Objective

The objective of the Columbia University Irving Medical Center (sometimes referred to as “CUIMC” or the “University”) Billing Compliance Program is to promote and ensure that the University’s affairs are conducted in accordance with applicable laws and regulations regarding professional fee billing. CUIMC is dedicated to providing high quality medical education, research, patient care and service to the community. An integral part of this mission is the obligation of every member of the CUIMC community, including each physician, non-physician practitioner (“NPP”) and staff member (and any affiliate or contractor corporation, organization or other entity, including any external billing company) that generates codes, submits, or is in any way involved in generating a bill for medical services, to act ethically and legally, and to document and bill for professional services appropriately and in accordance with applicable laws and regulations. Members of the CUIMC community also are expected to respect private and confidential information and to adhere to laws and regulations governing the privacy and security of patient health information and billing for items or services furnished in connection with human subject research.

The University’s Billing Compliance Program is governed and guided by the CUIMC Billing Compliance Plan and subject to applicable Federal and State Laws and regulations.

CUIMC Billing Compliance Plan

The University’s Billing Compliance Plan has been in place since 1996. The Plan has been amended from time to time and reviewed periodically.  The University’s Billing Compliance Plan applies to: (1) all CUIMC physicians, faculty and other health professionals involved in the provision of professional services (“CUIMC clinicians”); (2) any persons, corporations, organizations or other entities, including external billing companies, who are involved in professional fee billing for CUIMC clinicians (“billing personnel”); (3) any administrative personnel who are involved in implementing CUIMC’s compliance efforts (“administrative personnel”); and (4) clinical research staff.

Federal and State laws and regulations

In addition to our Billing Compliance Plan, we are governed by a number of important laws and regulations, including Federal regulations for teaching hospitals; Federal and State fraud and abuse prohibitions, anti-kickback and physician self-referral laws; the Affordable Care Act, Federal and State False Claims Acts, including whistleblower protections; the Federal Deficit Reduction Act; and New York State Medicaid compliance program requirements.

This Billing Compliance Manual is intended to summarize, for easy use and reference, the compliance principles and organizational structure set forth in the Billing Compliance Plan and applicable Federal and State laws and regulations. The Manual is also intended to update, amplify and explain certain requirements and processes at the University, and to cross-reference related legal and institutional requirements, including policies of Columbia Doctors

For additional information or to address specific compliance questions or concerns, please contact:

The Office for Billing Compliance, Columbia University Irving Medical Center
P & S Box 157
New York, NY 10032
United States
The Office of the General Counsel, Columbia University
535 West 116th Street
New York, NY 10027
United States