Ensuring Medical Coding Compliance

Medical Coding Compliance Program

In the dynamic landscape of healthcare, ensuring meticulous documentation and accurate coding is paramount for providers in Accountable Care Organizations (ACOs) and Managed Service Organizations (MSOs). Proper coding not only secures appropriate reimbursements but also safeguards against legal and financial risks. At Symbion Coding, we are committed to helping you navigate these challenges through comprehensive compliance programs.

Medicare Shared Savings Program (MSSP)

Participating in MSSP requires rigorous documentation to capture the full spectrum of a patient’s health condition accurately. This documentation is crucial for reimbursement but must be substantiated with evidence to withstand scrutiny. Inaccurate or unsupported diagnoses can lead to severe repercussions, including false claims liabilities and financial penalties.

Risk Assessment

Healthcare executives and compliance professionals must stay informed about the heightened enforcement of the False Claims Act (FCA) related to medical coding. A notable example is the July 2023 case where Martin’s Point agreed to pay over $22 million to settle allegations of submitting inaccurate diagnosis codes to increase Medicare reimbursements for its Medicare Advantage plan. This case underscores the critical need for diligence in managing two key risk areas: inaccurate and unsupported diagnoses.

Preventing False Claims Liability

To mitigate risks and ensure compliance, it is essential to focus on several critical areas.

Supporting documentation is vital for the proper assignment of diagnosis codes. Applying the “MEAT” criteria (Monitor, Evaluate, Assess/Address, Treat) ensures that every diagnosis is substantiated with relevant clinical evidence. This rigorous approach to documentation is not only a best practice but also a protective measure against potential audits and scrutiny from regulators.

Inactive diagnoses must be avoided in current coding. For instance, documenting prostate cancer as active when it is no longer under treatment (or patient had refused treatment) or submitting a code for an acute heart attack when it is a past event can lead to inaccuracies and potential compliance issues. Regular updates to patient problem lists are crucial to maintain the accuracy of the reported conditions. This practice ensures that patient records reflect the current clinical status accurately, avoiding the risk of overreporting or underreporting conditions.

Continuous education on proper coding practices and risk adjustment is vital. Physicians must be equipped with the knowledge to document conditions accurately and comprehensively. Ongoing training sessions and updates on the latest coding guidelines help ensure that the medical staff is well-informed and compliant with current standards.For instance, regarding acute heart attack, ICD-10 guidelines states that heart attack can only be coded as acute within 4 weeks of initial event. After that, it should be coded as an old myocardial infarction.  Documentation should always accompany codes to protect against unsupported RAF scores, ensuring compliance and accurate reimbursement.

Detecting Compliance Issues

Regular audits and reviews are essential for maintaining compliance and identifying potential issues before they escalate:

  • Periodic Audits: Conduct regular record audits to assess the effectiveness of education programs and identify potential overpayments. ACOs and MSOs often face unique auditing challenges due to their structure comprising multiple independent providers with varying documentation methods. Ensuring access to records and proper contractual agreements that allow periodic audits is crucial. These audits help in early detection of discrepancies and provide a roadmap for corrective actions, thereby reducing the risk of non-compliance.
  • Third-Party Review: Engage third-party reviewers to provide an objective evaluation of your compliance status. A reliable partner like Symbion Coding can identify both missed opportunities and unsubstantiated codes that may lead to overpayments. Our audits are designed to uncover hidden risks and ensure thorough documentation aligns with appropriate coding practices. An independent review brings an external perspective, often highlighting areas of improvement that internal teams may overlook.

Value-Add Potential

Through rigorous auditing and compliance programs, thorough documentation that aligns with proper coding can significantly enhance a beneficiary’s RAF score. This proactive approach not only ensures compliance but also maximizes financial outcomes, positioning your organization for sustained success. By improving the accuracy of your coding and documentation, you can achieve higher reimbursement rates and avoid costly penalties associated with coding errors. This value-add extends beyond financial gains, contributing to better patient care and streamlined operations.

Why Choose Symbion Coding?

