As a general matter, questions about billing issues should be presented initially to one of the departmental compliance leaders. The training materials also informs University employees and billing personnel that they may report to the Office of Billing Compliance or the Director any activity that they believe to be inconsistent with University policies or legal requirements regarding billing. The materials explains how those persons can be contacted. Employees who report in good faith possible compliance issues are not subjected to retaliation or harassment as a result of the report. Concerns about possible retaliation or harassment should be reported to the Director.
The Director maintains a log of compliance concerns that are reported directly to the Chief Compliance Officer or to the Director. This log records the issue, the departments or divisions affected and the resolution. Each month, a copy of this log is provided to the Chief Compliance Officer and each quarter to the University’s internal auditor. The log reports should note any issues that remain open. This log should be treated as a confidential document and access should be limited to those persons at the University who have responsibility for compliance matters.
A hotline for the submission of anonymous complaints about billing compliance is monitored each business day by Office for Billing Compliance personnel.
Columbia University Billing Compliance Plan
September 9, 1996 (with amendments to October 2003)
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