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Outpatient testing billing practices

Compliance Monitor, September 29, 2006

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Q: It has been proposed that we allow outpatient testing patient encounters to be coded by admitting clerks or the respective outpatient departments that perform the testing or rehab services.  It is proposed to be piloted in our Cardiac Rehab area.  Then, if successful, to begin with outpatient laboratory procedures and outpatient x-rays. Is this appropriate?

A: If you are talking about professional services [supervision and interpretation], the rules may be slightly different but there should be no problems. That is, no problems if they are trained on professional coding. Actually, as long as they are trained in the correct rules, there should be no problem for hospital side coding either. The key would be training. Auditing their coding, frequently at first, would give you some confidence level. Then their coding should be audited periodically, as should any other coding. Such auditing, whether in-house or contracted, should be part of the facility's compliance plan.

Thanks to Quinten A. Buechner, M.S., M.Div., ACS-FP/GI/PEDS, C.P.C., president of ProActive Consultants, LLC in Cumberland, WI for providing the additional information on this question.

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