The Chief Compliance Officer, who is a senior administrator designated by the Executive Vice President for Health and Biomedical Sciences and Dean of the Faculties of Medicine and Health Sciences, has primary responsibility for implementing and managing the University’s compliance effort. The Dean designates the Chief Compliance Officer, and on matters of compliance, the Chief Compliance Officer reports to the Dean through the Senior Associate Dean for Clinical Affairs, who serves as Billing Compliance Medical Director. The Chief Compliance Officer is authorized to report directly to the Dean, the President of Columbia and the Board of Trustees. The Chief Compliance Officer also reports to the Executive Vice President for Finance, who reports to the Audit Committee of the Committee on Finance of the University's Trustees on these matters. The Chief Compliance Officer, with the assistance of the Billing Compliance Medical Director and University counsel where appropriate, performs the following activities:
Assists in the review, revision, and formulation of appropriate policies to guide billing of professional fees for services provided by University faculty;
Works with Departments and faculty to develop plans for implementing University policies on billing;
Assists in developing and delivering educational and training programs;
Works with Schools, Departments and faculty to develop and/or enhance billing expertise and to facilitate Department based training programs;
Coordinates reviews of medical charts and associated billings; and
Provides other assistance as directed by the Chief Compliance Officer.
The Chief Compliance Officer works closely with representatives of the Departments and any entities or individuals who handle professional fee billing for the University’s faculty to foster and enhance compliance with all applicable billing requirements. To assist the overall compliance effort, the Steering Committee meets periodically under the direction of the Chief Compliance Officer in an advisory capacity.
Columbia University Billing Compliance Plan
September 9, 1996 (with amendments to October 2003)
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