CHAPTER

Developing a Coding
Compliance Program

Objectives
At the completion of this chapter, the learner should be able to:
Identify the seven key components of a corporate compliance program.
Describe the importance of a corporate compliance program and the purpose
of a coding compliance program.
Discuss the purpose of the Office of Inspector Generals compliance guidance
for health care entities and identify key elements.
Describe the difference between mandatory and permissive offenses.
Discuss the roles of the coding compliance manager and the coding compliance
committee.
Identify areas that should be defined within coding compliance policies.
Discuss the importance of coding compliance education.
Recognize the importance of coding accuracy and distinguish between coding and
documentation errors.
Explain differences in coding certification and professional coding organizations.
Identify the coding resources that must be kept up to date.

Key Terms
chargemaster
code of conduct
coding certification
coding compliance
coding compliance
education
Coding Compliance
Manager

coding resources
compliance officer
compliance program
Comprehensive Error
Rate Testing (CERT)
program
corporate compliance
program

mandatory exclusions
OIG Compliance
Guidance
outcomes
outcome indicators
permissive exclusions
process

Recovery Audit
Contractors (RACs)
structure

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Integrating Coding and Corporate Compliance

Corporate businesses and health care organizations alike may be subject to criminal and civil actions
under a variety of federal and state laws, including the False Claims Act, the Wire and Mail Fraud
Act, securities and employment laws, and a number of others. In todays business market, many
organizations have adopted corporate compliance programs to educate everyone from top executives
to line-staff employees on the laws and regulations that affect their operations. A corporate compliance
program can prevent both intentional and accidental wrongdoing and can be viewed positively by
investigators and the courts, often reducing civil or criminal penalties. The mere existence of a
compliance program, however, does not excuse any corporation of wrongdoing. In fact, a poorly planned
and executed compliance program can be viewed worse than having no compliance program at all.
Health care providers need to address many of the same compliance concerns as their corporate
counterparts. In addition to the laws and regulations already in existence, health care providers face
continuing enforcement initiatives from the Centers for Medicare & Medicaid Services (CMS), the Office
of Inspector General (OIG), the United States Department of Justice (DOJ), and various national and
state accreditation bodies. In addition to conducting federal and state payer oversight, private payers
are also engaged in reviewing and auditing health care services for quality, medical necessity, and health
care financial waste. Health care organizations today must have a comprehensive corporate compliance
program that embodies accountability, responsibility, investigation, and education.
A health care providers compliance program will consist of various policies and standards and
will vary depending on the specific entity. Generally, corporate compliance programs include policies
and procedures designed to define and identify laws and regulations, correct identified problems, and
put controls in place to prevent future problems. Policies may address a variety of compliance issues
including:
Fraud and abuse awareness
Whistle-blower protections
HIPAA privacy rules
Referral guidelines
Teaching physician rules
Coding and documentation
Billing and reimbursement
Misuse of funds and property
Antidumping regulations
Conflicts of interest
Labor laws
Researching compliance issues
Marketing
Medical records creation/retention
Patient risk identification (e.g., medical error reduction, medication safety, patient safety)
Business associates agreements
Security of health information
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Coding compliance is inherently linked to a number of the preceding compliance risk areas including
proper documentation, accurate billing, medical records creation and retention, referral guidelines, and
teaching physician rules. Acknowledging that one of the biggest areas of risk for health care providers is
the accurate submission of claims and reimbursement to Medicare, an effective health care corporate
compliance plan will also include an effective coding compliance plan.

OIG Compliance Guidelines

There is OIG compliance guidance for several specific health care areas including hospitals, physicians,
nursing facilities, pharmaceutical manufacturers, ambulance suppliers, hospices, durable medical
equipment manufacturers, and home health agencies. The OIG also publishes an annual work plan that
outlines activities that the OIG will be reviewing. These resources, along with the results and summaries
of audits that the OIG has performed, are located on the OIG Web site at www.oig.hhs.gov. Although
there may be subtle differences in the compliance guidance publications, there is a common theme that
the OIG outlines in seven basic compliance elements. These elements stem from the federal sentencing
guidelines, which are detailed policies and practices that the federal criminal justice systems use to
prescribe appropriate sanctions for offenders convicted of federal crimes. The seven elements include
the following:
1. Establishing compliance standards through the development of a code of conduct and written
policies and procedures
a. The code of conduct is a general organizational statement of ethical and compliance
principles that guide the entitys operations.
b. The code is similar to a constitution, in that it details the fundamental principles, values,
and framework for action within an organization.
c. The code of conduct articulates a commitment to compliancy by management, employees,
and contractors and summarizes the broad ethical and legal principles under which the
organization operates.
d. The code of conduct should include a requirement that professionals follow the ethical
standards dictated by their respective professional organizations.
e. The code of conduct should be brief, easily readable, and cover general principles applicable
to all members of an organization.
Compliance policies and procedures should be developed to assist employees in carrying out
their job responsibilities as well as the mission and objectives of the organization. Policies need
to be consistent with applicable federal and state regulations. According to the OIG Program
Guidance for Hospitals, policies and procedures should be:

Clearly written, with relevant day-to-day responsibilities

Readily available to individuals who need them
Monitored and reevaluated on a regular basis
Distributed to all directors, officers, managers, employees, contractors, and medical and
clinical staff members

Compliance policies and procedures should include risk assessment tools that assist an
organization in identifying its weaknesses and areas of risk. The risk assessment tool should
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reflect federal and state regulations, the OIG work plan, internally identified risk areas, and
areas of risk and liability identified through the CMS Conditions of Participation (CoPs) and
associations such as The Joint Commission.
2. Assigning compliance monitoring efforts to a designated compliance ofcer or contact
a. The compliance program/department should be led by a qualified compliance officer, who
is supported by a compliance committee. According to the OIG, the individual leading the
compliance program should be trustworthy. Furthermore, The organization must have
used due care not to delegate substantial discretionary authority to individuals who the
organization knew, or should have known through the exercise of due diligence, had a
propensity to engage in illegal activities (www.oig.hhs.gov).
b. The purpose of the compliance department is to ensure compliance with federal and state
regulations and to monitor the organizations compliance program.
c. The compliance committee is minimally composed of senior leadership, legal
representatives, physicians, and the compliance officer.
3. Conducting comprehensive training and education on practice ethics and policies and
procedures
Organizations that fail to provide adequate training and education for their staff risk liability
for violation of health care fraud and abuse laws. Each individual employee or contractor
of an organization requires the skills necessary to perform his or her job responsibilities.
This may include required annual compliance training for staff in specific areas, or general
education provided to all staff. According to the OIG, The organization must have taken steps
to communicate effectively its standards and procedures to all employees and other agents,
by requiring participation in training programs or by disseminating publications that explain in a
practical manner what is required. The training and education needs to be routinely reviewed to
ensure it is up-to-date and reflects the objectives outlined in the compliance program. Training
should be based on trends identified internally as well as those identified by outside sources
such as the OIG, CMS, and health care accrediting bodies. Training should be well documented,
identifying the specific session, length, date the education took place, and the individuals
who attended.
4. Conducting internal monitoring and auditing focusing on high-risk billing and coding issues
through performance of periodic audits
Audits should be regularly conducted to ensure that the organization is correctly submitting
claims and accurately assigning codes. The compliance plan should include specific details
about how issues are identified, audited, corrected, and continuously monitored. Components of
a coding compliance program are discussed later in this chapter.
5. Developing accessible and open lines of communication
Open communication is vital to the identification of potential areas of compliance risk.
There should be internal processes in place for reporting instances of potential fraud and
abuse. The OIG encourages an organizational culture of open communication without fear
of retaliation. Many organizations have established hotlines or other similar mechanisms
such as comment boxes so that issues can be reported anonymously. All staff, outside
contractors, patients, visitors, and vendors should have the ability to report potential
compliance issues.

