REGSCOD006 REV 3 6 2006 by HC12092903849

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									  DEPARTMENT: Regulatory Compliance                POLICY DESCRIPTION: Coding Continuing
  Support                                          Education Requirements
  PAGE: 1 of 7                                     REPLACES POLICY DATED: 3/6/98, 4/16/99,
                                                   8/1/00, 1/1/01, 6/1/02, 6/1/03, 11/30/04
                                                   (HIM.COD.006)
  EFFECTIVE DATE: March 6, 2006                    REFERENCE NUMBER: REGS.COD.006

  SCOPE: All full-time, part-time, and solo-practitioner contract personnel responsible for
  performing, supervising or monitoring coding of inpatient and outpatient services including, but not
  limited to:
  Emergency Department                                        Administration
  Radiology Department                                        Internal Audit
  Facility Health Information Management                      External Coding Contractors
  Corporate Regulatory Compliance Support                    Human Resources Department
  Registration/Admitting/Scheduling                           Service Centers
  Case Management/Quality Resource Management                 Ethics and Compliance Officers
  Ambulatory Surgery Centers (Including Business Offices and Medical Records)

  PURPOSE: To ensure that all personnel involved in the performance of final coding or formalized
  auditing of coding processes are aware of coding guidelines and coding guideline changes, which
  may impact complete, accurate and consistent coding.

  POLICY:
  1. Each person involved in the performance of final coding or formalized auditing of coding
     processes must complete a minimum set of required training hours per calendar year as defined
     further in this policy. Any associated cost will be the responsibility of the facility.
  2. Newly hired personnel involved in the performance of final coding or formalized auditing of
     coding processes must complete a minimum of eight (8) coding education hours within the first
     ninety (90) calendar days of employment.
  3. Newly hired personnel who have been designated as Outpatient (OP) coders, Inpatient/Outpatient
     (IP/OP) coders, or ASC coders within the Ambulatory Surgery Division (ASD) must also
     complete a minimum of eight (8) billing education hours within the first 90 days of hire.
  4. The work of newly hired personnel (within the first 90 calendar days of employment) must be
     carefully monitored by a fully-trained Company employee until the training requirements have
     been met.

  CODER REQUIREMENTS
  Requirements for Inpatient Coders are defined below:
      If an individual is responsible for inpatient coding only and is not involved in outpatient
         coding, the inpatient coder must meet the annual requirement for 30 hours of continuing
         education per calendar year.
      A minimum of fifteen (15) CE hours must be accomplished by formal coder education (e.g.,
         attendance at workshops provided by Regulatory Compliance Support or external


2/2006
  DEPARTMENT: Regulatory Compliance                POLICY DESCRIPTION: Coding Continuing
  Support                                          Education Requirements
  PAGE: 2 of 7                                     REPLACES POLICY DATED: 3/6/98, 4/16/99,
                                                   8/1/00, 1/1/01, 6/1/02, 6/1/03, 11/30/04
                                                   (HIM.COD.006)
  EFFECTIVE DATE: March 6, 2006                    REFERENCE NUMBER: REGS.COD.006

         organization, webcast, attendance at exit conferences after a coding review, annual review of
         Company coding policies and procedures) and the remaining hours may be accomplished by
         informal coder education (e.g., reading Coding Clinic, reading Health Information
         Management Update, reading CPT Assistant, coding specific carrier bulletins, Medicare
         Keynotes, etc)

  Requirements for Outpatient Coders are defined below:
      Outpatient coders must complete thirty (30) coding continuing education hours per calendar
        year to satisfy Company coding education requirements.
      Outpatient Coders must complete all mandatory education hours that are billing-related and/or
        OPPS related services assigned by Regulatory Compliance Support during the calendar year.
        OP coders must complete a minimum of eight (8) billing education hours on an annual basis.
        Billing education requirements may exceed eight (8) hours.
      The eight (8) hours of billing continuing education hours may be used to fulfill the thirty (30)
        hour requirement.
      A minimum of fifteen (15) CE hours must be accomplished by formal education (e.g., online
         billing courses, attendance at workshops provided by Regulatory Compliance Support or
         external organization, webcast, attendance at exit conferences after a coding review, annual
         review of Company coding policies and procedures) and the remaining hours may be
         accomplished by informal coder education (e.g., reading Coding Clinic, reading Health
         Information Management Update, reading CPT Assistant, coding specific carrier bulletins,
         Medicare Keynotes, etc)

