College of Medicine Compliance
Intro Heading link
With the advent of increase government regulations, the College of Medicine must ensure that we are compliant with applicable federal, state and other regulatory requirements. The College of Medicine (COM) Compliance Program provides a framework for adherence to all pertinent regulations, and a mechanism for preventing and/or reporting a breech in Compliance.
Compliance Plan Heading link
Key Elements of the COM Compliance Program Heading link
- Implementing written policies/procedures and guidelines;
- Designating a compliance officer/contact;
- Conducting comprehensive training and education;
- Developing accessible lines of communication;
- Conducting internal monitoring and auditing;
- Enforcing standards through well-publicized disciplinary guidelines; and
- Responding promptly to detected offenses and undertaking corrective Action
COM compliance personnel audit, monitor and conduct investigations into Compliance issues as necessary. Yearly concurrent and retrospective provider documentation audits are conducted by the compliance auditors and OCC coders per set schedules determined on an annual basis.
In addition, individual and group training on compliance issues is available by contacting the Director of Compliance or any of the compliance/coding auditors listed under the resources section.
Each department has designated a Departmental Compliance Liaison (DCL) to handle implementation and oversight of compliance with the guidance and oversight from the COM Director of Compliance. (See Resources).
UIHHS Compliance Hotline Heading link
Please use the UIHHS Compliance Hotline to report improper conduct, illegal actions, fraud and abuse.
Available 24 hours a day, is Anonymous and Confidential
Useful Resources Heading link
5-Minute Training Videos
View the training videos:
Compliance Educational Tools/Tips
Department Compliance Liaisons
Please click on the link below to see the list of liaisons.
Frequently Asked Questions Heading link
How do I bill a discharge day management code when I discharge my patient on day one, but dictate my notes on day 2? Which day do I use for submitting the claim?
The discharge day management service is billed under the actual discharge date. The medical records should clearly state the date of the actual discharge, and also indicate that the dictation was made on the following date.
How do you bill for a patient that has expired?
The Centers for Medicare and Medicaid Services (CMS) advises that according to established legal principles, an individual is not considered deceased until there has been official pronouncement of death. Reasonable and necessary medical services rendered up to and including pronouncement of death by a physician are covered diagnostic or therapeutic services.
Why are our claims for Hospital Discharge Day Management being reduced from 99239 to 99238?
Hospital discharge day management codes 99238 (30 minutes or less) and 99239 (more than 30 minutes) are time based so it is imperative that the medical documentation reflect the total time spent by a physician during the discharge of a patient. The codes include, as appropriate, final examination of the patient, discussion of the hospital stay, (even if the time spent by the physician on that date is not continuous), instructions for continuing care to all relevant caregivers, and preparation of discharge records, prescriptions and referral forms.
Can a physician bill for an initial visit when a patient goes from observation to admission?
Yes, an initial inpatient visit may be billed. Medicare payment for the initial hospital visit includes all services provided to the patient on the date of admission by that physician, regardless of the site of service. The physician may not bill an initial observation care code or an observation discharge management code for services on the date that he or she admits the patient to inpatient status.
If the physician states same/unchanged from last visit, will he receive credit for reviewing the last visit information?
Credit may be taken only if the physician includes the documentation from the previous visit.