Code of Conduct for Billing Compliance

Objective

To obtain a written commitment from all CUIMC clinicians and billing personnel, consultants, or contractors to act legally and ethically in furtherance of their work at CUIMC.

Policy

All CUIMC clinicians and billing personnel, consultants, or contractors are required to sign the CUIMC Code of Conduct. Signed copies are maintained by the OFBC. The basic principles of the Code of Conduct are:

  • Be honest and ethical, which includes following ethical standards promulgated by applicable professional organizations. Treat all patients and their families with dignity and respect at all times.
  • Obey the law. If you are uncertain about what the law or applicable regulations require, seek assistance from your department’s compliance personnel or the OFBC, 212-305-3842.
  • Be truthful. Document all care that you give timely, accurately, and completely.
  • Bills to patients and payors should reflect appropriate charges, be based on services actually provided, and be supported by documentation in the medical record.
  • Do not accept or pay kickbacks, or offer or accept any payment for referrals. Physicians must comply with applicable prohibitions on self-referrals.
  • Honor patient confidences. Patients rightfully expect that their private medical information will be handled appropriately and discretely. Confidential information concerning University matters also must be protected.
  • Report conduct that concerns you. If you believe that an activity may be illegal, unethical or otherwise troubling, report it. You may report to your Departmental Compliance Leaders, the OFBC, the Chief Billing Compliance Officer, or the University-wide compliance hotline. There is a policy of non-retaliation for any good faith report of possible improper activity.

Enforcement

An individual’s failure to live up to these principles will result in disciplinary action, up to and including termination, consistent with University policy. For violations of applicable laws individuals may also face criminal and civil penalties, including monetary penalties. Failure on the part of the University to fulfill its legal obligations, including the requirements of Federal health care programs, may result in exclusion from participation in such programs, as well as other criminal and civil penalties, including monetary penalties.

 

Office for Billing Compliance
Policy#: OFBC 1006
Original Date of Issue: 1996
Revised: 3/22/2023
Reviewed: 3/1/2024