Policies and = Procedures

POLICY

The mission of UNMC Physicians is = to support=20 the University of Nebraska Medical Center in fulfilling its mission of=20 education, research, patient care, and outreach to underserved = populations. UNMC=20 Physicians has a reputation of integrity and excellence in teaching and = patient=20 care. This reputation is our greatest asset. Everything we are able to = achieve=20 depends upon the trust our patients and business associates place in=20 us.

UNMC Physicians requires all employees to conform to the = highest=20 ethical standards and meet all legal obligations in the performance of = their=20 duties. To support this requirement, UNMC Physicians has developed and=20 implemented a Professional Fee Billing Compliance Plan. The Standards of = Conduct=20 that follow are an integral part of the billing compliance plan. The = Board of=20 Directors entrusts the President of UNMC Physicians with the = responsibility to=20 oversee the compliance plan. The responsibility for administration and = operation=20 of the plan is delegated to the Director of Compliance and the Associate = Compliance Officer. If you have any questions or concerns about these = Standards,=20 please contact the UNMC Physicians Billing Compliance Office at=20 559-2417.

PROCEDURE

All employees of UNMC Physicians = should=20 strive to achieve professionalism as outlined in the University of = Nebraska=20 Medical Center Code of Conduct (Available on the Intranet at http://info.unmc.edu= /ombudsteam/conduct.htm).=20 We must adhere to the policies and procedures adopted by UNMC Physicians = (Relevant sections in the UNMC Physicians Policy and Procedures Manual: = "Privacy,=20 Confidentiality, & Security of Patient & Proprietary=20 Information", "C= onduct",=20 and "Grievance").=20 UNMC Physicians staff and employees will act within the highest ethical=20 standards and follow regulations related to billing for professional fee = services. The following Standards of Conduct are not intended to = comprehensively=20 define all actions of our employees, but rather to communicate UNMC = physicians=92=20 expectations of proper and professional conduct in accordance with our = core=20 values, and as related specifically to our billing practices in = connection with=20 UNMC Physicians=92 Professional Fees Billing Compliance Plan (UNMC = Physicians:=20 Professional Fee Billing Compliance Plan, January 1, = 2007).=20

Demonstrate = Integrity and=20 Ethical Behavior: Day-to-day contact with patients and other = employees=20 should be conducted openly and honestly. This includes all issues = concerning=20 billing. We must listen carefully and ensure we are being heard = correctly.=20 Treating = others with=20 impartiality, respect and civility will maintain and strengthen = the=20 public=92s trust and confidence in our organization, and in the = handling of=20 documentation and billing for the services we provide. Every = employee must=20 avoid using his or her position for personal gain and avoid any = actual or=20 potential conflict of interest.

Maintain and Protect = Confidentiality: Our patients trust that their private medical=20 information, including billing information, will be handled = appropriately=20 and in confidence. We must each protect the integrity and security = of=20 patient records, billing and all private information concerning = our=20 patients, and protect the dignity and privacy of the individual. = Employees=20 will not use confidential information in a manner that would bring = financial gain to themselves or create an unfair disadvantage for = another=20 person. Only the patient has the right to disclose or authorize = disclosure=20 of their private medical information.

Obey the law:. It is = each=20 employee=92s responsibility to be familiar with relevant laws and = regulations that=20 pertain to their duties, to participate in training available to = them, to=20 take the initiative for self-development of their billing = compliance=20 knowledge, and to perform their duties in accordance with the = applicable=20 laws and regulations. Unfamiliarity with = relevant=20 laws and regulations will not excuse violations. To support these=20 obligations, UNMC Physicians has developed policies and procedures = as well=20 as in-service training and will continually update employees on = changes in=20 legal requirements. Further assistance can be obtained from = supervisors,=20 by directing questions to the Compliance Office (physcompliance=20 @unmc.edu), or by querying the Director of Compliance directly by = phone or=20 by email.

Report any conduct = that=20 concerns you: All employees have an obligation to report activity=20 reasonably believed to be a violation of the law, = government=20 regulations, University of=20 Nebraska policies or = procedures, as=20 well as UNMC Physicians policies or procedures. Absolute certainty = need=20 not be required to report a perceived problem. Rather, reporting = problems=20 allows UNMC Physicians to investigate potential problems quickly = and to=20 take prompt action to resolve any issues. Reports may be made to = your=20 supervisor(s), the UNMC Physicians Compliance Office (by campus = mail or=20 email at physcompliance@unmc.edu), = the=20 Director of Compliance, the Associate Compliance Officer, the = Compliance=20 Officer, or the Compliance Hotline (1-866-699-9015). The identity = of the=20 person making such a report will be kept confidential to the = extent=20 allowed by law.

Truthfully maintain = records:=20 all billing, documentation and other communication on the behalf = of UNMC=20 Physicians will be accurately prepared and retained in accordance = with=20 requirements. = Particular care=20 must be exercised to ensure that all billing communications = between UNMC=20 Physicians and all outside agencies (including government = representatives)=20 are truthful, accurate, and=20 complete.

Approved=20 by

UNMC = Physicians=20 Directors

CAO

Related = Policies

CD18 Compliance Hotline=20 Policy

HR35 =20 Privacy, Confidentiality and Security of Patient and = Proprietary=20 Information

HR03 =20 Conduct

Rl01 =20 Organizational Code of=20 Ethics