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.
Respectfully,
Scott B, MBA, CPCO