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Billing Compliance


2 Midnight Rule Resources

What is the Medicare 2 Midnight Rule?



Tip Sheet

The mission of The University of Texas Medical Branch at Galveston (UTMB) is to provide scholarly teaching, innovative scientific investigation, and state-of-the-art patient care in a learning environment to better the health of society.  An integral part of this mission is the obligation of each member of the UTMB workforce to act lawfully and ethically, and to document and bill for medical services in accordance with applicable laws and regulations. 

Accordingly, UTMB has established a comprehensive Billing Compliance Plan to assist practitioners and workforce members with submitting accurate billing to federal, state, and private payer programs.  This Plan is designed to ensure:  appropriate oversight; organized and effective training; documented billing policies and procedures; continuous monitoring to prevent and detect non-compliance; and an avenue to report and investigate compliance concerns.

It is the policy of UTMB that all claims for professional and facility/technical fee reimbursement are accurately prepared and correctly identify services performed by appropriate workforce members. At no time are billings to be prepared or submitted, or reimbursement received and retained, for services that have not been performed, or are medically unnecessary. Monies to which there is no legal entitlement must be returned to the appropriate payer within a reasonable timeframe. Refunds to Medicare must take place within 60 days of date the overpayment was identified.  Appropriate DRG, ICD-10-CM, CPT and HCPCS codes, must be utilized and all charges must clearly reflect the services provided.  Adequate and appropriate documentation to support the medical necessity of these services must also be maintained in the medical record.  UTMB policies concerning billing, which are included herein, are considered an integral part of UTMB’s commitment to fair and accurate billing.  All workforce members are charged with knowing and abiding by the Billing Compliance Plan and the various billing policies and procedures, as they relate to the workforce member’s job duties.

Billing Compliance Team

Maria Mantilla, MD, MHA, CPC, CHC
Director, Billing Compliance
(409) 747-1340
Rachel Estrada, CPC, COC
Coding/Billing & Reimb Auditor
(409) 747-8717
Karen Hill
Billing Compliance Assistant
(409) 747-8705
Lisa Hodges, CPC, COC
Coding/Billing & Reimb Auditor
(409) 747-8709
Gianna Luper
Billing Compliance Program Manager
(409) 747-8713
Ursula Sedgwick, CPC, COC
Coding/Billing & Reimb Auditor
(409) 747-8709
Linda Venzke
Compliance Nurse Auditor
(409) 747-8704
Christina White, CPC
Coding/Billing & Reimb Auditor
(409) 747-8797

Billing Compliance Training

UTMB Online Training System


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