  Requirements for Inpatient/Outpatient Coders are defined below:
      Inpatient/Outpatient Coders must complete thirty (30) coding continuing education hours per
         calendar year to satisfy Company coding education requirements.
      Inpatient/Outpatient Coders must complete all mandatory education hours that are billing-
        related and/or OPPS related services assigned by Regulatory Compliance Support during the
        calendar year. IP/OP coders must complete a minimum of 8 billing education hours on an
        annual basis. Billing education requirements may exceed 8 hours.
      The eight (8) hours of billing continuing education hours may not be used to fulfill the thirty
        (30) hour requirement. Inpatient /Outpatient coders are required to obtain a minimum of
        thirty- eight (38) hours.
      A minimum of fifteen (15) CE hours must be accomplished by formal education (e.g., online
         billing courses, attendance at workshops provided by Regulatory Compliance Support or
         external organization, webcast, attendance at exit conferences after a coding review, annual
         review of Company coding policies and procedures) and the remaining hours may be


2/2006
  DEPARTMENT: Regulatory Compliance                   POLICY DESCRIPTION: Coding Continuing
  Support                                             Education Requirements
  PAGE: 3 of 7                                        REPLACES POLICY DATED: 3/6/98, 4/16/99,
                                                      8/1/00, 1/1/01, 6/1/02, 6/1/03, 11/30/04
                                                      (HIM.COD.006)
  EFFECTIVE DATE: March 6, 2006                       REFERENCE NUMBER: REGS.COD.006

            accomplished by informal coder education (e.g., reading Coding Clinic, reading Health
            Information Management Update, reading CPT Assistant, coding specific carrier bulletins,
            and Medicare Keynotes)

  Requirements for ASC Coders within the Ambulatory Surgery Division (ASD) are defined below:
      ASC Coders within the ASD must complete thirty (30) coding continuing education hours per
        calendar year to satisfy Company coding education requirements.
      ASC Coders within the ASC must complete a minimum of eight (8) education hours per
        calendar year related to billing and/or billing-related services as defined by the Ambulatory
        Surgery Division Ethics and Compliance Officer (ECO).
      The eight (8) hours of billing continuing education hours may be used to fulfill the thirty (30)
        hour requirement.
      A minimum of fifteen (15) CE hours must be accomplished by formal education (e.g., online
         billing courses, attendance at workshops provided by Regulatory Compliance Support or
         external organization, webcast, attendance at exit conferences after a coding review, annual
         review of Company coding policies and procedures) and the remaining hours may be
         accomplished by informal coder education (e.g., reading Coding Clinic, reading Health
         Information Management Update, reading CPT Assistant, coding specific carrier bulletins,
         and Medicare Keynotes).

         NOTE: All mandatory billing education requirements outlined in the CIA, the CIA Medicare
         OPPS Workplan and Regulatory Compliance Support are consolidated in the document,
         “Mandatory Billing Training for New and Existing Employees” found on ATLAS. If the
         mandatory courses listed on this document for a specific CIA-related job function does not equal
         at least eight (8) hours, the employee is responsible for completing additional Regulatory
         Compliance Support education hours until the eight (8) hours is met. In no case should the
         education hours fall below the eight (8) hour minimum requirement outlined in the CIA.

