University of Florida College of Medicine – Jacksonville Departmental Compliance Plans

• Department of Anesthesiology

Other Policies and Documents

• 1995 Evaluation and Management Physical Exam Clarification
• Advance Beneficiary Notice – Ambulatory Policy (06/2015)
• Application of the -52 Modifier to Surgical Procedures with Delayed Primary Closure (07/2020)
• Billing Compliance and Corporate Responsibility Hotline (08/2021)
• Billing Compliance Investigation Guidelines (08/2022)
  The Office of Compliance has prepared guidelines that will be followed when it assists in the review and investigation of allegations of billing non-compliance.
• Billing for Unenrolled Providers (04/2021)
• Billing Medicare as the Secondary Payor for Consultation Services (07/2020)
• Billing Medicare Part B for Critical Care | Appendix A
• Cancelled Surgical Cases and Associated Pre-operative EM Svcs (08/2021)
• Charge Posting and Billing Compliance Process (06/2020)
• College of Medicine Policy on Pharmaceutical, Medical Device, and Biotechnology Industry Conflict of Interest (03/2023)
• Consultation Payment Policy - Skilled Nursing Facility or Nursing Facility Location when Medicare is the Primary Payor (06/2020)
• Crediting "Alert & Oriented X 3" for Evaluation and Management Physical Examination (05/2022)
• Crediting a Prior Review of Systems and/or Past, Family and/or Social History (05/2022)
• Crediting Unobtainable History (05/2022)
• Code of Conduct (06/2022)
  All employees are required to conform to the highest ethical standards and to meet or exceed all legal obligations in the performance of their job duties. In this regard, the Code of Conduct has been developed to ensure our work is performed in an ethical manner and to remind us of our commitment to act responsibly and legally.
• Compliance Review Action Plans (03/2020)
• E/M Table of Risk and Parenteral Controlled Substances
• Federal and State False Claims Laws (01/2023)
• Global Compliance Issues Refund Process (05/2020)
• Instructions from Government Carrier Representatives (04/2020)
• Medicare and TriCare Incident-to Billing in Physician Based Settings (05/2022)
  This policy sets forth a procedure to be used to determine whether or not a service rendered in a physician-based setting (office - place of service code 11) can be billed to Medicare incident to a physician. Medicare guidance on incident to billing, as it relates to this policy, is contained within the Medicare Benefit Policy Manual (100-02), Chapter 15, Section 60.
• Medicare Teaching Physician Policy and the GC and GE Modifiers (05/2022)
• Mission and Goals
  This document outlines the mission, values and goals for the operations of the Office of Compliance on the Jacksonville campus.
• Nursing Facility E/M Services and the Use of Advanced Practice Professionals (05/2020)
• Nursing Facility Services and Place of Service Codes (07/2020)
• Online Digital EM Service Medicare Coverage (03/2020)
• Physician Co-Signatures on NPP Notes (02/2015)
• Physicians Furnishing Less Than the Full Global Package - Use of Modifiers 54 and 55 (03/2020)
• Policy Against Fraudulent or Other Dishonest Acts (02/2002)
• Provider Changes in Medicare Enrollment Information
• Remedial and Disciplinary Action Memo (01/2017)
  The University has internal remedial and disciplinary mechanisms that apply to instances of billing non-compliance and provide administrators with the flexibility to impose appropriate remedies and sanctions when compliance problems occur with faculty or staff. This memorandum provides examples of potential billing compliance violations and probable consequences that exist under current University rules.
• Sanction and Exclusion Checks
• Selecting a Consultation Replacement Code when Medicare is the Primary Payor
• Skilled Nursing Facility or Nursing Facility Location when Medicare is the Primary Payor
• Signature Stamps, Password Sharing, Authentication of Electronic Reports and Scanned Signatures (04/2020)
• Split/Shared Billing between Advanced Practice Professionals and Physicians | Appendix A
• UF College of Medicine Billing Compliance Plan (05/2008)
  The University of Florida Billing Compliance Plan, originally adopted in June 1996, establishes an overall framework for billing compliance activities at the College of Medicine.
• UF Teaching Physician Billing Policy (08/2011-rev 06/2022)
  As part of the overall Billing Compliance Plan, this policy statement, originally adopted in June 1996, describes the standards that the University expects all faculty and employees to follow in connection with the Medicare teaching physician billing rules.
• Use of the JW Modifier for Drug Wastage
• Use of the KX Modifier for Gender Specific Procedures
• Use of Modifier 23
• Use of Modifier 24
• Use of Modifier 25
• Use of Modifier 57
• Use of Modifier 58
• Use of Modifier 78
• Use of Modifier 79
• Use of Modifier 91