Corrective Action Policy

Objective

To ensure that any instances of non-compliance with University policies or billing requirements are addressed and corrected in a prompt and appropriate manner.

Policy

At the discretion of the OFBC, any instance of non-compliance with University policies or billing requirements shall be addressed and corrected by a Corrective Action Plan formulated by the Chief Billing Compliance Officer. The OFBC will work with the appropriate Departmental Compliance Leaders to ensure that the plan is instituted and that the practice at issue is corrected. The Departmental Compliance Leaders are responsible for subsequent monitoring of the Corrective Action Plan and related activity within the applicable department(s) with timely reporting to the Chief Billing Compliance Officer and the OFBC.

  • Compliance issues identified by the OFBC, or by others and brought to the attention of OFBC, will be handled exclusively by the OFBC (unless involvement of the Office of General Counsel is appropriate) and will otherwise be subject to applicable University policy.
     
  • Typically, the OFBC will review the practices in question and, if appropriate, will formulate a Corrective Action Plan for immediate implementation. In most instances, the OFBC will meet with individual practitioners or staff involved and/or with departmental leadership and present the Corrective Action Plan. In some cases, a meeting may not be practicable, and the OFBC will present a written plan to departmental leadership in lieu of a meeting.
     
  • A Corrective Action Plan may include any or all of the following:
  1. a period of pre-billing review of the relevant practitioner or department’s charges;
  2. repayment of any associated overpayments;
  3. retraining or re-education of practitioners and staff;
  4. a written letter of warning or reprimand;
  5. imposition of terms of probation; and/or
  6. a recommendation of the restriction, suspension or termination of employment and/or University appointments, in accordance with University policy.
  7. Employees also should be aware that the law may provide for monetary and criminal penalties.

 

Office for Billing Compliance
Policy#: OFBC 10016
Original Date of Issue: 1996
Revised: 3/22/2023
Reviewed: 3/1/2024