University of Florida College of Medicine
Office of Compliance

Mission and Goals

Nina W. Tarnuzzer, MHA, CPA, CPC
Assistant Dean, Physician Billing Compliance

Mission

Office of Compliance:

The critical focus for the Office of Compliance relates to professional fee reimbursement. The Office of Compliance has the responsibility of:

(1)    Keeping abreast of the rapidly changing rules for billing;

(2)    Continually providing to educate physicians and others on new and existing rules;

(3)    Continually monitoring compliance of physicians and others (including overseeing department reviews);

(4)    Receiving and responding to questions related to billing issues and to reports of non-compliance;

(5)    Providing advice on disciplinary issues relating to compliance;

(6)    Working with Shands’ compliance team to coordinate compliance efforts;

(7)    Thoroughly documenting and reporting on all compliance activities;

(8)    Performing analytical review on the appropriate billing data; and

(9)    Engaging external billing auditors as appropriate.

Statement of Vision

The physicians of the College of Medicine practice the art of medicine and teach it to others. We wish to conduct ourselves in an exemplary manner and we are all committed to doing things right.

The College of Medicine has a strong and abiding commitment to ensuring that its affairs are conducted in accordance with applicable law.

The College of Medicine recognizes the need to ensure its physicians and staff are well informed about state and federal regulations applicable to billing, that they comply with those rules, and that performance is regularly audited so as to strengthen any weaknesses.

Statement of Values

We value:

(1)    Integrity, proficiency and due care in performing our work;

(2)    A service attitude that is responsive to the needs of the College of Medicine;

(3)    Quality products and services that are timely and relevant;

(4)    Each team member's role in the Compliance process; and

(5)    Confidentiality for individuals reporting possible compliance issues in good faith. Retaliation or harassment as a result of the report will not be tolerated.

Compliance Plan Authority and Responsibility

Assistant Dean, Physician Billing Compliance

Nina W. Tarnuzzer, MHA, CPA, CPC

Nina W. Tarnuzzer, MHA, CPA, CPC, graduated from both the University of Central Florida and the University of Florida. She began her career as a CPA in a public accounting firm eventually achieving partner status. She then served as Chief Financial Officer for an international retail corporation. She has eighteen years experience with the State of Florida, including five years experience in federal financial and compliance audits with the Office of Auditor General and nine years in Physician Billing Compliance at a major Academic Health Center. She has served as an adjunct instructor for the Masters Program in Health Administration with the University of Florida College of Health Professions. Nina became a Certified Procedural Coder in 1999.

In addition to overseeing the day-to-day activities of the Office of Compliance, the Assistant Dean must oversee all aspects of the College of Medicine Billing Compliance as extensively described in the College Billing Compliance Plan.  The Assistant Dean ensures all tasks required by the College of Medicine Billing Compliance Plan are accomplished, oversees and participates in the compliance investigations and recommends appropriate discipline, as well as designs and implements corrective measures after investigations are completed. The Assistant Dean develops reports assessing the College of Medicine's compliance efforts and status and provides this information to the Dean and other appropriate College and University officials.

The Office of Compliance is a department within the Dean's Office and is staffed and funded through the regular budgeting process.

The Asssitant Dean and Office of Compliance staff members have authority to access and review all documents of the College relevant to Compliance.

The Asssitant Dean will be responsible for ensuring that policies and procedures regarding the creation, distribution, retention, storage, retrieval and destruction of Compliance documents in accordance with University policy and Federal guidelines.

The Asssitant Dean will engage external auditors as appropriate.

The Asssitant Dean is responsible for the preparation of reports summarizing the compliance effort for the College of Medicine and its Departments, and identifies the changes that will be made to enhance compliance.

The Asssitant Dean is responsible for developing appropriate corrective action plans to any compliance issues.

Associate Asssitant Dean & Audit Manager

Meilan Zheng, BS, CPC

Meilan Zheng, B.S., C.P.C., holds a BS degree and became a Certified Professional Coder in 1996.  She has fourteen years of experience working in the medical field - six years in billing and reimbursement with the University of Washington Physicians billing group in Seattle and four years with the University of Arkansas for Medical Science as the Medical Services Manager with the Chart Audit unit in Little Rock, AR. She joined the Office of Compliance in 1999.

The Associate Asssitant Dean is responsible for auditing medical records in accordance with the Departmental Compliance Plan of the department in which she is working, as well the College of Medicine's Compliance Plan, Teaching Physician rules, CPT and ICD-9 coding, with a specific focus on the accuracy of the coding and the adequacy of the documentation.   The Audit Manager is also responsible for review of all reports produced by her staff, the design and management of audit programs, project timelines and the timely completion of the final reports.  Findings by individual records will be placed in a central database for the College from which a summary is prepared to ensure all appropriate individuals are audited within the department.  Upon completion of the audits, she will prepare draft reports and any necessary correspondence.  The Associate Asssitant Dean will also meet with Departmental Compliance Representatives or the Compliance Committee to discuss findings and recommendations.

