Washington State University’s student health services program located on the Pullman campus recently identified that it has not been in compliance with billing rules related to charging for third-party laboratory services. Specifically, lab services provided by a CLIA-certified outside lab were marked up and billed by Cougar Health Services, the WSU Pullman student healthcare provider. Cougar Health Services is contacting those that were impacted, including insurance payers, to report the error and determine if any repayment is required.
WSU has also notified the appropriate government agencies of the incorrect billing practice, which appears to have been in place for a number of years. The actual amount of the overpayment is still being determined.
This error was discovered through Cougar Health Services’ and WSU’s renewed emphasis on compliance and risk management. In 2020, Cougar Health Services launched a more robust compliance program, including formalizing compliance committee oversight, to examine regulatory issues that relate specifically to healthcare compliance.
The next step in the Cougar Health Services compliance program will be the hiring of a dedicated quality assurance and compliance coordinator, who will report directly to the executive director of Cougar Health Services and to WSU’s new chief compliance and risk officer.
WSU hired its chief compliance and risk officer in 2020 to oversee regulatory compliance across the entire WSU system.
WSU and Cougar Health Services take compliance responsibilities seriously. This event is an opportunity to improve programs, communications, and training. In response to this error, Cougar Health Services will be implementing recommended corrective actions, including the establishment of regular billing audits and monitoring plans, creating clear lines for reporting and communication of compliance concerns, and enhanced training.
Washington State University employees who have compliance or risk management-related concerns are encouraged to contact the chief compliance and risk officer, the Office of Internal Audit, the WSU Office of Compliance and Civil Rights, Human Resource Services, or other appropriate offices.
Phil Weiler, vice president of marketing and communications, 509-595-1708, firstname.lastname@example.org