PAGE: 5 of 5 / REPLACES POLICY DATED: 10/1/1999,
4/1/2001, 9/1/2002, 6/1/2003 (HIM.PHY.006)
EFFECTIVE DATE: March 1, 2006 / REFERENCE NUMBER: GOS.OSG.006
SCOPE: All full time, and part time, and solo-practitioner contract personnel responsible for performing, supervising or monitoring coding of Outpatient Services Group entities including, but not limited to:
Regional Service Centers (RSC) Administration
Management Services Organizations (MSO) Owned Outpatient Clinical Offices
Owned Physicians/Providers Ethics and Compliance Officer
Physician Services Operations Support External Coding Contractors
Physician Services Coding Consultants Physicians at Teaching Hospitals
Physician Services Compliance Consultants
Outpatient Services Group Billing and Coding Compliance
Owned Freestanding Outpatient Centers (e.g., ASC, Imaging Center, Radiation Oncology Center)
PURPOSE: To ensure that all personnel involved in the performance of coding or formalized auditing of coding processes are aware of coding guidelines and coding guideline changes, which may impact complete, accurate and consistent coding.
POLICY: Each person involved in the performance of coding or formalized auditing of coding processes must complete a required minimum of Coding Education (CE) hours per calendar year. Any associated costs will be the responsibility of the practice/entity, Management Service Organization, and/or Regional Service Center.
For physician practice, imaging center and radiation oncology center coders at least fifteen (15) hours of coding education must be completed per year. A minimum of seven (7) CE hours must be accomplished by formal coder education.
For Ambulatory Surgery Center and endoscopy center coders at least thirty (30) hours of coding education must be completed per year. A minimum of fifteen (15) CE hours must be accomplished by formal coder education.
Formal coding education includes but is not limited to attendance at workshops provided by OSG Billing and Coding Compliance, attendance at exit conferences after a coding review, annual review of Company coding policies and procedures. Informal coding education includes but is not limited to reading Part B News, reading Outpatient CNN (Coding News Network), reading CPT Assistant, coding-specific carrier bulletins, etc.).
NOTE: Continuing education requirements outlined in the Continuing Education Requirements Policy, GOS.GEN.007, do not replace this policy. GOS.GEN.007 indicates that any person involved in the performance of billing and/or billing-related services (such as outpatient coding) must complete a minimum of eight (8) education hours per calendar year. Billing credit hours to satisfy this requirement can only be obtained by taking billing courses authorized by Governmental Operations Support (GOS) or OSG leadership in the case of OSG Entity coders.
If an individual is responsible for outpatient physician practice coding only, the outpatient coder must obtain the fifteen (15) hours of continuing education as required by this policy. The eight (8) hours of billing continuing education required in GOS.GEN.007 may be used to fulfill the fifteen (15) hour requirement. The total number of hours required annually for outpatient physician practice coders is fifteen (15).
DEFINITIONS:
Coding: Coding is a function by which there is an assignment of a numeric or an alphanumerical classification to identify diagnoses and procedures. These classifications or “codes” are assigned based on the services provided and documented in the medical record. The classifications utilized for this purpose include: ICD-9-CM (International Classification of Disease – 9th edition – Clinical Modification); CPT (Current Procedural Terminology) or HCPCS Level II (Healthcare Common Procedure Coding Systems).
Outpatient Coder: An Outpatient Coder is an individual who applies outpatient coding and/or documentation guidelines to translate diagnosis and procedural phrases into ICD-9-CM and/or HCPCS/CPT code assignments. The outpatient coding function involves the analysis of medical records to identify relevant diagnoses and procedures for distinct patient encounters.
PROCEDURE:
1. The entity’s Ethics and Compliance Officer (ECO) or Corporate Responsible Executive must designate an appropriate person (e.g., Local System Administrator, Regional Administrator, Office Manager) to track the required education hours.
2. It is the responsibility of the direct supervisor to maintain an education file to ensure that each coder (outpatient or solo practitioner) receives the required coding education per calendar year.
a. The education file must be reviewed semi-annually by the entity’s and/or coder’s direct supervisor/area manager to evaluate individual coding education needs.
b. The education file must minimally contain:
· Copies of credential certification (where applicable),
· Copies of CE forms from educational workshops,
· Copies of attendance forms from exit conferences, and
· Acknowledgment of annual review of all Company policies and procedures.
See Attachment A for a sample of continuing education tracking form.
3. The coder’s direct supervisor must use one of the following methods to track education pursuant to policy:
a. The designated tracking system for Outpatient Services Group.
b. The coder’s direct supervisor will be responsible for providing specific information related to coding continuation education compliance to the facility ECO or Corporate Responsible Executive, whichever is applicable.
4. The designated person will be responsible for reporting completed education hours on a quarterly basis for use in the ECO Quarterly Report.
5. Any coder (inpatient, outpatient or solo practitioner) who does not meet the designated time frame in obtaining the required hours of coding training (new hires as well as annual requirements) must be reported to the ECO by the person’s direct supervisor. The ECO must report the coder’s name and supervisor’s name to the Division President.
The ECO must also include in his/her report, confirmation that an action plan has been developed for the person to complete the required training immediately.