Education & Training Coordinator

Susan A. Boyle, BS, CPC, CPC-I

Susan A. Boyle, CPC, attended the University of Texas at El Paso and Park University where she received her degree in Health Care Administration.  She became a Certified Professional Coder in 1998.  She comes from a nursing background and has spent the last 15 years in healthcare administration, working in clinical administration.  She has 2 years experience as a managed care analyst and spent the four years prior to joining the compliance team as clinical administrator for the Division of Cardiovascular Medicine, Department of Medicine at UF.  She joined the compliance team in July 2002.

The Education & Training Coordinator has the responsibility for providing general and specialty specific training and information to all University of Florida physicians, health care providers and other appropriate personnel in order to insure proper understanding and compliance with all upcoming agreements between the University of Florida and the Federal government.

Susan Boyle received her CPC-I in June 2007 and began teaching the CPC curriculum in June 2008.

Compliance Analysis - Special Investigations

Special Investigations Audit Manager

Dana King, CPC.

Dana King, C.P.C, attended Santa Fe Community College and has been employed with the University of Florida College of Medicine for the past 13 years.  During this time she has worked in every aspect of the billing system from helping to generate clean claims and having them billed out in a timely manner, working as a patient secretary, to serving as a Financial Counselor retrieving authorizations from the Insurance Companies and calculating patient surgical estimates.

Special Investigations Medical Compliance Auditor

Jocelyn V. Reed, CPC

Jocelyn V. Reed, CPC, has worked in the medical field for 11 years, six of them with Shands Hospital and the University of Florida. She received her CPC certification in 2004.

The Compliance Analysts/Special Investigators are responsible for ensuring that the protocols for corrective action are followed, provides guidance and monitoring to the Departmental staff that perform retrospective audit work and manages the division of the Office of Compliance that performs follow-up and new physician testing and special investigations. The Analysts review the medical records searching for unusual billing patterns or outliers, and upon request, researches medical records and summarizes findings for review.


Medical Compliance Auditors

Virginia G. Allen, CPC

Virginia G. Allen, CPC, graduated from Central Florida Community College with an Associates Degree and has attended classes at Florida State University.  She has worked at Shands Hospital and the University of Florida for the past five years in multi-specialty clinics.  She has experience in billing, obtaining authorizations, and coding and received her certification in coding in November, 2000.

Jackie Maxey Trotter, CPC

Jackie Maxey Trotter, CPC,  has 22 years experience in daily functions and medical billing for hospitals and physician offices.  She has spent the last four years with Shands at UF, in the Pediatric Specialty Clinic as a Financial Counselor, and as a Financial Support Analyst for the College of Medicine Department of Pathology billing office.  She became a Certified Professional Coder in 2001. 

Thawana McDougald, CPC

Thawana K. McDougald, CPC, has over 20 years experience in the medical field. She was employed with Family Practice Medical Group for 11 years with 5 years as Front office manager and has been with UF for the past 5 years. She received her Dental Asst. certification from Concorde Career Institute, Jacksonville, Fl in Feb.1996 and became a certified professional coder in Jan. of 2004.

Mindy J. Hawley, B.S., C.P.C.

Mindy J. Hawley, B.S., C.P.C., graduated from the University of Florida with her degree in Business Finance in 2005. Mindy has worked in the medical field at the University of Florida since 1999, and joined the compliance team in January 2002. She became a Certified Professional Coder in 2006.

The Compliance Auditors are responsible for auditing medical records in accordance with the Departmental Compliance Plan of the department in which they are working, as well the College of Medicine's Compliance Plan, Teaching Physician rules, CPT and ICD-9 coding, focusing specifically on the accuracy of the coding and the adequacy of the documentation.   Findings by individual will be placed in a central database for the College from which a summary spreadsheet is derived to ensure that all appropriate individuals are audited in the department.  Upon completion of the audits, they will prepare draft reports and any necessary correspondence for review by the Audit Manager.  The Auditors will also meet with Departmental Compliance representatives or the Compliance Committee to discuss findings and recommendations.


Legal Support from the Office of General Counsel

Susan B. Collingwood, Senior Associate General Counsel

Susan B. Collingwood received her bachelor's degree in chemistry from Indiana University and her juris doctor from the University of Florida in 1988 and was inducted into the Order of the Coif.  She began her legal practice in Orlando, Florida, first with the firm of David U. Strawn. P.A. and then with the firm of Fisher, Rushmer, Werrenrath, Keiner, Wack and Dickson, P.A.  Her practice focused on complex litigation, representing a broad variety of clients, including physicians and health care providers.  In 1995, Ms. Collingwood initiated the Medical School Office of the General Counsel, and has been providing legal advice on numerous health law issues since that time.