  DEFINITIONS:

  Coding: Coding is a function by which there is an assignment of a numeric or an alphanumeric
  classification to identify diagnoses and procedures. These classifications or “codes” are assigned
  based upon a review of the source document (medical record). The classifications utilized for this
  purpose include: ICD-9-CM (International Classification of Disease – 9th edition – Clinical
  Modification); CPT (Current Procedural Terminology) or HCPCS Level II (Healthcare Common
  Procedure Coding Systems).



2/2006
  DEPARTMENT: Regulatory Compliance                   POLICY DESCRIPTION: Coding Continuing
  Support                                             Education Requirements
  PAGE: 4 of 7                                        REPLACES POLICY DATED: 3/6/98, 4/16/99,
                                                      8/1/00, 1/1/01, 6/1/02, 6/1/03, 11/30/04
                                                      (HIM.COD.006)
  EFFECTIVE DATE: March 6, 2006                       REFERENCE NUMBER: REGS.COD.006

  Auditing: Validation of the appropriateness of HIM-assigned ICD-9-CM diagnosis and HCPCS/CPT
  and/or ICD-9-CM procedure code assignment. This may include at a minimum ensuring code
  assignment is supported by documentation in the medical record based on company coding policy
  and/or current industry standard coding guidelines. These reviews should be performed by an
  individual qualified to assign codes (based on job classification).

  Inpatient Coder: An Inpatient Coder is an individual who applies inpatient coding and/or
  documentation guidelines to translate diagnosis and procedural phrases into ICD-9-CM code
  assignments. The inpatient coding function involves the analysis of medical records to identify
  relevant diagnoses and procedures for distinct patient encounters.

  Outpatient Coder: An Outpatient Coder is an individual who applies outpatient coding and/or
  documentation guidelines to translate diagnosis and procedural phrases into ICD-9-CM and/or
  HCPCS/CPT code assignments. The outpatient coding function involves the analysis of medical
  records to identify relevant diagnoses and procedures for distinct patient encounters.

  Inpatient/Outpatient Coder: An Inpatient/Outpatient Coder is an individual who assigns a numeric
  or an alphanumeric classification to identify ICD-9-CM diagnoses and procedures, and applies
  outpatient coding and/or documentation guidelines to translate diagnosis and procedural phrases into
  ICD-9-CM and/or HCPCS/CPT code assignments. These classifications or “codes” are assigned
  based upon a review of the source document (medical record).

 ASC Coder within the Ambulatory Surgery Division: An ASC coder within the ASD is an
 individual in the Ambulatory Surgery Division who applies outpatient coding and/or documentation
 guidelines to translate diagnosis and procedural phrases into ICD-9-CM and/or HCPCS/CPT code
 assignments. The outpatient coding function involves the analysis of medical records to identify
 relevant diagnoses and procedures for distinct patient encounters.

         NOTE: All personnel performing outpatient coding-related services that are not defined in this
         policy are considered Other Billing Personnel. Refer to the Billing Continuing Education
         Requirements Policy (REGS.GEN.007).

  PROCEDURE:
  1. The facility ECO or Corporate Responsible Executive must designate an appropriate person (e.g.,
     Local System Administrator, Department Director) to track the required education hours for each
     person involved in coding and/or coding-related services.



2/2006
  DEPARTMENT: Regulatory Compliance                   POLICY DESCRIPTION: Coding Continuing
  Support                                             Education Requirements
  PAGE: 5 of 7                                        REPLACES POLICY DATED: 3/6/98, 4/16/99,
                                                      8/1/00, 1/1/01, 6/1/02, 6/1/03, 11/30/04
                                                      (HIM.COD.006)
  EFFECTIVE DATE: March 6, 2006                       REFERENCE NUMBER: REGS.COD.006

  2. It is the responsibility of the direct supervisor to maintain an education file to ensure that each
     coder (inpatient, outpatient, ASC, or solo practitioner) receives the required coding education per
     calendar year.
     a. The education file must be monitored semi-annually by the coder’s direct supervisor to
          evaluate individual coder education needs.
     b. The education file must contain, at a minimum, the following:
          i. Copies of credential certification (where applicable),
          ii. Copies of CE forms from educational workshops,
          iii. Copies of attendance forms from exit conferences, and
          iv. Acknowledgment of annual review or re-review of all Company coding policies and
               procedures.
          v. See Attachment A for a sample continuing education tracking form.
     c. The coder’s direct supervisor will be responsible for providing specific information related to
          coding continuation education compliance to the facility ECO or Corporate Responsible
          Executive, whichever is applicable.

