By Pam Hess, MA, RHIA, CCS, CDIP, CPC
AHIMA House of Delegates (HoD) Vote on Standards of Ethical Coding.
This October there was a proposed update to on the Standards of Ethical Coding. This is an important document that governs now medical coding from an ethical perspective. The 47 of the 52 Component State Association (CSA) delegates voted as follows: 150 for, 4 against, 2 abstained.
The updated document itself can be found on AHIMA Engage.
Because this document governs the practice of medical coding for all HIM practitioners, I would advise that each of you review it. Many of our newer HIM practitioners may not be aware of the existence of this document. It is up to us as a professional association member to share the information and make that we are all in compliance. The document explains the “expectations of professional conduct for coding professionals involved in diagnostic and/or procedural coding, data abstraction and related coding and/or data activities.” 1
To provide clarity within the document, the Standards include a list of definitions related to the practice of coding. The body of the document and primary content includes the Standards and Guidelines themselves. There are eleven standards with sub standards within each that explain the actions that a coding professional shall and shall not do:
- “Apply accurate, complete, and consistent coding practices that yield quality data.
- Gather and report all data required for internal and external reporting, in accordance with applicable requirements and data set definitions.
- Assign and report, in any format, only the codes and data that are clearly and consistently supported by health record documentation in accordance with applicable code set and abstraction conventions, and requirements.
- Query and/or consult as needed with the provider for clarification and additional documentation prior to final code assignment in accordance with acceptable healthcare industry practices.
- Refuse to participate in, support or change reported data and/or narrative titles, billing data, clinical documentation practices, or any coding related activities intended to skew or misrepresent data and their meaning that do not comply with requirements.
- Facilitate, advocate, and collaborate with healthcare professionals in the pursuit of accurate, complete and reliable coded data and in situations that support ethical coding practices.
- Advance coding knowledge and practice through continuing education, including but not limited to meeting continuing education requirements.
- Maintain the confidentiality of protected health information in accordance with the Code of Ethics.
- Refuse to participate in the development of coding and coding related technology that is not designed in accordance with requirements.
- Demonstrate behavior that reflects integrity, shows a commitment to ethical and legal coding practices, and fosters trust in professional activities.
- Refuse to participate in and/or conceal unethical coding, data abstraction, query practices, or any inappropriate activities related to coding and address any perceived unethical coding related practices.” 1
Did you know?
Standard #1 requires that managers foster an environment that supports honest coding practices. 1 This means that each manager is responsible to ensure that coders know about the Standards and that an environment is created to allow for expression of concerns if there is a potential violation. This violation could be something as simple as using information from a previous encounter to code from when that is not acceptable per the guidelines. An exception to this might be within the HCC guidelines where CMS specifically allows the inclusion of inpatient, outpatient and professional fee records for HCC assignment where applicable to the current encounter.
Standard #4 requires that coding managers develop query policies within their scope of responsibility to include “Designing and adhering to policies regarding the circumstances when providers should be queried to promote complete and accurate coding and complete documentation, regardless of whether reimbursement will be affected.” 1 This means that queries should be submitted to ensure that the record reflects the actual diagnosis and treatment provided even if it does not result in a change in reimbursement. Standard #4 also speaks to the practice of unnecessary queries such as querying for a gram-negative pneumonia on each pneumonia case. 1
Standard #5 is especially important and it outlines the proper communication between coders or HIM/Coding Managers and the compliance department when there is any misrepresentation of codded data to “inappropriately increase reimbursement, justify medical necessity, improve publicly reported data, or qualify for insurance policy coverage benefits.” 1
These are just a few of the gems you will find in the Standards of Ethical Coding Document. It would be a good idea to go over this document with your coding staff to ensure that they are aware that they are governed by a professional practice outlined by our professional association AHIMA.
Happy reading! And we will see you next time.
Standards of Ethical Coding, December 5, 2016, http://bok.ahima.org/PdfView?oid=301963