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All issues identified through these lines of communication need to be investigated and resolved.
The results of internal investigations should be shared with administration and relevant
departments on a regular basis. Policies and procedures should be updated to ensure that
issues do not recur.
A compliance program that contains internal reporting processes and procedures will enable
employees to freely report issues or concerns. An effective reporting mechanism can reduce
the possibility of whistle-blower suits that often occur in organizations that limit or prohibit the
communication of potential problems.
6. Enforcing disciplinary standards through well-publicized guidelines
Including enforcement and disciplinary methodologies in the compliance program will assist
in creating a culture that encourages appropriate ethical behavior. These actions also add
credibility and integrity to compliance programs. Disciplinary policies and procedures should be
readily available to all staff and included in orientation and training packages. The following are
components of appropriate disciplinary actions:

Methods of disciplinary action may include warnings (oral), reprimands (written), probation,
demotion, temporary suspension, termination, restitution of damages, and referral for
criminal prosecution.

Violations should be consistently applied, with provisions given for extraordinary

circumstances. Grievous violations may include termination.

Violations should be thoroughly investigated and documented, including the date of the
incident, names of responsible parties, and follow-up actions.

Policies should include disciplinary actions for those who were aware of violations but failed
to report them.

Potential employees should be checked against government sanctions lists, including the
OIGs List of Excluded Individuals/Entities and the General Services Administrations (GSAs)
Excluded Parties Listing System. Current employees should be routinely checked to ensure
they have not been excluded from the Medicare program.

Individuals or entities may be excluded from Medicare and other health care programs, such as
state Medicaid programs, for a number of violations. During fiscal year 2006, three thousand
four hundred twenty-two (3422) individuals and entities were barred from participating in
Medicare and other state and federal health care programs. Exclusions vary from a few
years to permanent exclusion and are based on the nature and seriousness of the offense.
Federal guidelines outline minimum exclusionary periods. Offenses are considered either
mandatory or permissive. Mandatory exclusions must be applied on conviction of violation
of certain state or federal health care fraud and abuse laws. Permissive exclusions are partly
discretionary and may be imposed by a court of law, licensing board, or other agency.
The minimum period of exclusion for a mandatory exclusion offense is five years. If there
is one prior conviction, the exclusion will be for ten years. If there are two prior convictions, the
exclusion will be permanent. The following are examples of mandatory exclusion offenses:

A criminal offense related to the delivery of an item or service under Medicare or Medicaid
A conviction under federal or state law of a criminal offense relating to the neglect or abuse
of a patient

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A conviction under federal or state law of a felony relating to fraud, theft, embezzlement,
breach of fiduciary responsibility, or other financial misconduct against a health care program
financed by any federal, state, or local government agency

A conviction under federal or state law of a felony relating to the unlawful manufacture,
distribution, prescription, or dispensing of a controlled substance

Under a permissive exclusion, individuals or entities may be excluded for a minimum of three
years on conviction of the following offenses, for example:

Interference with, or obstruction of, any investigation into certain criminal offenses

Failure to disclose information required by law

Submission of claims for excessive charges, unnecessary services, or services that were
of a quality that fails to meet professionally recognized standards of health care

Failure to supply claims payment information

Defaulting on health educations loans or scholarship obligations

7. Responding appropriately to detected violations through the investigation of allegations and the
disclosure of incidents to appropriate governmental entities
Once a potential compliance issue has been suspected or identified, appropriate steps must be
in place to thoroughly and promptly investigate the matter. Investigations should try to identify
the root cause of the problem and then promptly initiate corrective measures. If the potential
problem is a billing or coding error, for example, measures should be taken to immediately
reduce the possibility of further errors. If the discovery identifies that an overpayment occurred,
the overpayment should promptly be reported and repaid. As appropriate, referrals to the
appropriate law enforcement agency should be made.
As noted earlier, an effective compliance program that works to prevent and detect
violations can be viewed positively during an investigation. This is especially true for
considerations in permissive exclusionary offenses. An effective compliance program
can demonstrate the trustworthiness of the provider. Other considerations include the
providers past history of misconduct, response to allegations, willingness to modify
practices, repayments, and acknowledgment of wrongdoing. The following factors may
be considered:

Was there any voluntary disclosure by the provider?

What are the qualifications of the compliance officer and others involved in the compliance
program?

Were overpayments repaid?

What changes were made in response to identified problems?
How long had the compliance program been in effect?
What problems did the compliance program detect?
What measures were taken to reduce the possibility of further violations?
Are staff sufficiently trained in policies and procedures pertaining to Medicare and other
state and federal health regulations?

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The Coding Compliance Program: Developing Policies

and Procedures
An effective coding compliance program should be an integral part of a health care organizations
corporate compliance program. A coding compliance program is a valuable asset to the health
care entity, because it assists the organization in meeting its obligations to payers, employees,
shareholders, and the community. Whereas corporate compliance programs probably do not include the
detailed policies and procedures that specifically address complex coding and billing issues, a coding
compliance program can provide these necessary guidelines. The coding compliance program should
complement the overall organizations corporate compliance program, and should include the support of
administration. It is important to note that a single model coding compliance program will not fit every
organizations needs. The size and type of the facility, as well as the framework of the coding processes,
will affect the structure of the coding compliance program.
An effective coding compliance program will be continually evaluated and reevaluated. It is
understood that rules will change, new reimbursement methodologies will be adopted, codes will
change, new laws will be enacted, and there will be employee turnover. One method used to assess the
effectiveness of the compliance plan is a compliance scorecard. The scorecard can measure specific
processes and serve as a motivational tool for employees and managers. Scorecard items should be
reviewed and approved by staff and administration. Some scorecard items for a coding compliance
department may include the following:
Coding accuracy goal of 95%
Reduction in billing/claim errors (measured as a percent of total claims billed)
100% participation in coding and documentation educational programs
Turnaround time to complete audits (measured in days, weeks, months, etc.)
Attainment by all coding staff of the necessary continuing education units (CEUs) to maintain
coding certification
The effectiveness of the coding compliance program should not be based solely on performance
in a single area. For example, the coding accuracy of ancillary services cannot be compared with the
coding accuracy of inpatient hospital coding. Similarly, poor audit results in one particular area do
not mean that the coding compliance program is poor. Identifying problems and addressing them are
indicative of an effective coding compliance program.
The results of a well-developed and well-executed coding compliance program, along with dedicated
educational efforts, will be that coding will improve over time, documentation will support the medical
necessity of charges, denial rates and physician queries will decline, and all employees will have
received the training they need to perform their job responsibilities in a compliant manner. However, to
reach this goal the program must be effectively managed with operational policies and procedures that
are owned and adopted by all employees.
The OIG has recommended that to be effective, both coding compliance programs and corporate
compliance programs be continually assessed and monitored. The effectiveness of a program is the
measurement of various outcome indicators and may include billing and coding error rates, identified
overpayments and underpayments, and audit results. The focus on examination of the compliance
program is a crucial activity that examines the underlying structure, process, and outcomes of the
program. Structure measures refer to the capacity of the program to prevent and detect violations

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Table 5-1 Structure, Process, and Outcome of an Effective Coding Compliance Program.
Structure

Process

Outcome

Does the coding compliance

department have a code of conduct?

