Billing Compliance Manual
& Coding for Billing
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
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
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.
that Affect Billing Compliance
Stark (Physician Self-Referral Law)
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
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)
Claims Act Title 31
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
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
of Inspector General (OIG) Compliance Guidance
has a list of compliance program resources for hospitals, physician
practices, pharmaceuticals, third-party medical billing, etc.
Click here to access OIG
- Compliance Guidance
Physicians in Teaching Settings
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
& State Billing Manuals
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
The Oklahoma Health Care
Authority provides rules for documentation, coding and billing for
reimbursement under the OHCA program. Click here to access
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