Article II. General Policy

All claims for professional fee reimbursement made by or on behalf of UT Southwestern shall adhere to applicable UT Southwestern policies (e.g., Medicare Chart Review Protocol, Physician Payment Alerts, etc.) and the Rules and Regulations of the Board of Regents of the University of Texas System. Claims for professional fee reimbursement shall also:

• Satisfy the specific coding and billing requirements of individual, non-federal third-party payers; or
• Be consistent with the applicable standards set forth in the federal and state health care programs' regulations, procedures and guidelines or otherwise communicated by HCFA, its agents or any other agency engaged in the administration of the federal health care program and/or its agents.

The MSRDP Board and UT Southwestern Administration ("Administration") establish the billing philosophy and policies of UT Southwestern. These policies shall be distributed to all employees, physicians and independent contractors involved in submitting or preparing any and all requests for reimbursements on behalf of UT Southwestern for submission to the federal, state and private health care programs and/or entities. UT Southwestern shall post, in a prominent place accessible to each employee, a notice detailing its commitment to comply with all applicable federal, state and local health care program statutes, regulations and directives. Development of procedures for implementation of these policies, including provision of resources and assistance in the process, is the responsibility of UT Southwestern Health Systems ("UTSHS") as the responsible agent for billing operations. To guide physicians, other health professionals, and billing personnel in meeting this policy objective, the officials responsible for the Plan shall, with the assistance of legal counsel, review new and existing policy statements developed by MSRDP or Administration, refer policy statements to MSRDP or Administration for further clarification, information, or questions as necessary, and submit its recommendation regarding policy and procedure statements to Administration for final decision.

The authority of the Plan shall extend to all billing by or on behalf of UT Southwestern for clinical services performed by physicians and other health professionals associated with UT Southwestern, including the Southwestern Allied Health Sciences School ("SAHSS"). This Plan is applicable to all persons who are involved in the process of billing for professional health care services provided by or through UT Southwestern.

Every individual who participates in the billing process, including physicians, will receive copies of relevant standards of conduct and policies, and will be required to sign an attestation that the standards and policies have been read, understood, and will be followed. The documentation and communications resulting from activities related to this Plan shall be handled in a confidential manner.