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Thread: Coder Liability

  1. #1
    Join Date
    Apr 2007
    Lakeland, FL

    Default Coder Liability

    AAPC: Back to School
    In the event of an Audit, does a coder risk any liability to erroneous charges?

  2. #2
    Join Date
    Apr 2007
    Coastal Coders


    What sort of erroneous are you asking about?

  3. #3


    I'm also researching this matter. Our coders are being instructed to report codes that we don't agree with. Part of our process is to email the physicians that the code they've submitted is wrong, however if they disagree we are to continue billing the codes that they requested. We were told today that because we've emailed the physician saying we don't agree, that we cannot be held responsible in any way (either by an audit that exposes the fraud, or have our certifications revoked) because we have an email that told the doctor we didn't agree, but processed a code anyways.

  4. #4
    Join Date
    Apr 2007
    Columbia, MO


    The AAPC has several articles in back issues of the Coding Edge regarding this. Basically by submitting codes that you know are incorrect is still your liablitity and it is wrong. What kinds of things are we talking about. Disagreement with the dx code ot the visit level or what. You are allowed to code what is supported by the documentation utilizing the code book instructions and coding guidelines. also CCI edits for CPT codes.. For instance if the CCI edit says it is bundled and you cannot support unbundleing the 2 procedures with a modifier but the provider instructs you that that is what he wants done, then it is still fraud for you to do so. It is telling the payer that 2 indepent procedures were performed and meets the critieria of separate site, separate incision, separate organ, etc, however your review of the documentation did not support that. Yes you would be liable equal to the provider for submission of that claim.
    If you are disagreeing on the diagnosis then it is a matter of interpretation? or are they using incorrect dx codes in order to be paid. The latter is fraud. If it is a matter of the diagnosis is there but you do not recognise the documentation as such then that can be an issue where the provider is correct.

    Debra A. Mitchell, MSPH, CPC-H

  5. #5
    Join Date
    Apr 2007
    Las Vegas

    Question coding liability

    Can you please direct me to those articles so that I can use them for future reference?
    Malama pono,

    Sundae Yomes

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