  • Expert Coders: Our team of certified professionals brings years of experience in medical chart reviews and coding.
  • Enhanced Compliance: Our services help you stay ahead of regulatory changes and minimize audit risks.
  • Comprehensive Services: From chart retrieval to submission, we provide end-to-end solutions.
  • Flat-Fee Pricing: Transparent and competitive pricing with no hidden costs or long-term contracts.

At Symbion Coding, we understand the intricacies of medical coding and the importance of compliance. Our tailored solutions are designed to meet the specific needs of your organization, ensuring you remain compliant while optimizing your revenue streams. Our commitment to quality and accuracy sets us apart in the industry, making us a trusted partner for ACOs and MSOs.

For more information on how Symbion Coding can assist with your compliance needs, visit our Medical Chart Reviews and Medical Coding and Billing Compliance pages.

Stay compliant, stay profitable.

Navigating the Landscape of Governmental Coding Audits: A Comprehensive Guide

Dear Healthcare Professionals,


In an era where regulatory scrutiny is intensifying, the significance of governmental coding audits within the healthcare sector cannot be overstated. These audits serve as a cornerstone for maintaining compliance, ensuring the integrity of medical billing and coding practices. It is crucial to understand the complexities of these audits so you can ensure your practice will be prepared and not be taken by surprise.

I. Introduction to Governmental Coding Audits

At their core, coding audits are systematic reviews conducted to verify the accuracy of medical records coding. These assessments are crucial for compliance and are performed by various governmental agencies, including the Office of Inspector General (OIG), Centers for Medicare and Medicaid Services (CMS), and designated Recovery Audit Contractors (RACs) across specific regions. Their primary aim is to ensure healthcare providers adhere strictly to coding guidelines, thereby guaranteeing correct service level reporting and appropriate reimbursement.

II. Understanding Types of Audits

Coding audits are categorized into two main types, each with a unique focus and implications for healthcare practices:

  • Prospective Audits: These preemptive audits aim to catch errors before claims are submitted, offering an opportunity for correction and preventing future discrepancies.

  • Retrospective Audits: Conducted post-reimbursement, these audits can lead to financial recoupments, penalties, or other corrective measures if inaccuracies are discovered.

III. Audit Methodologies and Selection Criteria

The methodology behind coding audits is meticulously designed to cover various aspects of healthcare provision, employing either random sampling for a broad overview or targeted sampling for specific areas of concern, such as high-risk procedures or services with substantial reimbursement rates. Audits may zero in on areas like Evaluation and Management Services, Surgical Procedures, and Diagnostic Tests to ensure comprehensive coverage.

IV. Penalties and Consequences of Non-compliance

The repercussions of failing to comply with proper coding and billing standards are severe and multifaceted, encompassing:

  • Financial Repercussions: From fines to civil penalties, the financial burden on a practice can be substantial.

  • Exclusion from Federal Programs: Losing the ability to participate in programs like Medicare and Medicaid could be detrimental.

  • Legal Repercussions: In extreme cases, fraudulent practices lead to criminal prosecution.

  • Obligation to Repay: Erroneous billing often necessitates the repayment of overpayments, further straining financial resources.

  • Professional Consequences: Individuals may face the loss of their professional licenses.

  • Reputational Damage: The trust and confidence of patients and peers can be irreparably harmed.

V. Strategies for Mitigating Risks

The pathway to minimizing the risks associated with governmental coding audits is multifaceted:

  • Robust Compliance Programs: Implementing and adhering to stringent compliance protocols is foundational.

  • Continual Education and Training: Keeping abreast of the latest coding guidelines and regulations ensures accuracy and reduces errors.

  • Regular Internal and External Audits: Conducting thorough audits helps identify and rectify potential issues before they escalate.

VI. Conclusion: Your Partner in Compliance

Symbion Coding is committed to guiding you through the complexities of these audits, offering insights and strategies to safeguard your practice. For more insights and assistance, feel free to reach schedule a free consultation at: https://symbioncoding.com/contact-us/ 

Stay compliant and stay ahead!

Best Regards,

Symbion Coding