Section Four: Financial and Business Standards


We store medical and billing records in a safe and secure place for the time required by law or policy.
  • We do not falsify any record, contract, or other document.  
  • We truthfully and accurately maintain all paper and electronic data, including medical records and financial reports, in accordance with applicable laws, regulations, and policies.
  • Only authorized individuals should access medical and billing records.
  • We maintain all medical and billing records as required by law.
  • All cost reports submitted comply with federal and state laws, regulations, and guidelines.
  • We maintain and retain documents related to the Compliance Program.



Coding is the way we identify and classify health information (such as diseases and procedures) based on the care provided as documented in a patient’s medical record. Submitting these codes in the billing process is the way we identify charges for services we have provided. Our coding and billing practices strive to comply with all laws governing federal- and state-funded health care programs, and with the requirements of insurance companies.
  • We are committed to timely, complete, and accurate coding and billing. We bill only for services that we actually provide, document, and believe to be medically necessary.
  • We select billing codes that we believe in good faith accurately represent the services that we provide and that are supported by documentation in the medical record according to regulatory requirements and guidelines.
  • We address and respond to billing and coding inquiries and questions.
  • We make every effort to correct inaccuracies in billing in a timely manner as required by applicable laws and policies.

Employees should report concerns regarding the appropriateness of coding and billing practices to the appropriate supervisor, Facility Compliance Officer, or the DUHS, PDC, or SOM/SON Compliance Office.



It is a violation of the Federal False Claims Act to knowingly submit, or cause another person or entity to submit, false claims for payment of government funds, such as filing with Medicare a claim for payment for services that were not provided. Penalties for such action(s) may be three times the government’s damages plus civil penalties of $5,500 to $11,000 per false claim, and in criminal cases may include imprisonment. Health care organizations also can be excluded from participation in federal health care programs.

The False Claims Act contains provisions that allow employees with actual knowledge of alleged false claims to sue, on behalf of the government. These individuals will be protected from retaliation, e.g., harassment, demotion, and wrongful termination, as a result of the employee’s lawful acts in furtherance of a false claims action.



Our organization’s financial information serves as the basis for managing our business so that we are able to serve our patients, research participants, colleagues, and others. It is also necessary for compliance with tax and financial reporting requirements.

  • We maintain accounting records according to generally accepted accounting principles.
  • We maintain a system of internal controls to ensure accuracy and completeness in documenting, maintaining, and reporting financial information.
  • We cooperate fully with internal and external auditors and any regulatory agencies that examine our books and records.



Our “assets” include more than facilities, property, equipment, inventory, office supplies, and funds. Our assets also include employee time, business strategies, financial data, computer software, patents, trademarks, inventions and devices, as well as intangible intellectual property and other information.

Everyone is responsible for using corporate assets properly.

  • We take appropriate steps to protect corporate assets against loss, theft, or misuse. We report possible loss or theft to our supervisor.
  • We handle any purchase, transfer, or sale of assets in accordance with applicable policies and procedures.
  • We do not use equipment, or other assets for purposes not directly related to business or without prior approval from our respective supervisors except for limited personal convenience.
  • We do not photocopy or distribute material from books, periodicals, computer software, or other sources if doing so would violate copyright laws.



We employ the highest business standards in selecting, negotiating, and approving all contracts with third parties.

  • We maintain confidentiality regarding pricing and terms of contracts.
  • In contracting with vendors, insurance companies, and other contractors, we comply with all laws and regulations, including the receipt of fair market value in the payment and receipt of services and products.
  • We inform consultants, service providers, vendors, and other contractors that they are expected to comply with this Code.


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