The Office of Compliance

Compliance FAQ

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. 

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.

Is There Any Impact to Providers That have Been Grandfathered Out of EPIC?

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 is a requirement per the WCM Annual Compliance Plan.

Will Departments Continue to Get Audited by Internal Audit? What is the Difference Between Internal Audits and CPO Audits for Clinical Compliance?

Internal Audit has a very broad range of responsibilities over WCM business operations and financial controls. Billing Compliance operations focus on professional fee billing. Departments can expect ongoing support from both Internal Audit and Billing Compliance. 

If a Department Uses an Outsource Vendor for Coding Their Claims, Can the Same Outsource Vendor Be Used for Auditing?

No. For example, if a Department is using The Coding Network for coding support, then any compliance program risk-based audit assignment of a provider in that department would be performed by the internal billing compliance staff or a different coding vendor engaged by the Compliance Office.

Submit Compliance Incident

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