Non certified coders

Best answers
Does anyone know if you can get in trouble for having non certified wmployees working in your coding department? And I mean by the OIG or Medicare.
Last edited:


True Blue
Best answers
There are no requirements that I know of that practices must use certified coders. CMS and OIG are interested in whether the codes submitted are accurate, not in the credentials of those who chose the codes. In other words, practices are responsible for accurate coding, but how they arrive at that is up to them.

I have actually heard that in cases where CMS or OIG identifies inappropriate coding, they may actually be harder on practices that employ certified coders because there is a higher expectation for accuracy and they feel that the practice should have known better due to the fact that they had trained people on staff. I'm not sure if that is really true or not, and also think it would be a bad business practice and poor excuse for allowing coding errors, but I have heard it discussed that some practices might elect to not use certified coders for this reason.


Pasadena/LaPorte Texas Chapter
Best answers
I agree with @thomas7331.

Furthermore, there is an expectation by the government of those providers participating in federal programs to know the rules/regulations of the programs. Even if ignorant, if the provider seeks payment, the government will seek to hold the provider responsible and assess civil penalties.

The OIG published recommendations in the Federal Registry the following guidance:
"Periodically spot-checking the work of coding and billing personnel should be part of a compliance program."

Hiring a certified coder is a best-practice but not required. The certified coder has demonstrated through testing and continued education of correct coding. In my opinion, the risk of inaccurate coding increases if coding is not performed by a certified coder. Note, I did not say that a non-certified coder would inaccurately code, I only stated the risk increases. I also didn't say that having a certified coder would result in 100% accuracy.


Scott B, MBA, CPCO