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Standards of Conduct

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Anti kickback Law & Safe Harbor Fact Sheet

Antidumping Bulletin

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Supervising Physicians in Teaching Settings










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Billing Compliance Manual



Medical/Dental Documentation
& Coding for Billing

The Medical/Dental Documentation and Coding for Billing Compliance manual is provided for the University of Oklahoma faculty and staff. You must enter your campus user ID to access this page.  Click the bolded title below to access the manual.

You will be prompted to enter your OU or OUHSC Username ID to access the pages within this site.  To log in, you will be required to use your campus computer user ID.  Here are a few examples of the required format to log in:

enter your OUHSC user id and password

enter your OUHSC user id including domain - example: OUHSC\jsmith and your password

OU-Norman account   "4 + 4" and password

OU-Norman account   "4 + 4" including domain - example: SOONER\smit9988 and password

If you do not have an OU or OUHSC email account or are unsure of your username and/or password, please contact The Billing Compliance Office

Billing Compliance Manual ~ Policy & Procedures


Policies & Procedures

Policies and procedures for the University of Oklahoma are currently under construction.  However, to access the OU/OUHSC Compliance Program, please click on Compliance Program.  To access the Standards of Conduct from the OU/OUHSC Compliance office, please click on Standards of Conduct.

OU Physicians has their own set of policies and procedures which may be accessed through the intranet on campus computers.  To access the OU Physicians policies and procedures web site, please click on OUP Policies.


Regulations that Affect Billing Compliance

Stark (Physician Self-Referral Law)

Summary:  Stark Law prohibits referring a Medicare patient for any health service to an entity which the provider (or an immediate family member) has a financial interest unless an exception applies.  The entity that receives a prohibited referral may not bill Medicare for services performed.  The original Stark Law (Stark I) was enacted in 1989 and basically referred to clinical laboratory services.  In 1993, Congress broadened the Stark law (Stark II) to include referrals of a broad array of health services.  Click here to access information from CMS on Stark

False Claims Act

Summary:  The False Claims Act 31 U.S.C. sec. 3729-3733, protects the federal government against fraud and abuse.  Under the False Claims Act (FCA), anyone who knowingly submit, or causes another person or entity to submit, or knowingly makes, uses, or causes to be made or used, a false record or statement to get a false or fraudulent claim paid or approval of government funds are liable for three times the government's damages plus civil penalties of $5,500 to $11,000 per false claim.

The term "knowingly" means that a person:

1.  has actual knowledge of the information;
2. acts in deliberate ignorance of the truth or falsity of the information; or
3. acts in reckless disregard of the truth or falsity of the information, and no proof of specific intent to defraud is required.

The FCA contains qui tam, or whistleblower, provisions which allow anyone with evidence of fraud to sue on behalf of the government, in order to recover overpayments of federally funded health care programs.  The Department of Justice can investigate and decide whether to join the action.  If the government elects not to intervene, the qui tam relator may proceed with the action.  The whistleblower may be awarded a percentage of the recovered funds.

For a complete detail of the FCA for OU/OUHSC, please click on False Claims Act
For further details, access Department of Justice resources on the False Claims Act, click on the link(s) below -

False Claims Act Title 31

False Claims Report

Anti-Kickback Statue

Summary:  The federal anti-kickback law's main purpose is to protect patients  and federal health care programs from fraud and abuse.  The law states that anyone who knowingly and willfully receives or pays anything of value to influence the referral of federal healthcare business, including Medicare and Medicaid, can be held accountable for a felony.  Click here to access OIG Anti kickback Law and Safe Harbor Regulations Fact Sheet


Antidumping Bulletin

SUMMARY:  Special Advisory Bulletin addressing requirements of the patient anti-dumping statute and the obligations of hospitals to medically screen all patients seeking emergency services and provide stabilizing medical treatment as necessary to all patients, including enrollees of managed care plans, whose conditions warrant it.   Click here to access full antidumping bulletin


Office of Inspector General (OIG) Compliance Guidance

The OIG has a list of compliance program resources for hospitals, physician practices, pharmaceuticals, third-party medical billing, etc.  Click here to access OIG - Compliance Guidance

Supervising Physicians in Teaching Settings

Summary:  Section 15016, Supervising Physicians in Teaching Settings, was revised to clarify the documentation requirements for evaluation and management (E/M) services billed by teaching physicians. The revised language makes it clear that for E/M services, teaching physicians need not repeat documentation already provided by a resident. In addition, the revisions clarify policies for services involving students and other issues and update regulatory references.  Click here to access  Supervising physicians in teaching settings


Federal & State Billing Manuals

Medicare Carriers Manual

Program instructions are day-to-day operating instructions, policies, and procedures based on statutes and regulations, guidelines, models, and directives.  They are used by CMS program components, contractors, and State survey agencies to administer CMS programs.  For many others, they are a good source of technical and professional information about the Medicare and Medicaid programs. Click here to access the CMS site by clicking on CMS Manual System




Medicaid Manual

The Oklahoma Health Care Authority provides rules for documentation, coding and billing for reimbursement under the OHCA program.  Click here to access the OHCA Rules


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Healthcare Billing Compliance Office

Oklahoma City -
920 Stanton L. Young Blvd
Williams Pavilion, Ste 1230
Oklahoma City, OK 73104
Telephone: 405-271-1528
Fax: 405-271-2499


Tulsa -
4502 E 41st  ST, Ste 2G02
Tulsa, OK 74135
Telephone: 918-660-3627
Fax: 918-619-4058

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Last update 01/05/2015

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