Mission

The University of Rochester Medical Center Compliance Office promotes and supports a culture to build compliance consciousness into every employee's daily activties. This is accomplished through the implementation and maintenance of a Corporate Compliance Program that:

Establishes standards of performance for all employees to conduct business with honesty and integrity.

Offers easy access to staff, managers and faculty for guidance, education and incident reporting.

Monitors adherence to applicable federal, state and local laws, regulations, guidelines and program requirements.

Components

The Corporate Compliance Program developed a network of individuals committed to educating and assisting faculty and staff to proactively incorporate compliance at the department, division and/or individual position levels. These individuals include:

Corporate Compliance Officer, Frederick Holderle
Compliance Program Medical Director, Paul Levy, M.D.
Compliance Analysts/Educators assigned to each department
Departmental Compliance Liaisons

A variety of guidelines and tools are available to support individuals in their duties and responsibilities. Internal plans, policies and tools include a Code of Conduct, Compliance Program Policy Manual, Compliance Plan, Billing Compliance Plan, E&M Documentation Guides, Non-Physician Practitioner Billing Guidelines, documentation and coding hints, and summaries for appropriate coding of specific services. Some of the external guidelines, policies and regulations available through the Compliance Office are CMS Teaching Physician Guidelines, 1995 and 1997 E&M Documentation Guidelines and New York State Medicaid Guidelines and updates.

The compliance program applies a proactive auditing and monitoring process to identify potential errors in billing for services. The program utilizes many resources both internal and external to establish a list of risk areas. One key resource is URMC employees. Therefore, the program maintains both an open door policy and an Integrity Hotline. Employees who have any concern about whether a practice is proper and/or ethical should speak with their supervisor or manager, the Compliance Officer, a Compliance Office Analyst/Educator or the Integrity Hotline. Anonymous reports to the Integrity Hotline are accepted.

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