  3. The completion of coding education hours, as defined in this policy, must be tracked using the
     Company’s Learning Management System (LMS).

  4. The designated person will be responsible for reporting completed education hours on a quarterly
     basis for use in the ECO Quarterly Report.

  5. Any coder (inpatient, outpatient, inpatient/outpatient, ASC or solo practitioner) who does not
     meet the designated time frame in obtaining the required hours of coding training (new hires as
     well as annual requirements) must be reported to the ECO by the person’s direct supervisor and
     must immediately complete the training before resuming job responsibilities. If the training is not
     completed within two business days of the designated time frame, the employee must be
     suspended without pay until the educational requirements are met.
     The name of the person who did not meet the designated time frame in obtaining the required
     hours of coding training and the name of his or her direct supervisor must be reported by the ECO
     to:
                   Division or Market President for a hospital employee; or
                   Director of Operations in the Ambulatory Surgery Centers

         The ECO must also include in his or her report confirmation that an action plan has been
         developed for the person to complete the required training immediately.



2/2006
  DEPARTMENT: Regulatory Compliance                 POLICY DESCRIPTION: Coding Continuing
  Support                                           Education Requirements
  PAGE: 6 of 7                                      REPLACES POLICY DATED: 3/6/98, 4/16/99,
                                                    8/1/00, 1/1/01, 6/1/02, 6/1/03, 11/30/04
                                                    (HIM.COD.006)
  EFFECTIVE DATE: March 6, 2006                     REFERENCE NUMBER: REGS.COD.006

  6. The facility must be able to prove compliance with this policy when requested.

  7. Formal Coder Education
     a. Examples of formal coder education include: AHIMA educational seminars, coding audio
        conferences, webcasts, AHIMA annual meeting, exit conferences with Regulatory
        Compliance Support or Internal Audit , or other coding reviews, annual review of Regulatory
        Compliance Support Policies and Procedures, college courses related to coding such as
        medical terminology, Anatomy & Physiology, etc, independent study courses, billing-related
        courses that contain coding information not sponsored by Regulatory Compliance Support or
        by Ambulatory Surgery Division leadership, facility-provided educational sessions, e.g.,
        physician presentations, local coding roundtable meetings, state association meetings, etc.
     b. The coder’s direct supervisor will assign time for each coder to attend at least fifteen (15)
        hours of formal coder education per calendar year for inpatient, outpatient,
        inpatient/outpatient, and ASC coder.
     c. Educational requirements are for all designated employees if hired before October 3rd of the
        given year. PRN employee’s proof of CE hours should be outlined in his or her contractual
        agreement.
     d. Attendance at formal education sessions must be pre-approved by the coder’s direct
        supervisor.
  8. Informal Coder Education
     a. Examples of informal coder education include: review of coding newsletters, FI
        Bulletins/Transmittals related to coding, Medicare Keynotes, Journal of AHIMA, AHA Coding
        Handbook, AHA Coding Clinic, etc.
     b. Regulatory Compliance Support will supply, at a minimum, Health Information Management
        Update, Coding Clinic for ICD-9-CM, and CPT Assistant to each Health Information
        Management Department.
        i. The Health Information Management Director (HIM Director) will date stamp or write the
            received date on the upper right corner of each publication. Internal publications will
            include a space for the date received.
        ii. The HIM Director will route the publications to each coder in the facility.
            1. The coder’s direct supervisor will assign appropriate time for each coder to complete
                the reading of publications based on the needs of the department. All coders must
                read the publication within thirty (30) days of facility receipt and receive appropriate
                CE credit.
            2. After reading the publication, the coder will sign and date it. Internal publications will
                include a space for the signature and date.



