Columbia University Medical Center - Billing Compliance Program
Blue Line
Top Menu Graphic
Blue bar

Columbia University Billing Compliance Plan                         


The Columbia University Health Sciences Division (the "University") has an ongoing commitment to ensuring that its affairs are conducted in accordance with applicable law. The University also has a strong interest in making certain that its faculty and employees are fully informed about applicable laws and regulations so that they do not inadvertently engage in conduct that may raise compliance issues. Of particular concern, given the fact that many faculty engage in clinical practice, are legal requirements relating to professional fee billing. Compliance in this area is challenging because the regulatory requirements governing professional fee reimbursement are complex and changing. To further its commitment to compliance and to protect its employees, the University has adopted a formal compliance plan to address professional fee reimbursement. This plan results from the work of the Steering Committee, consisting of representatives of the Dean's Office, Internal Audit, General Counsel’s Office, faculty, and departmental and other administrators. The compliance plan has the following key features:

  • Designation of University officials responsible for directing the effort to enhance compliance, including implementation of the Plan;

  • Incorporation of standards and policies that guide University personnel and others involved with the billing process with regard to professional fee billing;

  • Development of compliance initiatives at the Department level, with compliance used as an element in evaluating the performance of managers and supervisors responsible for billing;

  • Coordinated training of clinical staff and billing personnel concerning applicable billing requirements and University policies;

  • A uniform mechanism for employees to raise questions and receive appropriate guidance concerning professional fee billing;

  • Regular chart and billing reviews to assess compliance, to identify issues requiring further education, and to identify potential problems;

  • A process, including a hotline for anonymous complaints, for employees to report possible compliance issues and for such reports to be fully and independently reviewed;

  • Formulation of corrective action plans to address any compliance problems that are identified; and

  • Regular reviews of the overall compliance effort to ensure that billing practices reflect current requirements and that other adjustments are made to improve the program.

The compliance program described in this document establishes a framework for legal compliance by the University and its employees. It does not set forth all of the substantive programs and practices of the University that are designed to achieve compliance. The University maintains various compliance practices and those practices continue to be a part of its overall legal compliance efforts.

Columbia University Billing Compliance Plan
September 9, 1996 (with amendments to October 2003)

Previous | Contents | Next