The Compliance Office, an independent entity within the School of Medicine, was established August 1, 1999. The Office is responsible for several oversight functions previously handled jointly by UNC P&A and the Dean’s Office. Its purpose is to assist UNC P&A physicians and other practitioners with complying with governmental regulations pertaining to medical record documentation and coding for billed services. The principal activities include:
- developing and maintaining a practice-wide compliance plan and assuring adherence to that plan
- conducting faculty and staff educational sessions on teaching physician regulations, documentation and coding of evaluation and management services and documentation of surgical and diagnostic procedures
- developing and maintaining electronic databases of faculty and staff participation in mandatory compliance-related training sessions
- conducting division-level, pre-bill medical record reviews of outpatient evaluation and management services, presenting results to division and department leadership and assisting with corrective action plans
- conducting pre-bill medical record reviews of inpatient services coded by the UNC P&A Charge Abstraction division
- monitoring trends over time through computer-based reporting-
- responding to audit requests from external agencies such as the North Carolina Medicare carrier
- investigating and resolving incidents which may be breaches in the School's compliance plan
- researching compliance-related issues with Medicare, Medicaid and other governmental and non-governmental third party payers
- maintaining a library of compliance-related source manuals and periodicals and serving as a resource and clearinghouse for researching and responding to compliance questions that arise from a variety of sources.
Although it is a separate agency, the Office works closely with several components of UNC P&A including Charge Abstraction and Coding, Reimbursement, the Claims Manager Coordinator and the Ambulatory Care operations staff. This association encourages collaboration regarding training activities and researching and communicating information on compliance- related issues.
The Compliance Office reports to the Executive Associate Dean for Clinical Affairs and the Executive Associate Dean for Administration and Planning. Through membership and participation in the UNC Health Care System Compliance Steering Committee, the Compliance Officer coordinates the School’s clinical compliance activities with those of UNC Hospitals. The Teaching Physician Oversight Committee (TPOC) chaired by the Executive Associate Dean for Clinical Affairs provides policy oversight for the Compliance Office. The TPOC membership includes nine faculty members, six of whom are department chairs, as well as the senior attorneys from the University and UNC Hospitals. Policy recommendations by TPOC, which subsequently are approved by the UNC P&A Board, become binding on the clinical faculty and relevant administrative staff of the School of Medicine.