Under the supervision of the Director of Compliance, a sample of medical records and corresponding bills for each department and division is periodically reviewed for compliance with the University's billing policies and with legal requirements. Each department is reviewed at least annually, but the Director may require more frequent reviews. The results of such reviews are reported to the Chief Compliance Officer, to the Chair, to the department’s compliance leaders, and to the University’s Internal Auditor. The University's Internal Auditor, as appropriate, performs independent reviews and reports the results of such reviews to the Chief Compliance Officer and to the Steering Committee, as well as to other relevant senior administrators. Moreover, the Chief Compliance Officer may, after consultation with legal counsel for the University, engage an external billing expert or auditor to review records for a particular department or drawn from a cross-section of departments.
If any of these reviews identify instances of possible non-compliance, the Director reports that fact to the Chief Compliance Officer, the Chair for the department whose billings are at issue, and to legal counsel for the University. In consultation with legal counsel, the Chief Compliance Officer reviews the situation to determine whether there appears to have been any activity inconsistent with University policies.
Columbia University Billing Compliance Plan
September 9, 1996 (with amendments to October 2003)
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