2/2006
  DEPARTMENT: Regulatory Compliance                POLICY DESCRIPTION: Coding Continuing
  Support                                          Education Requirements
  PAGE: 7 of 7                                     REPLACES POLICY DATED: 3/6/98, 4/16/99,
                                                   8/1/00, 1/1/01, 6/1/02, 6/1/03, 11/30/04
                                                   (HIM.COD.006)
  EFFECTIVE DATE: March 6, 2006                    REFERENCE NUMBER: REGS.COD.006

         c. The Health Information Management Department must maintain all of the routed
            publications.
  9. Regulatory Compliance Support will monitor the education files and publications.

  10. The Facility Ethics and Compliance Committee is responsible for implementation of this policy
      within the facility.

  REFERENCES:
  The American Health Information Management Association (AHIMA):
      Registered Health Information Administrator Continuing Education requirement of 30 hours
        per two year cycle
      Registered Health Information Technician Continuing Education requirement of 20 hours per
        two-year cycle
      Certified Coding Specialist Continuing Education requirement of annual self-assessment
  Coding Orientation and Training Policy, REGS.COD.005
  Coding Continuing Education Requirements for Outpatient Services Group Entities Policy,
    REGS.OSG.006
  Coding Orientation and Training for Outpatient Services Group Entities Policy, REGS.OSG.005
  Continuing Education Requirements Policy, REGS.GEN.007
  The Mandatory Billing Training for New and Existing Employees document




2/2006
                                       CODER CONTINUING EDUCATION TRACKING FORM
                                                       Sample Only

Coder Name: _________________________________ Title: _____________________________

 Department: _________________________________ Supervisor: ________________________

For each educational activity please specify program title or resource, date of completion or attendance and number or hours received. Informal education
hours (e.g., Coding Clinic review, Health Information Management Update review, carrier coding bulletin review, etc.) should be reported as actual time spent
reviewing the document. For example, a one-hour review of Coding Clinic should be reported as 1 hour earned.

Informal Education
                       AHA CODING         CPT ASSISTANT         HIMS UPDATE        MISCELLANEOUS                 HOURS EARNED                  TOTAL
                           CLINIC                                                    (specify item)
                       1st QUARTER            JANUARY             JANUARY
DATE REVIEWED
                       2ND QUARTER           FEBRUARY             FEBRUARY
DATE REVIEWED
                       3RD QUARTER             MARCH                MARCH
DATE REVIEWED
                        4TH QUARTER             APRIL               APRIL
DATE REVIEWED
                                                MAY                  MAY
DATE REVIEWED
                                                JUNE                 JUNE
DATE REVIEWED
                                                JULY                 JULY
DATE REVIEWED
                                              AUGUST               AUGUST
DATE REVIEWED
                                            SEPTEMBER            SEPTEMBER
DATE REVIEWED
                                              OCTOBER             OCTOBER
DATE REVIEWED
                                            NOVEMBER             NOVEMBER
DATE REVIEWED
                                             DECEMBER            DECEMBER
DATE REVIEWED


                                                                                                                        Attachment to REGS.COD.006
                                                                            TOTAL INFORMAL CE HOURS:
Formal Education
     PROGRAM             DATE            CE HOURS
    ATTENDED
Annual Review of
REGS.COD.001
Annual Review of
REGS.COD.002
Annual Review of
REGS.COD.003
Annual Review of
REGS.COD.004
Annual Review of
REGS.COD.006
Annual Review of
REGS.COD.010
Annual Review of
REGS.COD.012
Annual Review of
REGS.COD.013
Annual Review of
REGS.COD.015




                                                                             TOTAL FORMAL CE HOURS


COVERING CALENDAR YEAR: _______                          TOTAL CE HOURS:
This form must be maintained in the Employee’s Department Education File.

                                                                                      Attachment to REGS.COD.006

								
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