This Compliance Plan is intended to be flexible and readily adaptable to changes in regulatory requirements and in the health care system as a whole. The Plan is regularly reviewed to assess whether it is working. The Plan is changed as experience shows that a certain approach is not effective or suggests a better alternative. Recommendations for revisions to the Plan are suggested by representatives of the Dean’s Office, Internal Audit, General Counsel’s Office, faculty, and departmental and other administrators. Recommendations are considered by the Steering Committee and, if approved by the Steering Committee, are referred to the University’s Trustees for inclusion in the Plan.
Columbia University Billing Compliance Plan
September 9, 1996 (with amendments to October 2003)
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