Coders are in a unique position to spot a wide range of noncompliance issues, so they must be trained on their obligation to report what they find, a coding expert says. The hospital or health system should ensure that coders know how, what, and when to report noncompliance.
Because they review many types of documentation to determine the proper coding, coders are among the healthcare professionals most likely to spot a problem, says Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS, chief operating officer with First Class Solutions in Maryland Heights, MO.
Coders can contribute to monitoring compliance, risk management, and revenue cycle, Dunn says. They often will be able to raise a red flag for further investigation by compliance and risk management leaders, she says.
“They’re going to see untimely preparation of reports such as operative notes or discharge summaries,” Dunn says. “Operative notes, for instance, can become a risk management issue when there is a complication and the op note doesn’t get dictated until 30 or 40 days after the patient is discharged. If that case goes to litigation, it’s going to be hard for the surgeon to explain how he could accurately describe what happened in the procedure when the operative report is so old and he had done dozens of other operations before writing it.”
Dunn recalls one example in which the coder saw all the progress notes had been entered at the time of discharge, dictated on the same date by the nurse practitioner who worked with the physician, and signed by the physician.
“That coder reported a compliance issue, wondering how other members of the caregiving team could provide care without the progress notes for the patient, and also a compliance issue with everything being done at the end, and then a risk management issue because it is an employed physician,” she says. “You’re billing for their services, and the documentation to support the billing was not done in a timely fashion.”
Falls Not Reported
The coder can discover other risk management issues. For instance, they may be aware of falls and small injuries to patients that were not reported to risk management. Coders can be taught to log all instances of a fall or injury, forwarding that information to risk management at regular intervals in case any of them were not reported, Dunn says.
“That provides a check and balance to risk management,” she says. “They should have a report for that incident from nursing, but if that didn’t happen for whatever reason, then risk management has documentation to go back to and follow up.”
Since coding is performed usually at the time of discharge, a timely notice from the coder gives the risk manager a good chance at contacting the patient and employees reasonably soon after the incident, she says.
Coders also may see what coders call “biting,” comments in the medical record that do not concern the patient, such as a nurse detailing abusive language comments from a physician. Or a physician may state that another physician was not prepared or performed poorly. The name derives from the idea that they are biting each other with the comments.
“When the coders see something inappropriate, they should say something,” Dunn says. “You have to give them a way to do that quickly so that they’re not taking a lot of time away from their primary work. They can have a form to send a quick note to risk management saying, ‘Please see this progress note,’ with blanks for the record number and a short list of potential concerns to check off.”
Coding reports often are used to track healthcare-acquired conditions, but Dunn notes that those final reports may not be available in the computer system immediately. Directing coders to report these conditions to quality improvement or risk management allows the hospital to address the problem sooner, she says.
When educating coders and providing resources, remember that coders may be spread throughout a facility or health system, coding for both the hospital and physicians, and they often have no centralized reporting structure, Dunn says.
In the revenue cycle, coders may identify incorrect charges or the omission of legitimate charges, Dunn says. They also may come across incorrect use of abbreviations and terminology in the medical record, which could lead to noncompliance or liability.
“There are a lot of millennials at the bedside now and these physicians are used to a world of texting and abbreviations,” Dunn explains. “A coding professional may notice that, unless it’s a millennial coder, as well as things like the abbreviations on the do-not-use list.”
Another issue is clinical plagiarism, in which text is copied from one provider’s notes to another’s. Coders can be the eyes and ears of risk management and report many issues that might have gone unnoticed, Dunn says, but only if they are given a process and a culture that allows them to report quickly and safely.
“If you have a coding team that is focused solely on productivity because you have a CFO who only wants productivity, they are not going to be able to collaborate with risk management. Even if it takes one minute to report the issue, that’s one minute taken from coding productivity, and it matters,” Dunn says. “If you can show the value in what coders report to risk management, you can overcome that concern about productivity. Then risk management is going to hear about more problems than they ever imagined.”
SOURCE
- Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS, Chief Operating Officer, First Class Solutions, Maryland Heights, MO. Telephone: (314) 209-7800. Email: [email protected].
Coders are in a unique position to spot a wide range of noncompliance issues, so they must be trained on their obligation to report what they find, a coding expert says.
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