If an Individual Is Responsible for Inpatient Coding Only and Is Not Involved in Outpatient

DEPARTMENT: Regulatory Compliance Support / POLICY DESCRIPTION: Coding Continuing Education Requirements
PAGE: 1 of 6 / REPLACES POLICY DATED: 3/6/98, 4/16/99, 8/1/00, 1/1/01, 6/1/02, 6/1/03, 11/30/04 (HIM.COD.006), 3/6/06
EFFECTIVE DATE: June 1, 2007 / REFERENCE NUMBER: REGS.COD.006
SCOPE: All full-time, part-time, and solo-practitioner contract personnel responsible for performing, supervising or monitoring coding of inpatient and outpatient services including, but not limited to:
Emergency DepartmentAdministration
Radiology DepartmentInternal Audit
Facility Health Information ManagementRegulatory Compliance Support Human Resources Department Service Centers
Registration/Admitting/SchedulingEthics and Compliance Officers
Case Management/Quality Resource Management
External Solo-Practitioner Coding Contractors
PURPOSE: To ensure that all personnel involved in the performance of final 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:
1. Each person involved in the performance of final coding or formalized auditing of coding processes must complete a minimum set of required training hours per calendar year as defined further in this policy. Any associated cost will be the responsibility of the facility.
2. Newly hired personnel involved in the performance of final coding or formalized auditing of coding processes must complete a minimum of eight (8) coding education hours within the first ninety (90) calendar days of employment.
3. Newly hired personnel who have been designated as Outpatient (OP) coders or Inpatient/Outpatient (IP/OP) coders must also complete a minimum of eight (8) billing education hours within the first 90 days of hire.
4. The work of newly hired personnel (within the first 90 calendar days of employment) must be carefully monitored by a fully-trained Company employee until the training requirements have been met.
CODER REQUIREMENTS
Requirements for Inpatient Coders are defined below:

• If an individual is responsible for inpatient coding only and is not involved in outpatient coding, the inpatient coder must meet the annual requirement for 30 hours of continuing education per calendar year.
• A minimum of fifteen (15) CE hours must be accomplished by formal coder education (e.g., attendance at workshops provided by Regulatory Compliance Support or external organization, webcast, attendance at exit conferences after a coding review, annual review of Company coding policies and procedures) and the remaining hours may be accomplished by informal coder education (e.g., reading Coding Clinic, reading Health Information Management Update, reading CPT Assistant, coding specific carrier bulletins, Medicare Keynotes, etc.).

Requirements for Outpatient Coders are defined below:

• Outpatient coders must complete thirty (30) coding continuing education hours per calendar year to satisfy Company coding education requirements.
• Outpatient Coders must complete all mandatory education hours that are billing-related and/or OPPS related services assigned by Regulatory Compliance Support during the calendar year. OP coders must complete a minimum of eight (8) billing education hours on an annual basis. Billing education requirements may exceed eight (8) hours.
• The eight (8) hours of billing continuing education hours may be used to fulfill the thirty (30) hour requirement.

• A minimum of fifteen (15) CE hours must be accomplished by formal education (e.g., online billing courses, attendance at workshops provided by Regulatory Compliance Support or external organization, webcast, attendance at exit conferences after a coding review, annual review of Company coding policies and procedures) and the remaining hours may be accomplished by informal coder education (e.g., reading Coding Clinic, reading CPT Assistant, coding specific carrier bulletins, Medicare Keynotes, etc)

Requirements for Inpatient/Outpatient Coders are defined below:

• Inpatient/Outpatient Coders must complete thirty (30) coding continuing education hours per calendar year to satisfy Company coding education requirements.

• Inpatient/Outpatient Coders must complete all mandatory education hours that are billing-related and/or OPPS related services assigned by Regulatory Compliance Support during the calendar year. IP/OP coders must complete a minimum of 8 billing education hours on an annual basis. Billing education requirements may exceed 8 hours.
• The eight (8) hours of billing continuing education hours may not be used to fulfill the thirty (30) hour requirement. Inpatient /Outpatient coders are required to obtain a minimum of thirty- eight (38) hours.

