Whenever conduct that may be inconsistent with a billing policy or requirement is reported to the Director of Compliance, the matter should be referred to the Chief Compliance Officer. If the Chief Compliance Officer determines that there is reasonable cause to believe that a compliance issue may exist, an inquiry into the matter is undertaken with appropriate assistance from the Office of General Counsel and the University’s Internal Auditor. Upon completion of the inquiry, a written report is prepared, and copies of the report are provided to the Office of General Counsel and to the Internal Auditor. University employees should cooperate fully with any inquiries undertaken by the Chief Compliance Officer, the Office of General Counsel, or the University’s Internal Auditor. To the extent practical and appropriate, efforts should be made to maintain the confidentiality of such inquiries and the information gathered.
Nothing in this Plan shall limit the authority of the University’s Internal Auditor to conduct investigations or to act on his or her own initiative.
Columbia University Billing Compliance Plan
September 9, 1996 (with amendments to October 2003)
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