Include the code of conduct within

the coding compliance policy. Staff
sign attestation that they have
reviewed the policy annually.

Coding staff observe the code

of conduct.

Does the coding compliance

department regularly report auditing
results? Have results been effectively
communicated to coding, billing, and
clinical departments?

Audits results are presented at

quarterly Compliance Advisory
Committee meetings. Results are
shared with responsible departments
promptly.

Audit findings are reported and

education is initiated.

Is the necessary education performed

to address compliance issues?

Following reporting of auditing results,

training sessions are scheduled.

Education is conducted; errors are

reduced.

Have auditing and education

improved the results? Have processes
changed as a result of audit findings?

Perform follow-up audits to access

the effectiveness of retraining.

Additional training is performed as

needed; errors are reduced.

Is the coding compliance department

properly organized? Do employees
have the necessary qualifications to
accurately assess coding?

Coding compliance staff maintain

coding certification. Review staff
credential maintenance on an annual
basis.

Coding staff receive timely updates

on coding and regulatory changes,
reducing the potential for coding
errors.

Does the coding compliance

department have sufficient resources
(staff, budget), training, authority, and
autonomy to carry out its mission?

Budget will contain sufficient resources

for accurate coding including
resources, training, continuing
education opportunities, computer
software, auditing, and consultation
services. The department will assist
with coding services as applicable.

The coding compliance department

will be the health care facilitys expert
resource for coding advice. Adequate
resources reduce the potential for
coding errors.

Are coding compliance issues

thoroughly investigated, researched,
and documented?

Reviews are based on pre-identified

risk areas such as the OIG work plan.
Issues are identified internally and
externally. Coding and regulatory
guidelines are thoroughly researched.

A thoroughly investigated review

demonstrates accuracy and
competence. Proper education
can be conducted.

Does a relationship exist between the

corporate compliance program, the
coding compliance committee, and
the coding compliance department?

Committee structures will be multidisciplinary including coding,

business management services,
administration, and providers as
appropriate.

Communication among the various

departments helps to ensure effective
working relationships and follow
through on compliance issues.

of law. Process measures refer to the manner in which the program seeks to prevent and detect
violations of the law. Outcomes measures refer to the observable, measurable results related to
preventing and detecting violations of law and creating a compliant culture.
Table 5-1 displays the structure, process, and outcome measures as they relate to a coding
compliance program.
Fraud and abuse violations, Medicare review programs, and most recently, the development of the
Medicare Recovery Audit Contractor (RAC) program have brought to the forefront the importance of
good coding and documentation. In 2003, Medicare instituted the Comprehensive Error Rate Testing
(CERT) program. The CERT program measures the error rate for claims submitted to Medicare
Carriers, Durable Medical Equipment Regional Carriers (DMERCs), and Fiscal Intermediaries (FIs).
Another program that monitors the accuracy of Medicare payments is the Hospital Payment

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Monitoring Program (HPMP). This program measures the error rate for the Quality Improvement
Organizations (QIOs).
The CERT program reduced the errors in Medicare reimbursement from 9.8% in 2003 to 3.9%
in 2007. Although the reduction in the error rate was significant, Medicare determined that the 3.9%
equated to $10.8 billion in Medicare overpayments and underpayments.
Also in 2003, under section 305 of the Medicare Prescription Drug Improvement and Modernization
Act, Congress directed the Department of Health and Human Services (HHS) to conduct a threeyear demonstration program using Recovery Audit Contractors (RACs). The demonstration program
operated in New York, Massachusetts, Florida, South Carolina, and California and ended in 2008. The
RAC reviewers found more than $1 billion in improper payments to the Medicare program. In 2006,
Congress passed legislation to make the RAC program permanent and required expansion to all
50 states by no later than 2010.
The RAC program identified a number of sources for the errors including excessive units of service
billed, incorrect discharge disposition, medical necessity, and coding. Although the largest percentage
of errors was medical necessity (62% based on the audit findings through March 27, 2008), coding
contributed to greater than 25% of all errors found. Incorrect assignment of the principal diagnosis
contributed to 14% of the errors, and incorrect procedure codes contributed to 12% of the errors.
Some coding errors identified included respiratory system diagnoses with ventilator support, excisional
debridement, pneumonia, sepsis, and circulatory system diagnoses.
Programs such as CERT and RAC demonstrate the need to establish coding policies that address
internal and external auditing and accuracy. Policies should address coding processes when auditing is
performed prebilling, such as for assessing individual coder accuracy or addressing specific problem
areas. Policies should also include measures to be taken when a postpayment review occurs, such as
in the case of CERT or RAC reviews.
It is important that the coding compliance program include policies that help ensure accurate
coding and billing as well as stress the importance of good documentation. Policies should incorporate
documentation requirements, payer policies, and coding guidelines. The policy will generally include an
overall policy statement regarding the organizations commitment to compliant coding and a direction
that coders observe official coding guidelines. The following checklist can be used to address specific
policy issues and serve as a basis for reviews:
Is the importance of provider documentation emphasized? The providers documentation must
support every code assigned. In the ICD-9-CM Official Guidelines for Coding and Reporting,
provider means physician or any qualified health care practitioner who is legally accountable
for establishing the patients diagnosis.
When and how should a coder query the physician? Review the physician query process,
addressing related issues such as correcting errors and amending the medical record.
What is the process for ensuring that codes assigned through the chargemaster are
accurate? Review the developmental process for charges including the chargemaster
description of the service, code assignment, and applicable dosage units and other units
of service.
Do policies address resources and instructions for ICD-9-CM, CPT-4, and HCPCS coding?
Develop and frequently review facility-specific coding guidelines and policies, ensuring
consistency with official guidelines and federal regulations.
Are there specific coding areas that represent a compliance risk, and are instructions provided
that address them?

