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Pathologic Testing on Bone Marrow

Understand specimen collection procedures for reporting you can count on.

Robert Cassels, BA, CPC, and Shelley C. Safian, PhD, CPC-H, CPC-I, CCS-P

Although not performed as commonly as blood tests or urinalysis (because obtaining the specimen is complex), pathologic examination of a patient’s bone marrow has many possible uses, including:

  • As a diagnostic tool for suspected myeloma, leukemia, myelodysplastic syndromes, and myeloproliferative disorders
  • To assess a current diagnosis of thrombocytopenia, anemia, or leukopenia
  • To measure quantities of stored iron and marrow cellularity
  • To determine neoplasm, infection, fibrosis, or other infiltrative bone disease
  • To enable staging of lymphoma and/or other malignant neoplasms

A patient may have abnormal blood counts without an identifiable explanation, or have other abnormal cells evidenced in circulating blood. These, as well as a current bone marrow-related disease diagnosis (such as lymphoma), or indications that a malignancy has metastasized into the marrow, are standard justifications for obtaining and studying a bone marrow specimen. Typically, the specimen is taken from the posterior superior iliac spine of the pelvis to acquire a sample of the blood-forming cells in the marrow space. Evaluation of a specimen taken by biopsy is considered to be more accurate than one obtained by aspiration because the quantity of material gathered is greater, and more likely to represent a wider scope of sampling.

Specimen Extraction Coding

When coding for bone marrow biopsy, the first procedure code to report is that for obtaining the specimen, using either 38220 Bone marrow; aspiration only or 38221 Bone marrow, biopsy, needle or trocar.

Note that the abstraction of bone marrow from a patient is not performed solely for the lab, and it’s very important to identify from the documentation not only how the bone marrow was taken, but for what purpose. For example, bone marrow aspiration for platelet rich stem cell injections are not reported with 38220, but with 0232T Injection(s), platelet rich plasma, any site, including image guidance, harvesting and preparation when preformed. Harvesting bone marrow for transplantation is reported with either 38230 Bone marrow harvesting for transplantation; allogeneic or 38232 Bone marrow harvesting for transplantation; autologous.

When both a bone marrow biopsy and a bone marrow aspiration are performed on a Medicare beneficiary during the same encounter, do not claim 38220. Instead, report G0364 Bone marrow aspiration performed with bone marrow biopsy through the same incision on the same date of service.

Pathologic Testing

Next, the specimen will be sent to the laboratory for analysis. A bone marrow specimen obtained by either biopsy or aspiration can enable a hematologist/pathologist to investigate the patient’s hematopoiesis (the process of forming blood cells), as well as the shape, size, and quantity of red and white blood cells (RBCs and WBCs) and megakaryocytes (very large bone marrow cells that produce blood platelets). Blood cell formation is primarily the responsibility of the red bone marrow, specifically in the sternum, ribs, and the iliac bones (pelvis).

Code 88305 Level IV – Surgical pathology, gross and microscopic examination describes both evaluation of the bone marrow biopsy specimen by the naked eye (known as gross examination) and visualization of the specimen using a microscope. When the documentation states that the specimen was obtained by aspiration, report the analysis with 85097 Bone marrow, smear interpretation, instead of 88305.

It’s not uncommon for a decalcification procedure and/or iron staining to be performed at the same time as the surgical pathology examination. When documentation confirms this, report these procedures separately using +88311 Decalcification procedure (List separately in addition to code for surgical pathology examination) and/or 88313 Special stain including interpretation and report; Group II, all other (eg, iron, trichrome) except stain for microorganisms, stains for enzyme constituents, or immunocytochemistry and immunohistochemistry.

Per CPT® parenthetical instruction, report one unit of 88313 for each special stain on each surgical pathology block, cytologic specimen, or hematologic smear. Check documentation or query the testing pathologist to ensure the notes are clear as to how many blocks, specimens, or smears were tested. This will help you to report the accurate number of codes/units.

Immunophenotyping by flow cytometry can identify cell-specific antibodies, enabling more accurate determination of cell percentages and identification of abnormal cell patterns. Report this test using 88184 Flow cytometry, cell surface, cytoplasmic, or nuclear marker, technical component only; first marker and +88185 Flow cytometry, cell surface, cytoplasmic, or nuclear marker, technical component only; each additional marker (List separately in addition to code for first marker), as appropriate.