• A minimum of fifteen (15) CE hours must be accomplished by formal education (e.g., online billing courses, attendance at workshops provided by Regulatory Compliance Support or external organization, webcast, attendance at exit conferences after a coding review, annual review of Company coding policies and procedures) and the remaining hours may be accomplished by informal coder education (e.g., reading Coding Clinic, reading CPT Assistant, coding specific carrier bulletins, and Medicare Keynotes)

NOTE: All mandatory billing education requirements outlined in the CIA, the CIA Medicare OPPS Workplan and Regulatory Compliance Support are consolidated in the document, “Mandatory Billing Training for New and Existing Employees” found on ATLAS. If the mandatory courses listed on this document for a specific CIA-related job function does not equal at least eight (8) hours, the employee is responsible for completing additional Regulatory Compliance Support education hours until the eight (8) hours is met. In no case should the education hours fall below the eight (8) hour minimum requirement outlined in the CIA.
DEFINITIONS:
Coding: Coding is a function by which there is an assignment of a numeric or an alphanumeric classification to identify diagnoses and procedures. These classifications or “codes” are assigned based upon a review of the source document (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).
Auditing: Validation of the appropriateness of HIM-assigned ICD-9-CM diagnosis and HCPCS/CPT and/or ICD-9-CM procedure code assignment. This may include at a minimum ensuring code assignment is supported by documentation in the medical record based on company coding policy and/or current industry standard coding guidelines. These reviews should be performed by an individual qualified to assign codes (based on job classification).
Inpatient Coder: An Inpatient Coder is an individual who applies inpatient coding and/or documentation guidelines to translate diagnosis and procedural phrases into ICD-9-CM code assignments. The inpatient coding function involves the analysis of medical records to identify relevant diagnoses and procedures for distinct patient encounters.
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.
Inpatient/Outpatient Coder: An Inpatient/Outpatient Coder is an individual who assigns a numeric or an alphanumeric classification to identify ICD-9-CM diagnoses and procedures, and applies outpatient coding and/or documentation guidelines to translate diagnosis and procedural phrases into ICD-9-CM and/or HCPCS/CPT code assignments. These classifications or “codes” are assigned based upon a review of the source document (medical record).
NOTE: All personnel performing outpatient coding-related services or E&M assignment that are not defined in this policy are considered Other Billing Personnel or E&M assigner. Refer to the Billing Continuing Education Requirements Policy (REGS.GEN.007). Refer to Hospital Evaluation & Management Services, REGS.GEN.008, for educational requirements for those who assigned E&M codes.
PROCEDURE:
1. The facility ECO or Corporate Responsible Executive must designate an appropriate person (e.g., Local System Administrator, Department Director) to track the required education hours for each person involved in coding and/or coding-related services.
2. It is the responsibility of the direct supervisor to maintain an education file to ensure that each coder (inpatient, outpatient, or solo practitioner) receives the required coding education per calendar year.

1. The education file must be monitored semi-annually by the coder’s direct supervisor to evaluate individual coder education needs.
2. The education file must contain, at a minimum, the following:

i) Copies of credential certification (where applicable),
ii) Copies of CE forms from educational workshops,
iii) Copies of attendance forms from exit conferences, and
iv) Acknowledgment of annual review or re-review of all Company coding policies and procedures.
v) See Attachment A for a sample continuing education tracking form.

1. 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.

3. The completion of coding education hours, as defined in this policy, must be tracked using the Company’s HealthStream Learning Center (HLC).
4. The designated person will be responsible for reporting completed education hours on a quarterly basis for use in the ECO Quarterly Report.

1. Any coder (inpatient, outpatient, inpatient/outpatient or solo practitioner contractor) 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 and must immediately complete the training before resuming job responsibilities. If the training is not completed within two business days of the designated time frame, the employee must be suspended without pay until the educational requirements are met.

The name of the person who did not meet the designated time frame in obtaining the required hours of coding training and the name of his or her direct supervisor must be reported by the ECO to the Division or Market President.
The ECO must also include in his or her report confirmation that an action plan has been developed for the person to complete the required training immediately.