B. Dianne Farb, Assistant General Counsel

B. Dianne Farb received her juris doctor degree, with honors, in 2000 from the University of Florida Levin College of Law.  She received her bachelor of arts degree in Literature, summa cum laude, in 1997 from the University of North Florida, where she received the Award for Excellence in Literary Scholarship. Before attending law school, Ms. Farb worked in medical administration.  Ms. Farb is a member of the American Bar Association, the National Association of College and University Attorneys, the American Health Lawyers Association, and the Florida Bioethics Network. She was admitted to practice in Florida in 2000.

The Medical School Office of the General Counsel devotes full-time and part-time (respectively) efforts to providing legal support for the Compliance Program, including keeping up-to-date on all billing and regulatory issues so as to minimize the costly use of outside counsel. In addition to researching and providing authoritative answers to billing questions, the compliance attorneys will advise on the wide variety of legal issues associated with billing compliance while working with the Shands compliance team to coordinate compliance activities.   In addition, the Attorneys assess reports of non-compliance, design the appropriate response, oversee and assist in investigations, evaluate findings, advise as to the institutions ’ required response, and interact with state and federal officials. The Attorneys also participate in education programs and supervise outside counsel as needed to minimize costs to the College.


COLLEGE OF MEDICINE ACTIVITIES

Hotline

The University of Florida now has it's own hotline for any legal or ethical question that you may have regarding the conduct or billing of our physician services.

The Gator Compliance Hotline number is 1-866-574-2867

Each call is promptly investigated by our office. You may remain anonymous if you prefer.

Compliance Investigations

The College of Medicine Billing Compliance Plan requires all employees to report instances of suspected non-compliance to the Office of Compliance. Upon the receipt of a report of a compliance concern from any source, the Office of Compliance reviews the report and undertakes an appropriate investigation. The investigation may range from simple fact-gathering phone calls to multiple confidential interviews and extensive reviews of medical records.

After review and investigation, the Asssitant Dean or Associate Asssitant Dean prepares a written report of findings. This report is provided to the employee, the employee's supervisor, and, in appropriate circumstances, the Chair of the Department and the Dean of the College. With the advice of the Office of General Counsel, the College promptly evaluates what organizational response to the findings is appropriate, such as processing refunds and/or reporting the findings to the proper regulatory agencies.

Compliance Committee

The Committee is comprised of:

  • the Asssitant Dean of Compliance,
  • Compliance Representatives for each clinical department as designated by the Department's Chair,
  • and additional members as the Asssitant Dean and membership deem appropriate.

    • Duties:

    The Compliance Committee functions as a problem-sharing and problem-solving forum for the College. Compliance Representatives discuss current issues and challenges at the monthly meetings and engage in a collaborative process to address issues raised. Each clinical department has prepared a plan to address compliance efforts on a departmental basis. The plans are evaluated and modified on an on-going basis to ensure they meet the Departments needs and accurately describe the Department's practices. The plans should address compliance issues for all clinical venues of the department.

    Compliance Audits

    The systematic and routine review of selected encounters for each provider began 01/01/2000 conducted by a centralized Office of Compliance audit staff under the supervision of the Compliance Manager and the Asssitant Dean of Compliance.  The Office of Compliance compiles the audit findings, distributes audit results to the individual provider, the Department's Chair and Compliance Representative, and the Asssitant Dean of Compliance.

    The identification of any material deficiency will prompt additional review as to the appropriateness of:

  • Redesigning administrative procedures in the billing process;
  • implementing global or targeted educational activities;
  • imposing disciplinary actions; or
  • imposing restrictions on the billing authority of the non-compliant individual.

    • Evaluation of Compliance Performance

    The University of Florida College of Medicine's billing compliance plan confirms compliance is an essential element of every employee's job performance. Under established University of Florida rules and policies, every employee's performance is evaluated by his or her supervisor.

    The supervisor of a member of the faculty is their Departmental Chair, while the Chair's performance is evaluated by the Dean. All University employees receive annual evaluations of their performance. In addition, faculty, billing personnel and Chairs receive feedback on the results of the Department's quarterly compliance audits. This information is not only taken into account during the annual evaluation process, but may also result in immediate discipline of the employee as discussed below.

    Disciplinary Actions

    Under established University of Florida rules and policies, University employees are subject to discipline for failing to perform their job duties or disregarding University rules and policies. The University rules establish the disciplinary mechanisms that are used to address non-compliant behavior. The rules permit the University to respond to each unique factual situation in a fair manner, in proportion to the seriousness of the behavior.

    The Office of Compliance with, if necessary, the advice of the General Counsel, provides input to the employee's supervisor on the severity of any compliance violation. The Office of Compliance also independently reviews each case where discipline is considered to determine what, if any, additional measures must be put in place to ensure the problem is appropriately addressed (as to past behavior) and corrected in future.


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