Avoid the Red: Understand Your Liability as a Coder

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Note:  The following article synopsis was NOT provided by AAPC. It was created by Find-A-Code/innoviHealth.

Article Overview

This article discusses coder liability and the compliance risks that can arise from improper coding practices in a medical practice. It focuses on broad fraud-and-abuse concerns, common red-flag coding behaviors, the role of Medicare compliance concepts, and how coding choices can affect both reimbursement and patient records. The piece is intended for coders, billers, compliance staff, and practice managers who want a general understanding of legal exposure and risk avoidance.

Why This Topic Matters

Coding decisions can create legal, financial, and patient-relations consequences. Understanding the general areas of liability helps coding professionals recognize when to escalate concerns and maintain compliant documentation and reporting practices.

Article Sections

  1. Avoid What Smells Like Fraud

    Discusses general fraud-and-abuse concerns in coding, including how compliance issues may be viewed by government payers and regulators. It introduces broad categories of risky billing behavior and the importance of recognizing patterns of improper activity.

  2. Unbundling

    Covers the topic of unbundling and the use of Medicare National Correct Coding Initiative resources and edit concepts. It also references related edit concepts involving same-provider, same-beneficiary, same-date-of-service reporting.

  3. Bundling

    Describes bundling as a compliance risk and places it in the broader context of coding and reimbursement concerns. The section addresses general concerns about combining services inappropriately.

  4. Upcoding

    Addresses the risk of reporting more extensive or more expensive services than were actually furnished. It explains this issue as part of the broader discussion of fraudulent or abusive coding behavior.

  5. Don't Anger Patients

    Shifts to patient-record and liability concerns, including the effect of diagnosis coding on patients and potential disputes. It also touches on how coding choices can create documentation and legal concerns when diagnoses are uncertain.

What You Will Learn

  • How coder liability can arise from improper coding and billing practices
  • What general coding behaviors may be viewed as compliance red flags
  • How Medicare-related edit concepts relate to code reporting concerns
  • Why coding choices can affect patient records and create legal risk
  • When general disclosure or escalation of coding errors may be considered

Who Should Read This

  • Medical coders
  • Billers
  • Compliance staff
  • Practice managers
  • Healthcare administrators

Codes Discussed

Code Ranges Discussed

  • ICD-9-CM: 410 SERIES

Modifiers Discussed


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