The University of Michigan Health System has an ongoing commitment to ensuring its affairs are conducted in accordance with applicable laws. UMHS also has a strong interest in making certain its faculty and employees are fully informed about applicable laws and regulations to prevent conduct – whether intentional or unintentional – that may raise compliance issues.
Since many faculty members engage in clinical practice, legal requirements relating to professional fee billing are of particular concern.
This site provides faculty, physician assistants, nurse practitioners, administrators and billing staff with the tools and resources they may need to assist them with documenting and billing for clinical services.
Compliance in this area is challenging because the regulatory requirements governing professional fee reimbursement are complex and subject to change. To further its commitment to compliance and to protect its employees, the FGP has adopted a formal Compliance Program to address professional fee reimbursement. This Compliance Program has the following key features:
- Conduct internal monitoring and reviews with regard to professional fee billing;
- Designate a compliance officer or contact;
- Incorporate standards and policies that guide UMHS personnel and others involved with the billing process with regard to professional fee billing;
- Coordinate training of clinical staff and billing personnel concerning applicable billing requirements and UMHS policies;
- Develop a uniform mechanism for employees to raise questions and receive appropriate guidance concerning professional fee billing;
- Respond appropriately to detected offenses and develop corrective action;
- Develop open lines of communication; and
- Enforce disciplinary standards through well-publicized guidelines.
The professional billing compliance program described is intended to establish a framework for legal compliance by UMHS and its employees. It is not intended to set forth all of the substantive programs and practices of UMHS or the University that are designed to achieve compliance. The University already maintains and/or is developing various compliance practices and those practices continue to be part of its overall compliance efforts. UMHS intends that this professional billing compliance program embrace all elements of an effective program to prevent and detect violation of law.