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Does the policy emphasize that coding guidelines must be applied to all record types?
Do policies address new-hire training and continuing education? Are coding resources adequate,
and is there support and education for coding professionals?
How are coding errors identified? The policy should address how internal coding audits are
conducted, reported, and followed up. Discuss the process for addressing coding errors
identified through prepayment or postpayment reviews.
What documentation should be utilized to assign codes? How should documentation that is
incomplete, unsigned, or missing be considered? The entire medical record should be reviewed
to determine the specific reason for the encounter and the conditions treated.
Are all staff educated on the importance of quality documentation, risk identification, and
accurate coding and billing?
How are issues related to denials or rejected claims relayed to coding?
What is the process for making coding changes or corrections?
Are issues such as upcoding, medical necessity, and DRG optimization addressed in policy?
Does the policy address abstracting issues that may affect reimbursement such as
admission and discharge status, present on admission (POA) criteria, and accurate
demographic data?
Are claims submitted to billing before coding review or before all appropriate codes have been
added?
Does the policy address the appropriate utilization of modifiers and variances in payer billing
requirements? What is the process for addressing variances in official coding guidelines and
coding advice from payers?
Does the organization code directly off superbills and encounter forms? How does the facility
ensure that the documentation supports the services billed?
As mentioned earlier in this chapter, within the corporate compliance program the code of conduct
serves to guide employees in making ethical and compliant choices. Similarly, within a coding
compliance program, a code of conduct should be developed that addresses compliance with coding
guidelines and the responsibility to report coding compliance violations. The practice of upcoding
or downcoding and the selection of codes that affect reimbursement such as complications and
comorbidities should be addressed. For physician coding, guidelines should be established for selecting
the appropriate evaluation and management code (for example, 1995 or 1997 CMS guidelines). For
hospital coding, the importance of accurately reporting POA indicators should be included. The code
of conduct can be incorporated with professional coding associations codes of ethical behavior, such
as the AHIMAs Code of Ethics and Standards of Ethical Coding, the American College of Medical Coding
Specialists (ACMCS) Code of Ethics, and the AAPCs Medical Coding Code of Ethics.
A coding compliance program may be an integral part of a broader health information management
compliance program, which may include privacy and security issues of health records. As mentioned
previously, the specific makeup of the coding compliance program will depend on the type and size
of the organization. Regardless of whether an organization has a corporate compliance program or a
health information management compliance program, a coding compliance program can be developed
to address regulatory issues, coding policies, and coding integrity. Whether the health care organization
consists of a single physician in private practice, a 25-bed critical access hospital, a 1000-bed teaching
hospital, or a multiorganizational health care network, a coding compliance program can demonstrate
the providers commitment to compliant coding and billing.
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Coding Compliance Education

Policies and procedures are only one part of the coding compliance program. Coding compliance
education is a key element. Without it, the efforts of the coding compliance program are reduced to
being only as good as the paper it is printed on. The purposes of an aggressive and thorough coding
educational program include:
Promoting an understanding of coding guidelines and federal regulations
Implementing the policies and procedures developed and ensuring that employees understand
their role in the compliance process
Demonstrating the organizations commitment to compliance to employees, outside reviewers,
and regulatory agencies.
Compliance education will vary based on the needs of the institution and will vary for new and
existing employees. Educational needs should be assessed at least annually. In a large facility,
regularly scheduled classes can be held on topics that are typically complex or areas of high risk.
Smaller offices or facilities may wish to combine resources to bring educational opportunities to
their coders. Offering convenient classes during work hours helps ensure that coders will obtain
necessary education. Such classes can also provide opportunities for certified coders to obtain
CEUs. Establishing regular educational classes also provides evidence of the organizations
commitment to compliant coding. Some examples of fundamental coding classes that could be
offered include:
Evaluation and management coding
Modifier usage
CPT-4/ICD-9-CM coding
Global period coding and billing (general or specific topics of interest)
High-risk coding areas such as debridement (excisional and nonexcisional), interventional
radiology, sepsis and urosepsis, preventive medicine
Regulatory issues such as the proper use of the advance beneficiary notice (ABN) and local and
national coverage decisions
Payment methodologies including Medicare Severity Diagnosis-Related Groups (MS-DRGs),
Ambulatory Payent Classifications (APCs), Ambulatory Patient Groups (APGs), and physician fee
schedules
Consultations and shared visits
Midlevel provider coding
Using the proper coding resources, including using the Internet to research regulatory or coding
issues
The list and type of educational opportunities that can be offered are limitless. Offering
opportunities for coders to gather in a coding roundtable format provides valuable opportunities for
coders to discuss real-life coding examples with their peers. Educational sessions on clinical topics
can be especially helpful for specialty coders who wish to gain insight into complex procedures.
Anatomy classes can be especially helpful for coding orthopedics, obstetrics and gynecology, cardiac
procedures, and interventional radiology. Topics should also include issues identified through coding
reviews and audits.
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Some organizations offer extended educational programs to coders designed to enhance coding
education and to prepare individuals for coding certification exams. These programs bring the classroom
to the workplace. Many offer semester-length courses in medical terminology, ICD-9-CM, CPT-4,
pharmacotherapy, anatomy and physiology, and reimbursement methodologies. Numerous outside
educational resources can be utilized for these classes, or the organization may choose to employ its
own coding instructors.
Educational opportunities for employees should be flexible, allowing for just in time training for
immediate educational needs. Just in time training can address the constantly changing regulatory
requirements or coding errors that have been identified. Utilizing just in time training for new employees
can help prevent unintentional coding errors. All education provided should be well documented, noting
the date, topic, length, and names of attendees. Figure 5-1 shows a schedule of classes that could
be ongoing. Figure 5-2 shows an organizational in-house coding curriculum. Offering on-site continuing
education units to coding staff provides an opportunity for coding professionals to maintain coding
certification conveniently and cost effectively.
Most professional coding associations that provide certification or accreditation to their members
require continuing educational hours. The number of hours will vary with the associations requirements.
The associations will also vary as to what they accept as an approved CEU. Some associations require a
preapproval process before continuing educational hours can be accepted. Maintenance of certification
should be required of coding staff to demonstrate that they are receiving updates on coding and
regulatory changes.

Coding Accuracy
Along with providing coders continuing education and training updates, their accuracy rates should be
periodically evaluated. Not only is coding accuracy critical for compliant claims submission, but it also
affects the providers complication rates, mortality rates, severity of illness computations, health care
policy, and other administrative databases. Coding accuracy can also affect future rate setting figures
and prospective payment system payment weights.
In some organizations coding accuracy is a goal measured in employee performance evaluations.
Coding accuracy rates can also be used to determine salary and annual raises.
In determining coding accuracy it is important to distinguish coding errors that result from inaccurate
code assignment verses errors that result from poor documentation. Documentation errors should not
be counted as coding errors. Consider the following documentation errors that could result in coding
errors:
The physician documents that the patient has pneumonia. Documentation elsewhere in the
medical record indicates that the patient may have a bacterial pneumonia. The physician fails
to respond to repeated query attempts. The coder assigns ICD-9-CM code 486, Unspecified
pneumonia.
The physician documents that the patient suffered both bone fracture in the right lower arm.
An open reduction with internal fixation is performed. The coder is unable to assign an accurate
code because the documentation does not indicate the specific site, for example, proximal end,
distal end, or shaft.
Under the review of systems in an evaluation and management (E/M) note, the physician
documents, Pertinent to headache addressed in HPI, others negative. The physician should
indicate the specific systems reviewed and all others negative. The phrase others negative
should not be used to indicate a complete review of systems.
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General Hospitals Coding Compliance Course Offerings