Because 88184 and 88185 are specifically limited to the technical component only, you’ll need a code to report the interpretation service separately. Note, modifiers TC Technical component and 26 Professional component are not necessary because these details are already included in the code descriptors, as follows:

88187 Flow cytometry, interpretation; 2 to 8 markers

88188 9 to 15 markers

88189 16 or more markers

Fluorescent in situ hybridization (FISH) analysis (88365 In situ hybridization (eg, FISH), each probe) is usually performed after the analysis of the bone marrow, the results of which will direct the specific deoxyribonucleic acid probes to be conducted. FISH analysis is better than an overall karyotype test because it can find smaller pieces of chromosomes that may be missing or have extra copies.

Put It All Together

To make sense of it all, let’s consider a couple of realistic encounters and how to accurately report them.


A 43-year-old female has a history of chronic myeloid leukemia. She came to our facility today for a bone marrow aspiration, right side posterior iliac crest. A 15-gauge needle was used to obtain the aspirate including an aspirate clot. The patient tolerated the procedure well.

ICD-9-CM Diagnosis Code:

V10.62Personal history of myeloid leukemia

ICD-10-CM Diagnosis Code:

Z85.6Personal history of leukemia

Obtaining the Specimen:


Pathology Report:

The following specimens were reviewed: peripheral smear of bone marrow aspirate and clot section; iron stain.

Test Codes:




A 77-year-old male has multiple myeloma, and came to our facility for a bone marrow core biopsy, touch preparation. Biopsy site is left posterior iliac crest.

ICD-9-CM Diagnosis Code:

203.00Multiple myeloma, without mention of having achieved remission

ICD-10-CM Diagnosis Code:

C90.00Multiple myeloma not having achieved remission

Obtaining the Specimen:


Pathology Report:

Immunophenotyping (flow cytometry) performed, two markers

Test Codes:





The Results Are In

As mentioned, bone marrow analysis includes a quantification of megakaryocytes. A patient who has recently suffered a hemorrhage, has acute or chronic myeloid leukemia, or who has been diagnosed with secondary hypersplenism due to portal hypertension, is expected to have an increase in the percentage of megakaryocytes present in the bone marrow. Patients who have gone through (or are going through) chemotherapy, radiation therapy, or some specific drug therapies, and those with aplastic anemia, or infiltrative neoplastic or fibrotic marrow disease, will have a reduced number of megakaryocytes (normal range is 0-0.4 percent).

Patients with lymphoma, lymphocytic leukemia, mycoplasma infections, a viral and/or chronic infection, multiple myelomas, lymphomas, rheumatic fever, or another chronic inflammatory disease will have a greater than the normal percentage of lymphocytes. Normal range of lymphocytes is 11.1-23.2 percent.

Other conditions that may be confirmed or indicated by the results of a bone marrow analysis include:

Anemia: Iron deficiency is only one cause of an abnormally low count of hemoglobin, hematocrit, and/or RBCs. Low RBC volume reduces the amount of oxygen being transported, causing tissue hypoxia (low levels of oxygen). Classic signs and symptoms include tachycardia, dyspnea, and sometimes fatigue.

Leukemia: The presence of malignant cells within the bone marrow that produces blood cells (hematopoietic tissues), causing a reduction in the production of RBCs, WBCs, and platelets. This anemic state makes the patient very susceptible to infections and hemorrhaging. There are several types of leukemia, including myeloid leukemia and monocytic leukemia.

Thrombocytopenia: This is a low platelet count, most often due to increased platelet destruction, decreased platelet production, or malfunctioning platelets. Underlying conditions might include a case of splenomegaly (enlarged spleen) when bone marrow is destroyed by medication, chemotherapy or radiation therapy, or aplastic anemia.

Robert Cassels, BA, CPC, works as an outpatient coder at the Orlando VA Medical Center where he codes a wide variety of encounters. He spent several years specializing in dermatology coding. He is a member of the Orlando, Fla., local chapter.

Shelley C. Safian, PhD, CPC-H, CPC-I, CCS-P, teaches health information management and coding. She writes a monthly Q&A column and several articles each year on various aspects of coding and is the author of six textbooks. Safian has a Doctor of Philosophy in Health Care Administration and is an ICD-10-CM/PCS trainer. She is a member of the Orlando, Fla., local chapter.

