Audit Policy

Objective

To ensure compliance procedures are followed across all clinical departments and to create an audit trail for billing compliance activity.

Policy

CUIMC, through the OFBC and individual departments, will conduct the following types of audits.

• Routine Audits – Conducted by each department as a matter of routine compliance activity. These reviews are the subject matter of the quality assurance audits by the OFBC.
   
• Sample Quality Assurance Audits – Conducted on a routine basis by the OFBC Compliance Manager. The audit is conducted on services already reviewed.
   
• Investigative Audits –Investigative audits can consist of a review of such documents as billing reports and medical records. Reports of Investigative Audit outcomes are shared with leadership, administration, personnel from the relevant department, and other appropriate parties at the University.
   
• Pre-Billing Review Audits – are conducted for all new providers.
   
• Federal or State Initiated Focused Audits – Conducted upon receipt of governmental requests for documentation or refunds. The OFBC will coordinate and assess all documentation to be submitted to the Federal or State government and will assist the relevant department in formulating a response to the audit.
   
• Outsourced Billing and Coding Activity Audits – Conducted by OFBC on a regular basis to review a sample of documents coded by outside vendors. The OFBC shall develop any necessary Corrective Action Plan, and departmental compliance staff shall conduct associated quality assurance monitoring and report the results of that monitoring to OFBC.
   
• Research Billing Compliance Audits – Conducted by the OFBC on a regular basis to assess services for correct allocation of billing both to grants and to insurance companies.
   

Office for Billing Compliance
Policy#: OFBC 10015
Original Date of Issue: 1996
Revised: 3/22/2023
Reviewed: 3/1/2024