· Auditing and Monitoring
· Reporting and Investigations
· Enforcement and Discipline
· Response and Prevention
These elements should be a foundational
guide for any and every healthcare organi-
zation, company/system, practice, hospital,
clinic, etc. The seven elements can then be
built into a coding compliance program
and/or plan to outline the effort and work to
be carried out.
Last year, the healthcare community and
industry received a wonderful resource guide,
“Measuring Compliance Program Effectiveness; A
Resource Guide” from the HCCA and OIG. 4
The resource guide contents include the
1. Standards, Policies, and Procedures
2. Compliance Program Administration
3. Screening and Evaluation of Employees,
Physicians, Vendors and Other Agents
4. Communication, Education, and Training
on Compliance Issues
5. Monitoring, Auditing and Internal
6. Discipline for Non-Compliance
7. Investigations and Remedial Measures
This effectiveness guide goes into great
detail to assist the compliance industry and
compliance professionals. As such, there is
a wealth of information that can improve
and/or enhance healthcare compliance.
Having a Code of Ethics is extremely beneficial for the workplace and for the coding
area. The American Health Information
Management Association (AHIMA)
Code of Ethics5 for the Health Information
Management (HIM) arena includes coding
and serves seven purposes:
1. Promotes high standards of HIM practice.
2. Identifies core values on which the HIM
mission is based.
3. Summarizes broad ethical principles that
reflect the profession's core values.
4. Establishes a set of ethical principles to
be used to guide decision-making and
5. Establishes a framework for professional
behavior and responsibilities when professional obligations conflict or ethical
6. Provides ethical principles by which the
general public can hold the HIM professional accountable.
7. Mentors practitioners new to the field
to HIM's mission, values, and ethical
Ethical behavior is one area that certainly
has come under scrutiny in Hollywood, politics, and the corporate business world. An
ethical culture is created by an organization's
leaders who manifest their ethics in their attitudes and behavior. 6
Thus, now is the time to look closely at
the Coding profession and, in addition to the
AHIMA Code of Ethics, use the December
2016 AHIMA Standards of Ethical Coding. 7 The
standards now include definitions that provide
terminology consistency and clarity without
needless repetition in the standard itself.
For example, the section on coding-related
activities includes selection, research, and
completion of code assignment, querying,
other health record data abstraction, data analytics and reporting with codes, coding audits,
remote coding, and coding educational activities and functions. In addition, the portion
on data includes all healthcare data elements,
including clinical, demographic, and financial.
Eleven principles make up the foundation
of the ethical coding standards:
1. Apply accurate, complete, and consistent
coding practices that yield quality data.
2. Gather and report all data required
for internal and external reporting, in