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

Effective Date: December 11, 2007 

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

To see the full text of this policy, please use the link on the right.