Conflict of Interest?

crchandl

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I've researched this question and I'm unable to find an answer.

We have 2 Compliance Specialist that audit (IP/OP) E/M encounters for the providers where they work. It's their job to change the LOS assigned by the provider depending on the EHR documentation. As you know, this often involves changing the providers E/M LOS (for which they work) to a higher LOS than originally assigned by the provider.

Is it a conflict of interest for the Compliance Specialist to also enter the charges for the records she has audited or should the charges be entered by another department/staff member who it not in a Compliance/Auditor role?

Thanks
 
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