October 1st, 2014

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New CIC™ Inpatient Credential Opens Hospital Doors

Show you have specialized facility expertise.

By Brad Ericson, MPC, CPC, COSC

AAPC’s new credential for inpatient facility coding, the Certified Inpatient Coder (CIC™), opens new doors for members who work, or who want to work, in hospitals. Announced in August, the credential demonstrates competency abstracting information from the medical record for ICD-9-CM Volumes 1-3 coding and payment knowledge of Medicare Severity-Diagnosis Related Groups (MS-DRGs) and the Inpatient Prospective Payment System (IPPS).

Developed at the request of members and inpatient facility health information management directors, the CIC™ joins the long established outpatient facility coding credential, Certified Professional Coder-Hospital (CPC-H®), said Raemarie Jimenez, CPC, CPB, CPMA, CPPM, CPC-I, CANPC, CRHC, vice president of member and certification development for AAPC. As a result, the CPC-H® credential will be changed to the Certified Outpatient Coder (COC™) (all current CPC-H® credential holders will display the COC™ designation).

“We test inpatient and outpatient coding separately because the roles are distinct in the industry. By testing inpatient and outpatient separately, it allows us to focus on the coding and reimbursement competencies the credentialed member is qualified to perform.” Jimenez told Healthcare Business Monthly. Only the credential acronyms will change, not the competencies, she added.

CIC™ designated members will have demonstrated proficiency in:

  • Medical record review to abstract information required to support accurate inpatient coding
  • Assigning accurate ICD-9-CM Volumes 1-3 medical codes for diagnoses and procedures performed in the inpatient setting
  • Current rules, regulations, and issues regarding medical coding, compliance, and reimbursement under MS-DRG and IPPS systems
  • Integrating coding and reimbursement rule changes in a timely manner to include updating the Charge Description Master, fee updates, and the field locators on the UB04 form
  • Understanding anatomy, physiology, and medical terminology required to code correctly facility services and diagnoses
  • Outpatient reimbursement methodologies

The CIC™ exam is groundbreaking for AAPC, as it is the first fill-in-the-blank exam for the organization. Examinees will answer 60 multiple choice questions and code 10 inpatient cases in four hours. As with all AAPC exams, code books are welcome in the exam; see for specific exam requirements.

Cost is $325 ($260 for AAPC students) with one free retake.

Brad Ericson, MPC, CPC, COSC, is director of publishing at AAPC.

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Develop Powerful, Purposeful Networks

Establish professional connections necessary to advance your career.

 Darlene F. Helmer, MBA, CMPE, CPC, CMA, ACS-AN

In our industry, the importance of networking with other professionals can’t be expressed enough. Establishing a network you can tap into for coding advice and career opportunities requires making contacts, building relationships, and developing friendships. At one time, this might have been a job in itself, but in this age of social media, reaching out to others has never been easier. Thanks to the Internet, “society is on the verge of an unprecedented era of learning.” (MIT Technology Review, “The Power of Networks”) You now have the power to create a network that has no boundaries, and provides you with endless opportunities for learning and professional advancement.

Who You Know vs. What You Know

Author of “The Power of Networking” (, Sheila Savar asks, “Why is it that a recent college graduate lands his dream job while the other takes months to find any job? Why do some people move quickly up the corporate ladder while their equally qualified peers can’t even seem to move to the next level …?” The answer is simple: professional networking. Your ability to make connections with others – real or virtual – is your most valuable skill.

In fact, MIT Technology Review says, “… the art and science of developing powerful, purposeful networks that connect the right people, machines, and organizations is becoming a major competitive differentiator in today’s business landscape. Those who master these capabilities will offer the world something of value.”

Don’t Be Intimidated

When public speaker and author Catherine Statton began her career, she found professional networking “distasteful.” Her naiveté led her to believe that it was insincere to create relationships for the sole purpose of advancing her career. “That was until I understood the true value of a network; a coalition of the willing that supports and challenges me,” Statton writes in her blog. “My network values my strengths, encourages me, allows me to broaden my expertise, and find purpose and balance.”


