Detection and Prevention of Fraud

Objective

To comply with Section 6032 of the Deficit Reduction Act of 2005 (“DRA”), which requires that State Medicaid Plans be amended to require certain types of health care providers to establish written policies that address the following:

  1. the Federal False Claims Act, 31 U.S.C. 3729-3733 (“FCA”);
  2. the administrative remedies for false claims and statements found in the Program Fraud Civil Remedies Act, 31 U.S.C. 3801-3812;
  3. State laws pertaining to civil or criminal penalties for false claims and statements;
  4. the whistleblower protections provided under both Federal and State laws, and the role of these laws in preventing and detecting fraud, waste and abuse; and
  5. the health care provider’s policies and procedures for detecting and preventing fraud, waste and abuse.

Policy

Federal and State Laws Relating to False Claims and Whistleblower Protections

CUIMC shall make available to all University faculty and staff written materials providing detailed information about the FCA and other Federal and State false claims laws and whistleblower protections by including summaries of those laws and protections in (1) Exhibit A to this Manual, and (2) any Employee Handbook published for employees of CUIMC.

Policies and Procedures for the Prevention and Detection of Fraud, Waste, and Abuse

University policies and procedures that address the prevention and detection of fraud, waste, and abuse include, without limitation:

  • CUIMC Billing Compliance Plan
  • CUIMC Manual of the Office for Billing Compliance
  • Annual CUIMC billing compliance training
  • Individual Department or Division Billing Risk Assessments

All CUIMC faculty staff have an obligation to conduct themselves in accordance with all applicable laws and regulations, and to report actual or potential instances of fraud, waste, and abuse. Faculty or staff who have questions or concerns regarding the prevention and detection of fraud, waste, and abuse should consult with their respective Departmental Compliance Leaders or contact the OFBC at 212-305-3842.

Reporting of Compliance Concerns

Any member of the CUIMC community who knows or reasonably believes that the University or any of its employees or contractors may be involved in any activity that is prohibited by the FCA or other Federal or State fraud and abuse laws is required to immediately report such knowledge or belief using established University reporting procedures, which include reporting the matter to the Departmental Compliance Leaders, the OFBC, the Chief Billing Compliance Officer or the CUIMC Compliance Hotline.

Non-Retaliation

The University will not take, or tolerate, any intimidating or retaliatory act against an individual because the individual, in good faith, makes a report of practices reasonably believed to be improper. See Columbia University Non-Retaliation Policy.
 

Compliance Monitoring

As detailed throughout this Manual, the University has established internal systems and controls to monitor its coding and billing practices on an ongoing basis to ensure compliance with FCA and other fraud and abuse laws.

 

 

Office for Billing Compliance
Policy#: OFBC 10011
Original Date of Issue: 1996
Revised: 3/22/2023
Reviewed: 3/1/2024