USING THE TRICKS OF THE TRADE: This class will provide instruction on using the 3-M Encoder, Code-Correct and the CMS website,
including finding the Medicare fee schedule. (1 CEU)
THE BASICS OF MEDICARE: This class will focus on the basics of Part A and Part B Medicare services, including beneficiary benefits,
contractors, local and national coverage decisions and fee schedules. (2 CEUs)
EVALUATION AND MANAGEMENT (E/M) DOCUMENTATION AND CODING: This class will provide a review of documentation
requirements for E/M services using the 1995 and 1997 guidelines. The use of E/M codes will be discussed, including definitions, E/M
components and medical necessity. Participants will learn to apply codes from medical documentation. (2 CEUs)
THE OFFICE OF INSPECTOR GENERAL (OIG): Learn about the regulatory authority, regulations, audits, inspections and mission of the
OIG in this class. A review of OIG targets for the current year will also be discussed. (1 CEU)
DOCUMENTATION GUIDELINES FOR TEACHING RULES AND MIDLEVEL PROVIDERS: This class will provide a review of documentation
requirements, focusing on the teaching physician and midlevel provider requirements. Participants will discuss compliance issues and
will review medical documentation. (2 CEUs)
The PHYSICIAN QUALITY REPORTING INITIATIVE: This class will provide a background on the Physician Quality Reporting Initiative
(PQRI) measures and provide helpful information on appropriate coding and modifier usage. (1.5 CEUs)
THE CORRECT USE OF MODIFIERS FOR PHYSICIAN AND FACILITY: This class will provide an overview of the correct use of modifiers
for physician and facility (hospital) services. Participants will discuss the use of modifiers and CCI Edits as they pertain to professional
and facility services and will apply CPT/HCPCS modifiers in exercises. (2 CEUs)
CONSULTATIONS AND SHARED VISITS: This class will focus on the CMS guidelines for consultations and shared visits. Appropriate
billing for these services will also be discussed. (1 CEU)
NEW! RECOVERY AUDIT CONTRACTORS (RACs): Learn what all the fuss is about with the RAC ATTACKS! This class will discuss CMS
efforts to identify improper payments to providers through the use of RACs, the experiences of providers who have had RAC audits and
the scheduled roll-out for our State. (1.5 CEUs)
NEW! PREGNANCY AND GYNECOLOGICAL CODING: Chapter 11 of ICD-9-CM contains codes for normal pregnancy and delivery,
miscarriage, abortion and various obstetrical complications. If you dont regularly code obstetrical cases, you may find this chapter a
challenge. In this class, participants will review ICD-9-CM coding guidelines for pregnancy and gynecological conditions, along with
pertinent HCPCS coding. A review of common payer payment guidelines will also be included. Send us your toughest coding questions
before the class! (1.5 CEUs)
SKIN LESIONS AND LACERATION REPAIR: Dont get burned coding common skin procedures. These seemingly easy procedures can be
some of the most complicated services to code. This class will guide the participant through the coding guidelines and present clinical
examples. (1 CEU)
GI ENDOSCOPY CODING: This class will focus on gastrointestinal coding, specifically coding upper and lower endoscopies. Participants
will discuss CPT and Medicare guidelines for coding colonoscopies, including reviewing screening versus diagnostic procedures. Correct
use of modifiers and local coverage decisions (LCDs) will also be discussed. (2 CEUs)
WORKING DENIALS/THE APPEAL PROCESS REVISED: One of the most important elements of accurate coding and billing is
eliminating as many billing problems as possible before they occur. But working denials can be the coders worst nightmare. This class
will focus on methods to help you work denials and prevent them in the future. (1 CEU) NEW ADDITION! This class will also include a
review of Medicares denial and appeal process. (2 CEUs)
NEW! PREVENTIVE MEDICINE: This class will assist the participant in determining whether the visit is a preventive medicine visit or
an office visit. Documentation requirements will be discussed, as well as the definitions of the comprehensive history and physical
examination, anticipatory guidance, ordering of tests, and management of other medical problems. Medicare and commercial payment
policies will also be discussed. (1.5 CEUs)
NEW! RESEARCH CODING AND BILLING: This class will guide participants in the proper assignment of V70.7, Examination of
participant in clinical trial, and will discuss CMS current requirements for coding and billing for patients involved in clinical trials/
research. (1.0 CEU)

Figure 5-1 Coding Compliance Course Offerings. Example of listing of coding courses that could be offered
regularly as part of a coding compliance program. Offering continuing education units to coding staff on site
provides an opportunity for coding professionals to maintain coding certification conveniently and cost effectively.
Coding courses may be tailored to address specific coding areas of concern.

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General Hospitals Coding Curriculum

Course

Date/Time

Medical Terminology
Start date: September 9
End date: December 5
Room: HIM Education Suite

Tuesday: 1:303:30 p.m.

Friday: 8:3010:30 a.m.

Pharmacotherapy
December 9 and 12
Room: HIM Education Suite

CPT
Start date: September 8
End date: October 30
Room: HIM Education Suite
ICD-9-CM
Start date: January 12
End date: March 9
Room: HIM Education Suite
Certification Review
September 15
Room: HIM Education Suite

Students will learn medical terminology through a

combination of anatomy and physiology and word
building principles, focusing on the component
parts of medical terms: prefixes, suffixes and word
roots. Students practice formation, analysis and
reconstruction of terms. Introduction to operative,
diagnostic, therapeutic and symptomatic terminology
of all body systems, as well as systemic and surgical
terminology, is included.
Tuesday: 1:303:30 p.m.
This course places an emphasis on the understanding
of the action of drugs such as absorption, distribution,
Friday: 8:3010:30 a.m.
metabolism and excretion of drugs by the body.
Included are drug classifications, most commonly
prescribed drugs for each body system, and
pharmacotherapy references including the formulary
and PDR.
Monday: 2:004:00 p.m.
This class covers theories, concepts and applications
of Current Procedural Terminology (CPT) coding.
Thursday: 2:004:00 p.m.
Included will be an introduction to basic coding
principles, and conventions of CPT coding for each
of the CPT manual sections.
Monday: 10:00 a.m.12 p.m. This class discusses theories, concepts and
(no class 2/16)
applications in ICD-9-CM diagnostic coding. This indepth advanced ICD-9-CM course includes practical
Thursday: 3:005:00 p.m.
exercises and discussion of official coding guidelines.

September 15:
1:304:30 p.m.

OR
November 5
Room: HIM Education Suite

Course Description

This class provides a review of certification exams,

including a breakdown of exam sections, time
allotments, as well as other important information.
Class also includes study tips and a sample study
schedule, and recommended resources. A brief review
of coding competencies will also be discussed. Mock
exam will be given and reviewed during class.

Notes
24 class periods
(Recommended
before taking
coding courses)

2 class periods

16 class periods

16 class periods

1 class period

November 5: 9:00 a.m. to

12 p.m.

OR
March 12
Room: HIM Education Suite
Regulatory Issues
March 18
Room: HIM Education Suite

March 12: 9:00 a.m.

12 p.m.
March 18: 8:00 a.m.
12 p.m.

This class discusses various reimbursement

methodologies including ambulatory surgical center
payment rates (APCs), clinical laboratory fee schedule,
hospital inpatient prospective payment system,
hospital outpatient prospective payment system,
inpatient psychiatric facility prospective payment
system, Medicare physician fee schedule, the
UB-04 and CMS 1500 claims. A review of the hospital
and physician chargemaster development and
maintenance will be presented.

