Revenue Cycle Insider

Question: I am a certified professional coder (CPC^®) and certified professional medical auditor (CPMA^®) and work as an auditor in a small practice. We’re under new management and I’ve also been asked to work in coding and billing. Is this a conflict of interest, since I’m doing internal audits, too?

Utah Subscriber

Answer: One way to remain compliant generally is to have specific policies about what responsibilities make sense for which roles.

One of the main reasons an audit is useful is because it’s an objective look at a data set or other information. Compromising the objectivity by having to audit one’s own work may be problematic. However, someone who has certifications in coding and medical auditing has the knowledge and skills to perform the necessary tasks for each role. Many auditors start out as coders, and as their expertise is acknowledged, they may take on auditing duties and then assume an auditing role.

Conflicts of interest are always a concern, from a compliance perspective, but one could conceivably perform coding and billing duties while conducting some internal audits, especially if there’s other information that needs auditing, like if you’d be auditing another coder’s work or provider documentation.

Anticipating and discussing any direct conflicts of interest or reasons objectivity may be compromised would be crucial before assuming responsibilities of coding and auditing within the same practice. Making sure you have enough time and bandwidth to manage both roles is also important — and possibly reason to push for hiring an additional coder instead.

Rachel Dorrell, MA, MS, CPC-A, CPPM, Production Editor, AAPC