You can advise the doctor that the OIG doesn't often distinguish between honest mistakes and attempts to collect improper reimbursement through fraudulent activities; they can assess the maximum fine of $11,000 plus 3 times the amount improperly paid for EACH claim that is incorrect, in the event of an audit. If the doctor still prefers to do their own coding, I would strongly recommend that they have an internal or external audit conducted to assess their level of billing compliance. It's too risky to cross your fingers and hope for the best. Hope that helps!
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