Retention of Compliance Training Records Policy

Columbia University Irving Medical Center’s Office for Billing Compliance will retain Compliance and Fraud Waste and Abuse training records for all providers and staff for a period of ten years in compliance with 42CFR 422.504(d).

Training records are housed in our training databases and hard copy back-up is housed in our office for current records (up to 10 years) and at our storage facility after ten years. The storage facility is accessible within 24 hours of request for the documents.

Process for Notification of Excluded Providers and Allegations of Fraud, Waste and Abuse

  1. Office for Billing Compliance will receive the exclusion runs on a monthly basis.
     
  2. OFBC reviews and verifies that any person on the exclusion list is actually a provider or employee of Columbia. This entails some additional verification and contact by the OFBC.
     
  3. If identified as excluded, then notifications to be sent to:

           A. Faculty Affairs, if Provider
           B. Human Resources, if provider or staff
           C. Departmental leadership, if staff employee

     
  4. After HR and Department or Faculty Affairs has been informed and determined what the course of action will be.
     
  5. Notification to EPIC to hold all billing of provider and to remove access to the sign on process to the billing system for both provider and/or employee.
     
  6. Notify Columbia Doctors, Departmental leadership and the Enrollment group – to begin disenrollment, if necessary.
     
  7. Columbia Doctors enrollment group will notify the health plan.
     
  8. The Office for Billing Compliance will conduct an investigation into any allegation of fraud, waste and abuse.  If sufficient evidence is found of fraud, waste and abuse, we will follow up with a report to the appropriate parties with recommendations and notification to EPIC, Leadership and the health plan.

 

 

Office for Billing Compliance
Policy#: OFBC 10024
Original Date of Issue: 1996
Revised: 3/22/2023
Reviewed: 3/1/2024