of an "organization manager" or a "disqualified person", to understand what an "excess benefit transaction" is, to understand how to use the "Rebuttable Presumption Safe Harbor" and to take steps necessary to protect yourself and Penn.