Compliance & Privacy Office

Compliance FAQ

If a Department Has Engaged a Vendor to Perform a Separate Departmental Audit, Does This Need to be Approved or Reviewed by CPO?

The WCM Annual Compliance Plan FY2021 (page 7) sets forth the requirement for clinical departments to obtain approval from the Compliance Officer for any external reviews, audits, or coding services prior to the engagement.

Why Were WCM Audits not Held in the Initial Months of the Pandemic When Codes Were Changing Constantly, While Even Medicare Placed a Hold on Their Audits?

While the billing compliance activity did not come to a halt, the activity level was reduced in 2020. The reviews that were performed provided the institution with the awareness that billing integrity was being preserved during the dynamic and challenges associated with the pandemic. Also keep in mind that payers have the right to audit claims retrospectively and because they may have stopped doing so for a period in 2020, the services submitted during that time could still be subject to a retrospective review. 

How Will Services Rendered in Locations not in EPIC, i.e., Methodist, Westchester, etc. Be Handled as Part of the New Audit Process?

The Billing Compliance program encompasses all WCM providers who have professional fee billing activity regardless of where they document their patient services. Timely access to records needed for an audit will be expected. See page 7 of WCM Annual Compliance Plan FY2021.

 

Do Department Repercussions Need to be the Same or Can They Choose to Be More Strict or Less Strict?

The WCM Annual Compliance Plan FY2021 (page 11), outlines disciplinary guidelines for the Departments to follow.

Can Departments Continue to Handle Their Own Onboarding Training for New Providers in Conjunction with the CPO? Required Courses?

It is very important that the departments continue to provide the department and specialty-specific onboarding training to new providers to supplement the Compliance Program general training. 

Submit Compliance Incident

Weill Cornell Medicine Compliance & Privacy Office 575 Lexington Avenue, 9th Fl New York, NY 10022 Phone: (866)-293-3077