Risk Assessment of Medical Coding Services

Office of Inspector General

By Pati Trites MPA CHBC, with Staff Reporters

Any readers considering enrolling in a medical coding school should read this ME-P.

Why? Because the written policies and procedures concerning proper health insurance and Medicare coding should reflect the current reimbursement principles set forth in applicable statutes, regulations and Federal, State or private payer health care program requirements, and should be developed in tandem with organizational standards.

Furthermore, written policies and procedures should ensure that coding and billing are based on medical record documentation; which is now the “reality” rather than just a “reflection” of the reality.

Focus on the Codes

Particular attention should be paid to issues of appropriate diagnosis codes, CPT, DRG and MS-DRG coding, individual Medicare Part A and B claims (including documentation guidelines for evaluation and management services) and the use of patient discharge codes. The billing company should also institute a policy that all rejected claims pertaining to diagnosis and procedure codes be reviewed by the coder or the coding department. This should facilitate a reduction in similar errors.

Problem Areas

Among the risk areas that some billing companies who provide coding services should address are:

  • Internal coding practices;
  • “Assumption” coding;
  • Upcoding and Downcoding;
  • Alteration of medical records and documentation;
  • Coding without proper documentation of all physician and other professional services;
  • Billing for services provided by unqualified or unlicensed clinical personnel;
  • Availability of all necessary documentation at the time of coding; and
  • Employment of sanctioned individuals.

Assessment

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Billing companies that provide coding services should maintain an up-to-date user-friendly index for coding policies and procedures to ensure that specific information can be readily located.

Similarly, for billing companies which provide coding services, the physician-executive and billing company should assure that essential coding materials are readily accessible to all coding staff.

Finally, billing companies should emphasize in their standards the importance of safeguarding the confidentiality of medical, financial and other personal information in their possession.

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3 Responses

  1. Pati,

    Things have really changed in the era of Health 2.0. Most physicians accept patients whose insurance is supplied by one of the over three-hundred federal healthcare programs. This, in essence, makes physicians “Government Contractors”. The American people, physicians included, become a little more than slightly aggravated when they hear about government contractors charging ridiculous amounts for hammers and toilet seats.

    Physicians and other healthcare providers are now being asked to comply with the government contracting rules regarding documentation of services for appropriate payment.

    Why do physicians have to follow these complicated and time-consuming CPT® rules when they have more important duties to complete? It all boils down to the “Golden Rule.” “He who has the Gold—Makes the Rules.”

    This applies to both Federal insurance programs, private insurers, and whatever health reform political machination may evolve going forward.

    Well done.

    Dr. David Edward Marcinko; MBA
    [Editor-in-Chief]

    Like

  2. Regardless of the codes …

    The Senate just voted to postpone the 21 percent Medicare physician payment cuts until April 1, 2010.

    Amy

    Like

  3. The High Cost of Undercoding

    Caution is a learned reaction to negative experiences and is often a wise course of action in the practice of medicine. In a medical practice billing department however, caution and “compliance phobia” may be costing doctors revenue.

    http://www.physiciansmoneydigest.net/your-practice/The-High-Cost-of-Undercoding

    Hope Hetico RN, MHA
    [Managing Editor]

    Like

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