Figure 5-2 General Coding Curriculum. Example of an in-house coding curriculum offered as part of a coding
compliance program. These classes may be eligible for continuing education units (CEUs).
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A patient has a diabetic ulcer of the left ankle that requires debridement. The documentation
of the debridement does not indicate the deepest level debrided or the method of debridement
(excisional or nonexcisional). The documentation does not indicate whether the patient has
Type 1 or Type 2 diabetes. The coder is unable to correctly identify the type of diabetes, the
extent of the debridement, and whether the debridement was excisional or nonexcisional.
The physician documents the removal of a 2.0-cm benign lesion of the upper arm. The physician
documents that adequate margins were taken to ensure complete removal. The coder assigns
the code for a 2.0-cm lesion removal, as the physician failed to document the specific excised
diameter.
As documentation errors should not be counted as coding errors, neither should billing errors or
chargemaster errors be counted as coding errors. For example, codes that are entered into a coding
or abstracting system but do not cross over accurately to the claim should not be counted as a coding
error. An error in the chargemaster that incorrectly cross-walks a charge code to a CPT-4 or HCPCS code
is not a coding error. When billing denials occur because payers do not follow coding guidelines, these
are also not coding errors.
Accuracy standards should be consistent among all coding areas, such as hospital inpatient,
outpatient, ancillary services, and physician coding. Nationally, the recognized best-practice standards
indicate that a minimum of 95% accuracy is desirable. Some organizations may introduce incentive pay
for accuracy rates that are higher. Coding reviews on individual accuracy rates should be performed at
least biannually. An individuals accuracy rate can indicate the frequency of the review. For example,
for a coder who is maintaining 95% accuracy, reviews can be performed only twice a year. For a coder
failing to maintain the accuracy rate, reviews can be quarterly or even monthly. If coding accuracy is
linked to salary and performance expectations, human resource policies should clearly outline the
necessary disciplinary steps to assist the employee in achieving the performance goals. This may
include additional training, a formal educational plan, or 100% coding review. Performance expectations
in regard to coding accuracy should be clearly communicated to new staff at the time of hiring.

The Coding Compliance Manager and Coding

Compliance Committee
Many health care organizations create a position of coding compliance manager, but this will vary
depending on the individual needs of the facility. In smaller settings, the coding compliance manager
may have other responsibilities such as coding manager or health information management (HIM)
director. The coding compliance department may consist of one individual who has multiple
responsibilities or an entirely separate department with multiple employees. The coding compliance
department may be part of a facility's overall compliance area. The coding compliance manager may be
responsible for monitoring and conducting audits as well as identifying risk areas. Other responsibilities
include conducting educational and training programs, reporting issues, monitoring changes in federal
and state guidelines, and ensuring that coding vendors (billing vendors, coding consultants) understand
the institutions coding compliance guidelines. This individual will likely have an extensive coding
background applicable to the organizations setting (e.g., hospital inpatient and outpatient, physician
services, long-term care, teaching rules). An understanding of federal and state regulations is also
important. Other desirable skills and knowledge sets include:
Familiarity with fraud and abuse regulations
Chargemaster or charge creation experience
Claims and billing experience
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Coding Compliance Manager Job Description

Purpose: To maintain the Corporate Compliance Program for ABC Hospital in accordance with ABCs Hospital Corporate Compliance
Manual and the Office of Inspector Generals Compliance Program Guidance.
Description: The Coding Compliance Manager manages, oversees, and monitors the audit process for the coding and billing operations.
Responsible for:
Overseeing the Recovery Audit Contractors (RAC) audits and other outside payer audits, responding to denials, and ensuring timely
responses.
Developing and implementing audit plans.
Preparing correspondence, reports, and presentation materials.
Serving as a subject matter expert in coding, billing, MS-DRG coordination, reimbursement, and compliance, as well as specific laws
and regulations imposed on health care systems.
Managing and developing in-service educational programs and informational materials.
Assisting the VP, Health Information Manager, and Chief Compliance Officer in the development and implementation of RAC and
other audit appeal strategies.
Managing and directing the operations of the compliance review program, including supervising Coding Compliance Analysts.
Keeping pace with the latest developments, advancements, and trends in coding, billing, reimbursement, laws, and regulations
imposed on health care.
Minimum Qualifications:
Education: Bachelors degree in Health Information Management (HIM), Business Administration or related field or an equivalent
combination of education and experience.
Experience: 510 years experience in healthcare business practices relative to coding, billing, auditing, utilization, third-party
payer regulations, risk assessment, reimbursement and contractual agreements, management and supervision. Expert knowledge
of ICD-9-CM, CPT-4, and HCPCS classification systems, as well as MS-DRG, APC and other reimbursement methodologies.
Licensure/Certification: RHIA, RHIT, CCS, or CPC-H
Other: High moral and ethical character with a sense of honesty, integrity and caring. Independent, objective, detail-oriented, and
analytical. Must possess excellent verbal presentation and education skills.
Contacts:
Reports to: Executive Vice President, CFO, CRO.
Relationship with: All levels of management and administration, department directors, physicians, nurses, ancillary staff, practice
managers, coding and billing staff, registration staff. Reporting liaison with CRO, local board, ABCs Hospital Compliance Program
Committee.

Figure 5-3 Coding Compliance Manager Job Description.

An understanding of the relationship between coding and billing
Familiarity with the local Medicare contractor
Communication, management, and human relation skills
The coding compliance manager may report to the organizations compliance officer, HIM director,
director of finance, or directly to the chief operating officer (COO). The coding compliance manager
should have a current coding certification. See Figure 5-3 for a job description for a hospital coding
compliance manager.
The coding compliance manager may be supported by staff that perform auditing, education, and
other compliance activities. Titles of these individuals will vary but may include coding compliance
auditors or reviewers, coding auditors, medical auditors, or compliance specialists. To gain the respect
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Coding Compliance Analyst Job Description

Purpose: To perform audits in accordance with ABCs Health Systems annual Compliance Work Plan and prepare written and oral
communications to the Coding Compliance Manager and/or Corporate Compliance Officer.
Description: The Coding Compliance Analyst supports the organizations corporate integrity program through the identification and
assessment of coding compliance risk and maintains a current understanding of regulatory trends and changes in coding policy and
reimbursement methods.
Serves as a resource for coding and clinical staff on issues related to compliant coding and billing
Applies knowledge of medical terminology, abbreviations, anatomy and physiology, diseases, and procedures to accurately review
coding assignments
Applies knowledge of ICD-9-CM, CPT-4 and HCPCS nomenclature, coding rules, guidelines and proper sequencing to analyze
medical record documentation and coding assignments
Applies knowledge of ethical coding principles and revenue cycle activities to evaluate coding compliance through coding audits
Works with departments and physicians to monitor compliance to coding standards and provide guidance to help them meet the
requirements
Assists departments and physicians in development of corrective action plans involving coding issues when areas of opportunity are
identified
Receives, develops, coordinates and/or oversees internal and external coding audits for the purpose of monitoring and detecting any
misconduct or noncompliance to final resolution.
Assist in the development of coding education plans, materials, and resources to educate employees with respect to overall
objectives of the corporate compliance program
Carries out all duties and responsibilities as assigned by the Coding Compliance Manager, Chief Compliance Officer and/or the
Compliance Committee.
Minimum Qualifications:
Education: Associates Degree in Health Information Management or related field preferred.
Experience: Minimum three years of diagnostic and procedure coding. Experience with Microsoft Word and Excel, encoder products,
auditing software preferred.
Licensure/Certification: RHIA, RHIT, CCS, CPC-H
Other: Detail-oriented and analytical. Strong customer service and communication skills. Ability to operate various computerized
medical coding and information processing systems. Exceptional organization skills. Ability to analyze medical records and create audit
reports that assist physicians, management and hospital staff in understanding coding compliance issues.
Contacts:
Reports to: Coding Compliance Manager.

