Business Practices

Billing & Coding Integrity

We are committed to accuracy in coding and billing practices and to compliance with all governmental and third-party payer requirements.
We do not allow anyone who has been excluded from government health care programs to participate in OSU Medicine health care programs.
We REQUIRE our employees and other associates to report any activity that is potentially fraudulent or unethical using the appropriate reporting mechanisms.
We conduct quarterly coding audits for all OSU Medicine Providers through our vendor at the American Academy for Professional Coders (AAPC). Each Provider will have 10 encounters audited per calendar year. Based on the coding accuracy of those encounters, Providers might be assigned additional audits as necessary. We also assign audits as necessary in response to alleged discrepancies and notices from regulatory authorities. We also provide various training opportunities through AAPC, which can be scheduled through the Compliance Office.

OSU-CHS REPORTING INFORMATION

• We follow federal and state laws and OSU Medicine policies and procedures to ensure our clinical billing, coding and documentation
are performed accurately and timely.
• We do not present or cause to be presented any false, fictitious or fraudulent claims.
• We promptly report any suspicion of false, fictitious or fraudulent claims.
• We bill only for services that are actually provided, are medically necessary and are ordered by appropriately licensed individuals.
• We adhere to teaching physician billing requirements.
• We assign proper codes that accurately reflect the services provided.

• We cooperate fully with government and other payer auditors and their agents. We provide accurate and complete information to which auditors are entitled during an inspection or inquiry.
• We maintain appropriate and timely documentation to support coding and billing and respond to audit findings appropriately.

Conflicts of Interest

We promptly identify and manage any actual, potential or perceived Conflict of Interest. A Conflict of Interest is a situation in which an individual’s private interests — financial or otherwise — may compromise or have the appearance of compromising the individual’s ability to make objective decisions related to the individual’s responsibility to OSU.
OSU-CHS utilizes the COI-Smart site for Conflict of Interest disclosures
and management.

COI-SMART DISCLOSURE SITE

Any staff, faculty, resident, student or other associate who receives an annual COI Disclosure notification must complete the disclosure in the COI-Smart program within the timeframe designated. When a potential Conflict arises before the next disclosure is due, the disclosure must be updated within 15 days.
• Any OSU Medicine staff, faculty, resident, student or other associate who does not receive the notification, but has an actual, potential or perceived Conflict of Interest must request access to the program from the Compliance Office.
• Potential conflicts of interest include, but are not limited to:

o Owning a company that contracts or competes with OSU
o Using OSU resources for personal purposes
o Supervising a family member at OSU
o Serving as an investigator on a research study and having a significant financial interest in the company that sponsors the study

Gifts and Gratuities

We avoid even the appearance of undue or illegal influence in providing care for patients. We do not offer or accept gifts or favors in exchange for influence or assistance in a transaction. We discourage the acceptance of gifts from patients, but may accept gifts of nominal value, given as an expression of gratitude, on behalf of the entire care team.
We follow federal and state laws, OSU policies and the Oklahoma Ethics Commission Guide for State Officers and Employees with regard to the acceptance of gifts.

OKLAHOMA ETHICS COMMISSION GUIDE FOR STATE OFFICERS & EMPLOYEES

• We do not allow our medical judgment or business decisions to be influenced by gifts from pharmaceutical companies or vendors.
• We do not solicit tips or gifts from patients.
• If a patient insists on giving a nominal gift, such as a box of chocolates, it may be graciously accepted and shared with the care team. Patients who wish to give monetary gifts or gifts of more substantial value should be referred to the OSU Foundation.
• We do not accept money or anything of value in exchange for the purchase of goods or services or the awarding of contracts.
• Items that should not be accepted include, but are not limited to:

o Free sports tickets to an event from a patient or vendor
o A monetary tip for taking a patient in a wheelchair to a car

Referrals

We follow all laws and regulations to ensure that patient referrals are made solely on the basis of what is best for the patient seeking treatment.
We review all financial relationships with physicians and other health care providers for compliance with the Anti-Kickback Statute and the Stark Laws.
What is the Anti-Kickback Statute? A U.S. federal criminal statute that prohibits offering or receiving, directly or indirectly, remuneration (anything of value) to induce, or in exchange for, a referral of federal health care program business, including patients, items or services.
Example: A hospital provides free office space to a physician in exchange for referrals.
What is the Stark Law? A set of U.S. federal laws that prohibit a physician from referring Medicare or Medicaid patients for “designated health services” to an entity with which the physician or an immediate family member has a “financial relationship,” where no Stark exception applies.
Example: A doctor who invests in an imaging center may not refer patients to the center, and the entity may not bill for the services, unless the financial relationship fits within an exception.
• We do not offer financial incentives to anyone to increase referrals.
• We do not make payments or provide benefits, such as free office space, to a physician in return for referrals.
• All physician contractual relationships are reviewed by Legal Counsel and are fair market value for the services rendered.
• We contact OSU CHS Legal Counsel or the Compliance Office with any questions or concerns about physician arrangements.

Business Relationships

Only certain OSU executives are authorized to sign contracts on behalf of OSU Medicine. Any contracts signed by individuals who are not authorized by the President are void.
• A Business Associate Agreement must be executed for all business associates, as defined by HIPAA, to support protection of PHI being used to perform a service for OSU. All Business Associate Agreements should be kept on file with the Compliance Office.
• Employees who wish to receive care or medical advice from an OSU provider should do so by establishing a physician-patient relationship with the provider through scheduled appointments.