Strive to achieve coding compliance that really works.
I’m often asked about how one would or should strive for coding compliance and make it happen. The first thing I do is to identify and acknowledge the risks or potential risks that occur. We all know that there are risks across healthcare, and some specific ones within health information management (HIM) and coding. The April 2017 report from Crowe Horwath titled, “20 of the Top Risk Areas in Healthcare”[i] included these risk areas related to clinical coding:
In addition to the above risks, I often watch and then review the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) reports relating to healthcare, as they do provide some very important findings and warnings to take heed of. Then there is your own external and internal auditing of documentation and coding which will help to identify risks.
As a foundation to your coding compliance plan you’ll want to review the OIG seven key compliance elements[ii] as these provide a set of crucial components that can be included into your program:
An additional resource to utilize for your coding compliance program is the American Health Information Management Association (AHIMA) Code of Ethics[iii] for HIM, which includes the following seven elements:
I like to see an organization, company, or practice establish a code of ethics or embrace and acknowledge the AHIMA code as one they follow and adhere to.
To dive deeper into coding compliance, you should also make use of the AHIMA Standards of Ethical Coding iv. This industry gold standard contains eleven (11) principles that make up the basis of the ethical coding:
When building your coding compliance program you’ll also want to have written policies and procedures (P&P) in place. These are not simply a verbal direction, but written and detailed. This is one area I’ve seen and heard over the years that is often missing from a coding compliance program. I also have heard how a P&P for coding is contrary to the Official Guidelines, which would not be appropriate (often there is a financial incentive behind this type of P&P). Some basic P&Ps would include, but are not limited to these examples:
Your P&Ps should be reviewed at least every two years to make adjustments, etc., but more often as needed, such as a regulatory change. More can be said about P&Ps but for the context of this article, the above would be a good place for you to start.
When you have your program in place and operational, you’ll want to assess the overall coding compliance program effectiveness at least every two years (more often if needed) to ensure success and the desired outcomes are being achieved. This assessment may be done by an external resource and would include interviews with staff as well. The coding compliance leadership should be open and engaging, plus have transparency, as this will greatly help your effectiveness and success.
You don’t want to wait for regulators to knock on your door, so ensure you have a strong and achievable coding compliance program that is working. Keep in mind that it’s always best to be proactive rather than reactive when it comes to compliance. I hope you’ll discuss your coding compliance efforts, or lack thereof, now, and not wait for a risk to impact your organization or practice.
Ultimately your coding compliance program/plan will assist with achieving accuracy and integrity with clinical documentation and coding. Making all this happen however, will take time and effort, leadership, dedication, and accountability. I strongly encourage all settings of healthcare to work on and achieve coding compliance that really works!
Program Note
Be sure to listen to Gloryanne Bryant today on Talk Ten Tuesdays at 10 a.m. ET.
[i] Sarah A. Cole: “20 of the Top Risk Areas in Healthcare” Crowe Horwath, April 18, 2017. Available at https://www.crowehorwath.com/insights/healthcare-connection/20-risk-areas-healthcare.aspx
[ii] HHS, Office of the Inspector General: Compliance Guidance. Available at https://oig.hhs.gov/compliance/compliance-guidance/index.asp
[iii] AHIMA Code of Ethics. Available at http://bok.ahima.org/doc?oid=105098#.WqBaAGrwZNB
Iv American Health Information Management Association (AHIMA): Revised Standards of Ethical Coding. May 2017. Available at http://journal.ahima.org/2017/05/10/ahimas-revised-standards-of-ethical-coding-available/
EDITOR’S NOTE: Artificial intelligence was utilized for structural refinement and grammatical editing. All analyses, interpretations, and opinions expressed in this article are solely those of
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