Figure 5-4 Coding Compliance Analyst Job Description.

of the coding staff whose work is being reviewed, the auditors must be highly experienced in the area
they are auditing. Utilizing individuals who are not responsible for the actual coding and billing processes
within the organization will help demonstrate objectivity of the coding review and credibility of the
auditing process. Figure 5-4 is a typical job description for the position of coding compliance analyst.
Many organizations utilize outside consultants or companies to perform coding audits. This can
provide a valuable educational experience, as good consultants will be able to share best practices of
several organizations. Consultants can also be utilized when the structure of the organization is small,
and individual or independent reviews within the coding department are not possible. Prior to an outside
audit, consultants should be provided with the coding policies and procedures that are used within the
organization. Consultants should also be aware of local Medicare policies or state regulations that directly
affect the organizations coding. Even if an organization has its own coding compliance department,
consultants can be utilized periodically to assess the accuracy of the coding compliance auditing.
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The coding compliance department and manager should be viewed as a valuable resource for other
departments in the organization for answering coding and billing questions as well as for reporting
potential compliance issues. The coding compliance program that runs like a police state will not provide
a means for employees to seek advice or to report potential problems. Employees within the coding and
billing areas, as well as other departments, should be encouraged to report potential compliance issues
to the coding compliance manager.
A coding compliance committee should be part of the coding compliance program and have
representatives from finance and accounting, administration, business office services, clinical staff,
utilization management, and coding services. In some organizations, the coding compliance committee
may function in cooperation with other committees, such as the chargemaster or medical record
committee. The committee can discuss issues related to claims management, documentation, coding,
duplicate billing, and issues relating to medical necessity. The committee can also share resources
related to coding updates and regulatory changes.
The compliance committee structure should help foster communication among the various
departments. The importance of communication among coding, billing, and patient accounts
departments cannot be overstressed. In many organizations denial information is not shared with
the individuals who are responsible for coding. As a result, coders may not be aware of coding
errors that led to payment denials or delays. Communication among departments can result in
immediate cost benefits owing to decreased denials, fewer delays in payment, and improved
coding accuracy.
The activities of the coding compliance program must be carefully documented and may include:
Summaries of compliance committee minutes, including approvals of the compliance plan or
calendar and any policies/procedures
Employee background, including rsums demonstrating coding qualifications, certifications,
and ongoing continuing education
Training and education agendas, handouts, and attendance rosters
Hotline reports and investigations
Corrective action including employee education, discipline, self-disclosures, rebilling, and policy/
procedure revisions
Monitoring and auditing activities

Stafng Coding Professionals and Coding Certication

Coding staff should be required to obtain the necessary training and education needed to accurately
assign diagnosis and procedure codes. Hiring unqualified individuals to perform coding duties can lead
to fraudulent coding and billing and be viewed as lack of commitment to compliant coding and billing.
Along with a thorough understanding of coding systems, it is preferable that coders have course work
in medical terminology, anatomy and physiology, pathology, and reimbursement systems.
When hiring certified coding individuals, it is important to recognize that there are several
associations and organizations that provide coding certication, and the individual requirements for
obtaining certification will vary. For example, the fact that a coder is certified may demonstrate that
the individual has met only the minimum necessary standards of the professional association and has
passed a certification exam. Other associations provide certification to individuals who pass an exam
that reflect a mastery skill in a particular coding area.
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It is important to understand the associations educational requirements, certification maintenance

policy, and underlying philosophy. For example, some businesses and associations grant a coding
certification after attendance at a day-long coding seminar. Others may provide coding seminars in
a 40-hour boot camp format and then certify individuals after they have successfully passed an
examination. Still other certifications are associated with approved programs in technical schools and
universities. The educational requirements for coding certification vary from none required to high school
diploma to associate and bachelor degrees. The phrase truth in advertising is important for both the
organization that is hiring the certified coder and the coder who seeks certification. There are numerous
examples of coders who spent hundreds of dollars on a coding certification course and exam only to
learn later that the credential is not recognized by the majority of health care providers. There are an
equal number of examples of employers who have hired individuals with letters after their name and
a coding certificate in hand, but the individual could not perform entry-level coding. Certification alone
does not indicate coding competence. The ideal candidate will likely have a combination of education,
training, certification, and experience.
Several professional coding associations offer specialty coding certifications. For instance, there
are coding certifications that emphasize hospital (facility) coding, professional (physician) coding, and
specialty coding (e.g., dermatology, interventional radiology, emergency department). There are also
certifications that represent apprenticeship or associate status, indicating that the individual has
passed an entry-level coding exam but may be lacking in experience.
A coding exam should be administered to all potential employees. The exam should include
questions replicating actual coding scenarios reflective of the facility and the specific position.
Questions on regulatory requirements, coding guidelines, basic anatomy and physiology, and medical
terminology can help gauge an individuals knowledge of the entire coding process. Including general
compliance questions that assess how an individual might respond to a specific situation can provide
valuable insight into the applicants ethical behavior and understanding of compliance guidelines.
Consider these examples of questions that appear on a hiring coding test:
1. The physician has marked the diagnoses and services performed for a patient on a
superbill. You notice that the dictated documentation from that visit includes different
diagnoses. You should:
a. Select the code(s) noted by the physician on the superbill.
b. Determine the code(s) yourself from the physicians documentation.
c. Use a combination of both sets of codes.
d. Query the physician.
2. You are the hospital coder responsible for coding ancillary visits, specifically, radiology
and laboratory services. You notice that orders originating from a local physicians office
always has the same diagnosis code noted, specifically Pneumonia, ICD-9-CM diagnosis
code 486. This occurs regardless of the specific tests that were ordered. You should:
a. Assign the diagnosis listed on the order.
b. Assign diagnosis codes based on the results of the tests.
c. Inform the coding supervisor of the questionable diagnosis.
d. Telephone the physicians office receptionist.
Questions such as these can help assess the employees possible response to difficult problems
and potential conflicts.
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Coding Performed by Physicians

Sometimes, physicians may feel they should assign their own codes. Just as the coder should be
skilled in correct coding assignment, the physician should be trained in ICD-9-CM and CPT-4 coding, the
official coding guidelines, and state and federal regulations. But often, physicians are not able to spend
the time necessary to be fully informed about the complex coding guidelines, frequent changes, payer
billing requirements, and regulatory updates. Consequently, the physician's practice can be placed at
risk for fraudulent coding and billing. Many coding auditors can attest that coding performed entirely by
the physician who is not familiar with coding guidelines is often less accurate than coding performed by
experienced coders.
The physician should not be entirely excluded from the coding process, however. The importance
of their documentation and requirements needed to accurately assign codes should be stressed
with physicians, and such discussion can close the communication gap that often exists between
physicians and coders. As mentioned elsewhere in this book, the coding can be only as good as the
documentation.

