Notice, February 1997

Revision in Works for
UC Billing Guidelines

The fight over IL 372 has to do with what occurred in academic medical centers prior to July 1996, when the federal government issued a clear set of regulations governing Medicare billing. Mindful of its trouble regarding past practices, UC issued, last October, a set of billing "Compliance Guidelines" that were intended to let UC medical faculty know what was expected of them under the new regulations while assuring the federal government that UC was serious about enforcing the rules.

Those guidelines are now in force, says Maria Faer, special assistant for clinical services administration at UC, but they are undergoing revision to make them consonant with University regulations as well as federal requirements.

The October guidelines had many UC faculty seeing red, as they call for physicians who render service to bear "primary responsibility for ensuring compliance" with regulations. Further, they note that individual physicians will be held responsible for repaying "any amounts received as a result of improper billing to a third party payor" and they even specify a mechanism for this repayment: "Ordinarily, repaid amounts will be deducted from future payments to individuals in accordance with Departmental distribution plans."

With respect to this last measure, Faer says, "we've been told you can't do that" under UC regulations; hence, this provision is being revised, along with several others. She notes, however, that the October guidelines were drawn up "to put campus administrations into compliance with regulations that we have no choice about."

Duncan Mellichamp, Chair of the Academic Council, said the guidelines needed to be revised, since "they virtually ignored due process in UC's personnel procedures." He said he hoped that the provisions being revised would include those dealing with financial liability. "Is it fair that clinical departments, with their responsibility for administering the compensation plans, be allowed to pass all responsibility onto individual faculty?" he asked.