Organization

The University has designated certain individuals and offices to execute and oversee its Billing Compliance Program.

  • Chief Billing Compliance Officer: The Chief Billing Compliance Officer is designated by the Executive Vice President and Dean of the Faculties of Health Sciences and Medicine. The Chief Billing Compliance Office has primary responsibility for implementation and managing the University’s billing compliance effort, including but not limited to supervising audits, both internal and external, to evaluate compliance and assisting in addressing compliance issues that arise in the course of audits or otherwise.
     
  • Office for Billing Compliance (“OFBC”): The University maintains an OFBC, which, under the supervision of the Chief Billing Compliance Officer and the Director of the OFBC: (1) assists in the review, revision and formulation of appropriate policies to guide billing of professional fees for services provided by CUIMC clinicians; (2) reviews Federal and State Compliance Program Guidance, work plans, special advisory bulletins and special fraud alerts from the Health and Human Services Office of Inspector General (“OIG”) and the New York State Office of Medicaid Inspector General (“OMIG”) to identify risk areas and the need for changes in billing procedures; (3) works with the Columbia Doctors departments and CUIMC clinicians to develop plans for implementing CUIMC policies on billing; (4) develops and delivers billing-related educational training to University personnel: (5) coordinates review of medical charts and related billings; and (6) coordinates (with other departments, including the Office of the General Counsel) any repayments and other responses to identified billing issues; and (7) maintains compliance and refund logs.

 

The OFBC staff includes several managers (“Compliance Managers”), each of whom is assigned responsibility for the oversight of several clinical departments.

  • Departmental Compliance Personnel: There are also compliance personnel within each clinical department. Each clinical department develops a work plan based on an annual departmental risk assessment and some large departments may develop plans for specific divisions. Each department appoints a faculty member and a departmental implementation plan administrator (collectively the “Departmental Compliance Leaders”), and some clinical departments have additional compliance staff members.
     
  • Office of the General Counsel: The University’s Office of the General Counsel provides professional legal assistance and support for the Compliance Program, including involvement in responding to any identified problems/issues are identified.
     
  • Privacy Office: Provides professional guidance and assistance in matters of privacy and related matters. The University maintains a Privacy Office, which includes a Privacy Officer and additional support staff. The Privacy Office is responsible for overseeing CUIMC’s compliance with applicable privacy laws, rules and regulations, including but not limited to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and regulations promulgated thereunder and the Health Information Technology for Economic and Clinical Health Act. Title XIII of the American Recovery and Reinvestment Act of 2009 and regulations promulgated thereunder (“HITECH”).

 

 

 

 

Office for Billing Compliance
Policy#: 1002
Original Date of Issue: 1996
Revised: 3/22/2023
Reviewed: 3/1/2024