Coding Compliance Resources

Within the coding compliance program should be a commitment to utilizing the appropriate coding
resources. Using outdated coding resources can result in coding and billing errors and pose a
compliance risk for the organization. It is often surprising the number of denials that can be immediately
traced back to using an outdated code book or superbill. Coding resources that must be kept up-to-date
include:
International Classication of Diseases, 9th Revision, Clinical Modication (ICD-9-CM) code book
Current Procedural Terminology (CPT-4) code book
Health Care Common Procedure Coding System (HCPCS) Level II Coding Procedures code book
National Correct Coding Initiative (NCCI) manual or electronic file
Computerized encoding systems
The most recent update to the ICD-9-CM Ofcial Guidelines for Coding and Reporting
AHAs Coding Clinic for ICD-9-CM
AMAs CPT Assistant
Encounter forms, billing sheets, superbills
Coders should also have access to the numerous online resources that can assist coding accuracy
and reduce the possibility of future denials. These include access to local and national payer coverage
decisions, local contractor Web sites, the CMS Web site, and regulations published in the Federal
Register. Other valuable resources available online include medical terminology aids, medication and
pharmacy information, resources on specific diseases, anatomy plates, and details on surgeries and
procedures. A detailed listing of Web sites can be maintained and should be regularly updated.
The development of a coding compliance program does not need to be onerous. Many facilities
already have policies on coding, billing, and documentation. The OIG Web site contains many
publications helpful in developing compliance programs. Professional associations also have examples
of coding compliance structure and policies that provide assistance in the development of a coding
compliance program. It is important that the coding compliance program is not left on the shelf. A
program that is on paper only will not protect an organization from fraud and abuse risk and liability.
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Chapter Review
1.

List the seven components of a corporate compliance program and briefly describe each.

2.

If a health care facility has an overall compliance program, why is it necessary that the facility also
have a coding compliance program? How are the two programs different?

3.

The OIGs Compliance Program Guidance for Hospitals states, Because incorrect procedure coding
may lead to overpayments and subject a hospital to liability for the submission of false claims,
hospitals need to pay close attention to coder training and qualifications. What measures can
health care facilities take to ensure that coders are properly trained and are qualified?

4.

Review one of the areas that should be included within a coding compliance policy, for example,
coding from incomplete records, making coding changes, or documentation that should be reviewed
for coding purposes. Write the policy statement(s).

5.

Define the purpose of the code of conduct, and identify some of the issues that should be
addressed in the code.

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6.

Explain why documentation errors are not necessarily coding errors.

7.

Define the characteristics, responsibilities, and qualifications of the coding compliance manager.

8.

Write a coding question for a hiring test that assesses the potential applicants understanding of
the official coding guidelines.

9.

What factors can demonstrate the trustworthiness of the health care provider?

10. Structure, process, and outcome are components of effective assessment of a coding compliance
program. If the structure question is: Are coding compliance policies reviewed regularly? what
would be the process and the outcome?

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Case Studies
Case Study 1
The coding compliance manager has completed a review of inpatient hospital coding. In a few records
she determines that the coder should have queried the physician to resolve conflicting information in the
medical record. There is an organizational policy on physician queries that discusses the proper format
of a query, but it does not address whether the physician should be queried as a result of findings on
audits or postpayment.
1.

What should a coding compliance program policy include regarding physician queries?

Case Study 2
Within a surgical practice, a few physicians document the CPT-4 procedure code on their operative
reports. Sometimes the coding is correct, but the surgeons are not generally considering coding
guidelines and bundling rules. In a coding audit it is determined that some coders are assigning the
codes as the surgeons have noted on their surgical reports, whereas others appear to be coding from
the documentation within the operative note.
1.

What should a coding compliance program policy state regarding codes within dictated reports and
use of those codes by coders for billing?

Case Study 3
A patient is seen for multiple plantar warts. The physician states in the documentation that multiple
plantar warts were removed with laser. The coder assigns CPT-4 codes 17000 and 17003.
1.

Has the coder assigned the codes accurately?

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2.

Chapter 5

Developing a Coding Compliance Program

What instruction, if any, should be given to the coder and/or the physician?

Case Study 4
A local Medicare contractors Part B policy states: Codes V67.00, V67.09, V67.1, V67.2, and V71.1
are non-specific ICD-9-CM codes that require an additional ICD-9-CM code to specify the disease entity
treated. When a metastasis of the primary neoplasm is suspected, report V71.1 with a secondary
neoplasm ICD-9-CM code (e.g., 196.0198.89) or personal history of neoplasm ICD-9-CM code (e.g.,
V10.00V10.9).
1.

Determine the accuracy of the coding information provided by the contractor.

2.

Provide guidance in the form of a policy statement that would assist the coder in determining how
to accurately assign codes in situations when a primary neoplasm is suspected.

Case Study 5
An outside consulting firm has been hired to perform a coding audit of inpatient and outpatient records
at a hospital. The audit shows the following:
Inconsistent application of HCPCS modifiers. For example, some coders apply the modifier RT/
LT only to Medicare claims, whereas other coders apply them to all payers.
Inconsistent coding of excisional debridement for inpatients. Some coders are assigning
ICD-9-CM procedure code 86.22 when the physician notes the wound was sharply debrided.
Other coders appear to be assigning 86.22 only when the physician notes excisional
debridement.
1.

Create an educational plan that could be used to address the issues identified in the audit.

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2.

Write coding compliance policy statements that could address each of the issues identified.

3.

Are the problems that were identified coding or documentation errors?

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References
American Health Information Management Association. (2008, July 24). Benchmarking coding quality.
Audio seminar/webinar. Available for order at https://imis.ahima.org//orders/productDetail.cfm?pcAU
DMC072408&bURL%2Forders%2FproductByCategory%5FAUD%2Ecfm%3Ft%3D7
American Hospital Association. (2008, July 16). Regulatory advisory; Medicare recovery audit
contractors (RACS): Coding and documentation strategies. Retrieved from http://web.mhanet.com/
userdocs/articles/RAC/AHA_RAC_CodingAdvisory_071608.pdf
Department of Health and Human Services, Office of Inspector General. (2005, January 31). OIG
supplemental compliance program guidance for hospitals. Federal Register, 70(19), 48584875.
Department of Health and Human Services, Office of Inspector General. Work plan for fiscal year 2009
Retrieved from http://oig.hhs.gov/publications/docs/workplan/2009/WorkPlanFY2009.pdf
Hapner, Peggy. (2001, May). Covering the bases of coding compliance [Electronic version]. Journal of
AHIMA, 72(5), 6971.
TMF Health Quality Institute, the Quality Improvement Organization Support Center for the Hospital
Payment Monitoring Program. 2006, January; rev. 2008, March. Hospital Payment Monitoring Program
(HPMP) compliance workbook. Retrieved from http://hpmp.tmfhqi.net/LinkClick.aspx?fileticketnory3jyb
h2U&tabid522&mid1248
Wiggin and Dana, LLC. (2000, March 16). Compliance programs for nursing facilities: Ten steps towards
making a good faith & meaningful commitment towards compliance. Retrieved from http://www
.wiggin.com/pubs/alerts_template.asp?ID737167212000

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