UW Health Professional Services Compliance Program
The Board of Directors of the University of Wisconsin Medical Foundation (UWMF) has
established the UW Health Professional Services Compliance Program (the “Program”).
UW Health recognizes that an effective Program can improve communication about
applicable federal, state and local laws and regulations within the organization. An effective
Program can also prevent problems, or detect potential problems early enough to reduce
legal risks. With the greatest risk to physician group practices being improper professional
billing, the Program focuses on education, documentation, coding, and billing as applied to
provider services (M.D., D.O., P.A., N.P., Ph.D., etc). In adopting the Program, the Board of
Directors establishes an ongoing commitment to compliance and the expectation that
UWMF employees demonstrate the highest ethical standards in performing their work
II. Program Overview
a. Compliance Officer. Program will maintain a Compliance Officer reporting to the UW
Health VP/Business Integrity and Chief Compliance Officer with additional direct
reporting responsibility to the UWMF Board of Directors, UW Health Professional
Services Compliance Support Committee (CSC), UWHCA Board of Directors, UWHCA
Audit Committee, Compliance Executive Oversight Committee and the UW Health CEO.
b. Compliance Support Committee. Program calls for a Compliance Support Committee
(CSC), a committee reporting to the UWMF Board of Directors, whose members include
at least 6 physicians, 2 Department Administrator representatives, and one UWMF
Board Member. The Committee provides guidance and oversight for all aspects of the
c. Policies and Procedures. The Compliance Officer and CSC will create, review and
approve policies, procedures and other guidance to meet the objectives of the Program.
d. Communication of Issues. The UW Health Professional Services Compliance
Department will maintain mechanisms (e.g. hotline, online reporting form) to receive
reports regarding potential compliance violations. All staff members will be educated
on the ways to report issues.
e. Training and Education. The Program, at the direction of the UWMF Board of Directors,
provides mandatory annual online training of all employees to include relevant laws and
regulations as well as documentation and billing policies. In addition to the mandatory
training, other mechanisms (face to face, newsletter, etc.) will be employed to provide a
comprehensive education program for our providers and coding personnel.
f. Auditing and Monitoring. The Program calls for a robust auditing and monitoring
process to detect, prevent and correct compliance vulnerabilities. Through a risk
assessment process, UW Health Professional Services Compliance Department will
formulate and prioritize an audit plan. Data analytics, OIG Work Plan, current trends
and other resources will be used in determining those things that pose the highest risks
associated with professional coding and billing.
g. Issue Resolution. The UW Health Professional Services Compliance Officer and CSC will
be responsible to ensure all reports of compliance violations are thoroughly investigated
and resolved. Outside counsel, UW Hospital and Clinics Authority, and UW School of
Medicine and Public Health may be brought in to assist in the resolution process as
necessary. The Compliance Officer may put a hold on charges in question until
resolution is made and where necessary, refunds will be calculated and repaid as
promptly as possible.
h. Enforcement of Disciplinary Actions. If deemed necessary, the CSC will recommend
disciplinary action to other bodies who have disciplinary authority over the individual(s)
and will require a report back to the CSC Chairperson confirming action was taken.
Approved by the UW Health Professional Services Compliance Support Committee on January 19, 2017.
Gerald Lang, Professional Services Compliance Support Committee Chair
Mary Waldo, UW Health Professional Services Compliance Officer
Troy Lepien, VP Business Integrity and Chief Compliance Officer