6. The facility must be able to prove compliance with this policy when requested.
7. Formal Coding Education
a. If the healthcare provider performs the coding function, the Regional Practice Administrator, will assign time for each healthcare provider to attend the required hours of formal coding education per calendar year.
b. Attendance at formal education sessions must be pre-approved by the Regional Practice Administrator/Manager.
c. The direct supervisor/manager will assign time for each individual participating in the coding process/coder to attend the required hours of formal coder education per calendar year.
d. Attendance at formal education sessions must be pre-approved by the coder’s direct supervisor.
e. Examples of formal education include: AHIMA and/or AAPC educational seminars, coding audio conferences, AHIMA and/or AAPC annual meetings, exit conferences with OSG Coding Consultants, or other coding reviews, annual review of Coding Policies and Procedures, college courses related to coding such as medical terminology, anatomy and physiology, etc., independent study courses, Company provided educational sessions, e.g., physician presentations, local coding meetings, state association meetings, etc.
8. Informal Coding Education
a. OSG Billing and Coding Compliance will supply, at a minimum, Outpatient CNN (Coding News Network) newsletter and CPT Assistant, by subscription, to every OSG entity, regional service center, and managed service organization.
b. The immediate supervisor will date stamp or write the received date on the upper right corner of each publication.
c. Internal publications will include a space for the date received.
d. The direct supervisor will route the publication to each provider and/or coder in the entity, and regional service center,
e. The direct supervisor/manager will assign appropriate time for each provider and/or coder to complete the reading of publications based on the needs of the department. All coders must read the publication within 30 days of receipt to receive appropriate CE credit.
f. After reading the publication, the provider and/or coder will sign and date it. Internal publications will include a space for the signature and date.
g. Examples of informal education include: review of coding newsletters, carrier bulletins/transmittals/memorandums related to coding, Medicare Keynotes, AAPC Coding Edge Magazine, Journal of AHIMA, AHA Coding Handbook, AHA Coding Clinic, CPT Assistant, etc.
9. The direct supervisor/manager must maintain all of the routed publications in an accessible location.
10. The completed continuing education tracking form must be kept in an education file. OSG Billing and Coding Compliance will monitor the continuing education tracking forms submitted, the education files and the publications.
The entity’s Ethics and Compliance Officer is responsible for implementation of this policy.
REFERENCES:
The American Health Information Management Association (AHIMA):
· Registered Health Information Administrator Continuing Education requirement of 30 hours per two-year cycle
· Registered Health Information Technician Continuing Education requirement of 20 hours per two -year cycle
· Certified Coding Specialist Continuing Education requires annual self-assessment.
· The American Academy of Professional Coders (AAPC) requires 18 hours per year for Certified
Professional Coders (CPC).
OIG Compliance Program for Individual and Small Group Physician Practices (2000)
OIG Model Compliance Plan for Third Party Billing Companies (1999)
Coding Orientation and Training for Outpatient Services Group Entities, GOS.OSG.005
Continuing Education Requirements Policy, GOS.GEN.0071/2006
ATTACHMENT A
CODER CONTINUING EDUCATION TRACKING FORM
Sample Only
Coder Name: ______Title: ______
Department: ______Supervisor: ______
For each educational activity please specify program title or resource, date of completion or attendance and number or hours received. Informal education hours (e.g., CPT Assistant review, Outpatient CNN (Coding News Network) review, carrier coding bulletin review, etc.) should be reported as actual time spent reviewing the document. For example, a one-hour review of Coding Clinic should be reported as 1 hour earned.
Informal Education
/ Part B News /CPT ASSISTANT
/PHYSICIAN SERVICES CODING UPDATE
/ MISCELLANEOUS (specify item) /HOURS EARNED
/ TOTALDATE REVIEWED / JANUARY / JANUARY / JANUARY
DATE REVIEWED / FEBRUARY / FEBRUARY / FEBRUARY
DATE REVIEWED / MARCH / MARCH / MARCH
DATE REVIEWED / APRIL / APRIL / APRIL
DATE REVIEWED / MAY / MAY / MAY
DATE REVIEWED / JUNE / JUNE / JUNE
DATE REVIEWED / JULY / JULY / JULY
DATE REVIEWED / AUGUST / AUGUST / AUGUST
DATE REVIEWED / SEPTEMBER / SEPTEMBER / SEPTEMBER
DATE REVIEWED / OCTOBER / OCTOBER / OCTOBER
DATE REVIEWED / NOVEMBER / NOVEMBER / NOVEMBER
DATE REVIEWED / DECEMBER / DECEMBER / DECEMBER
Annual Review of GOS.OSG.001
Annual Review of GOS.OSG.003
Annual Review of GOS.OSG.004
Annual Review of GOS.OSG.0005
Annual Review of GOS.OSG.006HIM.COD.010
Annual Review of GOS.OSG.008
TOTAL INFORMAL CE HOURS:
Formal Education
PROGRAM ATTENDED / DATE / CE HOURSTOTAL FORMAL CE HOURS
COVERING CALENDAR YEAR: ______TOTAL CE HOURS:
This form must be maintained in the Employee’s Department Education File.
Attachment to GOS.OSG.006