1. The facility must be able to prove compliance with this policy when requested.

1. Formal Coder Education
2. Examples of formal coder education include: AHIMA educational seminars, coding audio conferences, webcasts, AHIMA annual meeting, exit conferences with Regulatory Compliance Support or Internal Audit , or other coding reviews, annual review of Regulatory Compliance Support Policies and Procedures, college courses related to coding such as medical terminology, Anatomy & Physiology, etc, independent study courses, billing-related courses that contain coding information not sponsored by Regulatory Compliance Support or by, facility-provided educational sessions, e.g., physician presentations, local coding roundtable meetings, state association meetings, etc.
3. The coder’s direct supervisor will assign time for each coder to attend at least fifteen (15) hours of formal coder education per calendar year for inpatient, outpatient, inpatient/outpatient coder.
4. Educational requirements are for all designated employees if hired before October 3rd of the given year. PRN employee’s proof of CE hours should be outlined in his or her contractual agreement.
5. Attendance at formal education sessions must be pre-approved by the coder’s direct supervisor.

8. Informal Coder Education

1. Examples of informal coder education include: review of coding newsletters, FI Bulletins/Transmittals related to coding, Medicare Keynotes, Journal of AHIMA, AHA Coding Handbook, AHA Coding Clinic, etc.
2. Each hospital must have, at a minimum, Coding Clinic for ICD-9-CM, CPT Assistant and other required references in its Health Information Management Department.
3. The Health Information Management Director (HIM Director) will date stamp or write the received date on the upper right corner of each publication.
4. The HIM Director will route the publications to each coder in the facility.

(a) The coder’s direct supervisor will assign appropriate time for each coder to complete the reading of publications based on the needs of the department. All coders must read the publication within thirty (30) days of facility receipt and receive appropriate CE credit.
(b) After reading the publication, the coder will sign and date it.

1. The Health Information Management Department must maintain all of the routed publications.

9. Regulatory Compliance Support will monitor the education files and publications.
10. The Facility Ethics and Compliance Committee is responsible for implementation of this policy within the facility.
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 requirement of annual self-assessment

Coding Orientation and Training Policy, REGS.COD.005

Coding Continuing Education Requirements for Outpatient Services Group Entities Policy,
REGS.OSG.006
Coding Orientation and Training for Outpatient Services Group Entities Policy, REGS.OSG.005
Continuing Education Requirements Policy, REGS.GEN.007
Hospital Evaluation & Management Services, REGS.GEN.008
The Mandatory Billing Training for New and Existing Employees document

4/2007

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., Coding Clinic review, Health Information Management Update 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

/ AHA CODING CLINIC /

CPT ASSISTANT

/ MISCELLANEOUS (specify item) /

HOURS EARNED

/ TOTAL
DATE REVIEWED / 1st QUARTER / JANUARY
DATE REVIEWED / 2ND QUARTER / FEBRUARY
DATE REVIEWED / 3RD QUARTER / MARCH
DATE REVIEWED / 4TH QUARTER / APRIL
DATE REVIEWED / MAY
DATE REVIEWED / JUNE
DATE REVIEWED / JULY
DATE REVIEWED / AUGUST
DATE REVIEWED / SEPTEMBER
DATE REVIEWED / OCTOBER
DATE REVIEWED / NOVEMBER
DATE REVIEWED / DECEMBER
TOTAL INFORMAL CE HOURS:

Formal Education

PROGRAM ATTENDED / DATE / CE HOURS
Annual Review of REGS.COD.001
Annual Review of REGS.COD.002
Annual Review of REGS.COD.003
Annual Review of REGS.COD.004
Annual Review of REGS.COD.006
Annual Review of REGS.COD.010
Annual Review of REGS.COD.012
Annual Review of REGS.COD.013
Annual Review of
REGS.COD.015
Annual Review of Regs.COD.016
TOTAL FORMAL CE HOURS

COVERING CALENDAR YEAR: ______TOTAL CE HOURS:

This form must be maintained in the Employee’s Department Education File.

Attachment to REGS.COD.006