Got coding questions? Your Academy has the answers. Each month we feature a member’s question with an answer provided by AAPM&R’s Reimbursement and Policy Review Committee (RPRC).
Q: If a coding error is made by billing personnel, can the clinician be held responsible?
A: Yes. The clinician is ultimately responsible for claims submitted under his or her NPI. In cases of erroneous or even fraudulent billing, the payer can hold the clinician financially and legally responsible, regardless of practice setting. Clinicians practicing in a hospital can be held responsible for the coding of the hospital system, just as clinicians practicing in an office can be held responsible for the submissions of the office coders. This fact underscores the importance of coding education for both the clinician and billing personnel.
As a precaution, clinicians should consider annual coding education in the form of in-person and online training sessions. Medicare and specialty societies regularly host regional in-person meetings that billing personnel can attend. It may also be appropriate to require billing personnel to clear any changes to clinician coding with the provider. This is especially important for new personnel. Annual internal audits on documentation and coding can also identify problem areas as well as provide educational opportunities for coders and physicians. The website of the Office of the Inspector General maintains a number of resources on compliance programs, which include information on how to conduct annual audits.
Find additional resources related to reimbursement here. Do you have a coding or billing question? Contact AAPM&R at firstname.lastname@example.org for assistance.
Accurate coding is the responsibility of the provider. This article is intended only as a resource to assist in the billing process.