Billing Compliance Manual

CUIMC's Billing Compliance Plan applies to all CUIMC physicians, faculty, entities, corporations, administrative personnel, clinical research staff, and other health professionals involved in the provision of professional services.

The Billing Compliance Manual is intended to summarize, for ease of use and reference, the compliance principles and organizational structure set forth in the Billing Compliance Plan and applicable Federal and State laws and regulations. The Manual is also intended to update, amplify, and explain certain requirements and processes at the University, and to cross-reference related legal and institutional requirements, including policies of Columbia Doctors.

Table of Contents

• Overview of Billing Compliance Program
  • Objective
  • Organization
  • Scope
  • Departmental Compliance Responsibilities
    • Medical Record Retention
  • Code of Conduct for Billing Compliance
  • Columbia University Compliance Hotline
• Compliance Operations
  • Billing Compliance Risk Areas
  • Risk Assessment Policy
  • Governing Laws and Guidelines
    • Prohibitions Against Kickbacks, Self-Referrals and Fee Splitting
    • Detection and Prevention of Fraud
    • Physicians at Teaching Hospitals
    • Speaking with Government Agents
  • Audit Policy
  • Corrective Action Policy
  • Refunds/Credit Balances and Self Disclosures
  • Education and Training Policy for Employees and Contractors Involved in Billing
    • Education and Training for New Hires
    • Ongoing Training for CUIMC Clinicians and Billing Personnel
    • Clearing Claim Scrubber Coding Edits in Epic
    • Qualification Standards for Charge Review Personnel
    • Policy Regarding Ineligible Persons
    • Billing Consultants or Contractors
    • Retention of Compliance Training Records Policy
• Medical Billing Guidelines
  • Medical Billing Policy
  • Coding
  • NPP (Non-Physician Providers) Billing Practices
  • Diagnostic Supervisory Regulations
  • Scribes
• Documentation & EMR Guidelines
• Compliance Policies
  • Collection of Health Insurance Co-payments, Deductibles, Coinsurance
  • Professional Courtesy
  • Advance Beneficiary Notices of Non-coverage
  • Acceptance and/or Solicitation of Gifts or Benefits from Vendors, Patients, and Others
  • Patient Financial Hardship
  • Payment Accommodation Policy
• Other Practice Policies
  • Patient Transportation Policy
  • "No Show" Charge Policy
• Research Billing Compliance
• HIPAA/HITECH Compliance
• Federal Laws/Administrative Remedies for False Claims
• Frequently Used Terms
• Frequently Asked Questions (FAQ)
• Helpful Phone Numbers, Acronyms & Websites