Detection and Prevention of Fraud, Waste and Abuse The Federal Deficit Reduction Act of 2005

Policy Statement

This policy outlines the University's protocols for preventing and detecting any clinical billing fraud, waste or abuse in its organization, consistent with the requirements of the Federal Deficit Reduction Act of 2005.

Reasons(s) for the Policy

Columbia University is committed to complying with the requirements of Federal and State law, including Section 6302 of the Federal Deficit Reduction Act of 2005, and to preventing and detecting any fraud, waste, or abuse in its organization in connection with government health care programs. Columbia University maintains a compliance program and strives to educate its employees, contractors and agents on fraud and abuse laws, including the importance of submitting accurate claims and reports to the Federal and State governments.

  Primary Guidance to Which This Policy Responds

There is not a primary policy to which this policy responds.  It is consistent with applicable law and best practices.

Responsible University Office & Officer

The Columbia University Medical Center Office for Billing Compliance is responsible for the maintenance of this policy, and for responding to questions posed regarding this policy.   The CUMC Chief Compliance Officer is the Responsible Officer. 

Revision History

This policy was established in November 2007.

Who Is Governed By This Policy

All staff and faculty at Columbia University Medical Center -- or anyone working on behalf of Columbia University -- involved with the submission of accurate claims and reports to the Federal and State healthcare programs are governed by this policy.

Who Should Know This Policy

All staff and faculty at Columbia University Medical Center, as well as any business partners, agents and vendors, involved with the submission of claims and reports to the Federal and State governments.

Exclusions & Special Situations

None.

Policy Text

Columbia University prohibits the knowing submission of a false or fraudulent claim for payment from a Federal or State funded health care program.  Such a submission is a violation of Federal and State law and can result in significant administrative and civil penalties under the Federal False Claims Act, a Federal statute that allows private persons to help reduce fraud against the United States Government.

To assist Columbia University in meeting its legal and ethical obligations, any employee who reasonably suspects or is aware of the preparation or submission of a false claim or report or any other potential fraud, waste, or abuse related to a Federal or State funded health care program is required to report such information promptly.  Reports may be directed to:

(i) the employee's supervisor or vendor's business partner;

(ii) Chief Compliance Officer;

(iii) Compliance Hotline at 866-627-3768 or 212-305-7739 (physician billing); or

  (iv) online at https://www.submitreport.com/columbiauniversity.jsp?langRequested=0

Any employee or vendor of Columbia University who reports such information will have the right and opportunity to do so anonymously and will be protected against retaliation for coming forward with such information both under Columbia University's internal compliance policies and procedures and Federal and State law.  However, Columbia University retains the right to take appropriate action against any such individual(s) who has/have participated in a violation of Federal or State law or University policy.

As an organization, Columbia University commits itself to investigate any suspicions of fraud, waste or abuse swiftly and thoroughly and requires all employees to assist in such investigations.  If an employee believes that his/her Supervisor is not responding to his or her report within a reasonable period of time, the employee shall bring these concerns to the Chief  Compliance Officer, or call the Compliance Hotline at 866-627-3768 or 212-305-7739 (physician billing).  Failure to report and disclose or assist in an investigation of fraud and abuse is a breach of the employee's obligations to Columbia University and may result in disciplinary action.

A Summary of Federal and State Laws regarding Fraud and Abuse follows this policy.  Notably, certain laws enable individuals to bring their concerns of fraud and abuse directly to the government.  Columbia University urges all employees and business partners to bring their concerns to the University first so that it can redress and correct any potentially fraudulent activity.  Further information relating to Columbia University's policies for detecting and preventing fraud are available online at:

Columbia University Administrative Policy Library: http://www.columbia.edu/cu/administration/policylibrary/az_index/index.html#D

Physician billing at Columbia University Medical Center:    http://www.cumc.columbia.edu/dept/compliance/index.html  

The physician billing compliance manual is also available online http://vesta.cumc.columbia.edu/compliance/Compliance_Manual_3_1_07.pdf