The policy of Columbia University is to bill only for professional services actually provided. The University recognizes that special billing requirements may apply to certain government-sponsored programs or to other providers; any such requirements must be followed. In selecting codes to describe services rendered, University clinicians, other health professionals, and billing personnel are to select codes that they believe, in good faith, correspond to services actually rendered, as documented in the medical record. University clinicians, other health professionals, and billing personnel have a collective responsibility to be knowledgeable about the meaning of the codes applicable to their area of practice, including relevant directives from billing authorities.
University clinicians, other health professionals, and billing personnel should never submit a claim that is known to contain inaccurate information concerning the service provided, the charges, the identity of the provider, the date of service, the place of service, or the identity of the patient.
When in doubt about how to bill a particular service, including the proper code to use, no claim should be submitted until appropriate guidance is obtained from departmental compliance leaders or from the Director of Compliance. The resolution of any such billing questions should be documented in writing.
It is the responsibility of the billing clinician or other health professional to ensure that appropriate documentation supports the claim being submitted.
To guide clinicians, other health professionals and billing personnel in meeting these objectives, the Chief Compliance Officer shall, with the assistance of legal counsel, review existing policy statements, revise those statements as necessary, and develop any additional statements that seem advisable. University policies concerning billing, as those policies may be changed periodically, should be considered an integral part of this Plan. University employees are also expected to adhere to the Health Sciences’ records retention policy for clinical services and to codes of conduct generally applicable to personnel at the Health Sciences, including those provided in the University’s Faculty Handbook and its personnel policies.
Columbia University Billing Compliance Plan
September 9, 1996 (with amendments to October 2003)
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