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Are online coding discussions putting your practice at risk?

By Cheryl Toth, MBA  bio

Here’s an email we recently saw while monitoring a specialty coding listserv:

Sent: Monday, June 04, 2018 2:08 PM
Subject: Acromioplasty and hardware removal with total shoulder arthroplasty
Hello All,
We have a surgeon that says I am not an aggressive coder because I communicate to him when NCCI indicates that certain procedures are bundled, and now I am second-guessing myself. Can you confirm whether or not 23130 and 20680 for removal of 2 suture anchors from the humeral canal from a previous rotator cuff repair are bundled with 23472?


Perhaps you think your employees would have enough common sense not to post something like this online. But unfortunately, we see questions like Debra’s on coding discussion boards and listservs all the time.

If you haven’t caught on yet, Debra’s question has inferred that her doctor prefers unbundling to following CCI edits. And the domain name in her email address would make any auditor salivate, because identifying this practice and its physicians will take all of about two seconds.

Welcome to the risky world of online coding discussions. Where managers and physicians are often the last to know that staff is spending chunks of the day answering coding and billing questions for other practices. This, instead of working on the practice’s accounts – and on the practice’s dime.

The Basics

Coding Boards are Internet forums that use a website for people to start and participate in topical conversations (called “threads”).

Email Listservs use an email system instead of a site to connect people about a particular topic. Once subscribed, anyone can pose questions about that topic. These questions are generally sent by email to the entire group for a response.

The cost to your practice aside, this online collaboration may seem like a harmless way to get coding questions answered. But on these sites, anyone can proclaim “expertise” and provide a correct or incorrect answer. There are no industry standard guidelines for these online groups. Anything your practice posts could be used against you. And most importantly: Unlike a coding education company, society, or professional consultant, individual staff carry no errors and omissions insurance. If your practice relies on one of their wrong answers and gets audited, to whom will you go for restitution?

Discussion boards are not inherently evil. But used improperly, they can get a practice into real trouble. If your practice is willing to allow staff to use them, set rules and develop policies first. Because once the practice’s questions or answers are “out there” on the Internet, they are discoverable by just about anyone.

1. List and evaluate all sites. Include the URL, sponsor (if relevant), contact information, and moderator names. Evaluate the site against criteria such as the following:

  • Is the site or list sponsored by a national specialty society or professional organization?
  • What are the credentials of those responding to the questions?
  • Is the board or list moderated? If so, what are the credentials of the moderator?
  • Does the organization that sponsors the board or list carry errors and omissions insurance that protects your practice against inaccurate advice?
  • Do the site’s Terms of Use allow for editing or deletion of inaccurate postings?

If the sites on your list have a moderator, that’s a good sign. So are the sites and boards whose respondents list their degrees and credentials. Look for physician coding credentials such as Certified Professional Coder® (CPC), available from the American Association of Procedural Coders (, or physician office certifications from the American Health Information Management Association ( All indicate that the people providing coding answers have passed examinations that assess their knowledge.

2. Develop usage policies and procedures. Online coding boards and listservs bridge both HIPAA and billing compliance so you need policy statements in both your Billing Compliance Plan and your Social Media Policy, which requires employee sign-off. Items to include in these policies are the prohibition of postings or questions about physician coding behavior, or anything that could be perceived as the physician ignoring correct coding guidelines.

3. Don’t allow details that could identify the practice. Posting any piece of information that can identify the practice is risky and should be carefully controlled. Even personal emails and off the clock postings can be traced back to the practice, if the employee provides enough identifying details about themselves.

4. Validate and log all answers. Never trust what you find online. Always verify it against credible sources – such as those developed by your specialty society, the American Medical Association, or Federal transmittals. Only after responses are verified should the practice use the information in its billing and coding practices.

Cheryl Toth, MBA is a Tucson-based business writer and healthcare professional who blends exceptional communication skills with an ability to educate and inspire. She brings 20 years of practice consulting, technology management, and presentation experience to her projects. Cheryl is a co-host of Sound Practice, a Greenbranch Publishing podcast for physicians and practice leaders, that launched in the fall of 2018.

The above information is shared by a guest contributor and does not necessarily reflect the views of Medical Office Manager.

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