Tap into AAPC Networking

AAPC forums are a great place for networking, but if you like to put a face to a name, consider attending local chapter meetings and other gatherings with like-minded, skilled individuals who can help you reach your potential. Jobs for coders are plentiful and your network could hold the key to opportunity.

Joette Derricks, CPC, CHC, CMPE, CSSGB, CLHC, vice president of regulatory affairs and research with Anesthesia Business Consultants has worked in coding, auditing, and compliance for many years. “Every job I held since college was obtained through networking. When I had my own firm, networking resulted in many clients …” Derricks said.

Beyond personal gain, networking allows collaboration. With ICD-10 on our doorstep, two or more heads will be better than one when working through coding issues and questions the transition will surely bring.

Make Networking Second Nature

The benefits of networking became evident after my initial involvement in local chapters as reimbursement committee chairman of a national organization. I had little experience, but I knew connecting with the right people could enhance my knowledge.

Reimbursement meetings became a second home. I began acquainting myself with members and attendees, and I shared with them my desire to go back to school. The members went through the process with me and applauded my accomplishments. This drew us closer together and created an unbreakable bond. This volunteer position was the beginning of an invaluable personal and professional network, which continues to flourish.

Volunteer at your local chapter to start building lifelong relationships and broaden your opportunities for advancement. Get your name out there and connect with other healthcare professionals. Each day, introduce yourself to one person and start collecting business cards. What a prized possession my collection of business cards has become!

Master the Art of Networking

Networking is a two-way street. Within your network, share your ideas, experiences, and knowledge. If you don’t expect anything in return, you’ll learn more than you realize and experience the true power of networking.

Darlene F. Helmer, MBA, CMPE, CPC, CMA, ACS-AN,is vice president of provider education and training for Anesthesia Business Consultants (ABC). She has 30+ years of healthcare financial management and business experience. Helmer works closely with the ABC compliance department and is a member of the company’s ICD-10 training team. She is a longstanding member of AAPC and other associations, a frequent speaker at local and state conferences, and a member of the Baltimore East, Md., local chapter.

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Hire and Retain Excellent Coding Staff

Part 1: Finding the right person for the job takes more than luck.

By Pam Brooks, CPC, CPC-H

The job outlook for coders is good, according to U.S. Department of Labor statistics. Due to an aging population and an increase in insured Americans (compared to past years), the field is expected to grow as much as 21 percent. Coding is an attractive career option offering a professional environment, interesting work, and a median salary of $48,593 (AAPC Salary Survey, 2013). This should make it easy to find bright, talented, and enthusiastic coding staff, right? But as a hiring manager, I can tell you that finding good employees requires strategy.

Author’s Note: In this three-part series, we begin with a look at how to find accurate, efficient, and enthusiastic employees. In future installments, I’ll share tips on how to keep exceptional employees and how to improve the staff you already have. If you’re looking for a job, or looking to improve your current skills, you might pick up some tips, as well.

Set Expectations with the Job Description

You cannot expect to hire the right person unless you have a clear description of what that person’s job responsibilities will be. Ask for what you need, and be straightforward in how you ask for it.

Job descriptions include duties and tasks that are day-to-day assignments. For example, the job description might read, “Using CPT®, ICD-9-CM, HCPCS Level II, physician documentation, and other approved resources, to assign procedure and diagnosis codes, and modifiers, to all professional services.”

The job description also outlines responsibilities, which include all activities necessary to meet a particular need (e.g., “Serve as a definitive resource for physicians and administrative staff relative to technical guidance on professional coding issues.”). Tasks (e.g., training, auditing, educating staff and providers) should be based on the overall designated responsibility of the person in that position. That way, as tasks change, the responsibilities remain part of the job description.

Make sure the job description states all standards, guidelines, and expectations. This is how you can measure your employees’ work to quantify their success. For example, the job description might read, “Code with 95 percent accuracy as evidenced by quarterly external and internal audits.” This gives you metrics to support discussions regarding process improvement.

The job posting also should state education requirements. For example, you may require post-secondary coursework in anatomy, pathophysiology, and medical terminology, as well as coding certification or a bachelor’s degree. Do not settle for an under-qualified individual, unless you are willing to provide the education necessary to bring him or her to the required level. You can’t expect staff to learn without training, or to train themselves (even if you provide the tools). If you have the resources to train new coders, you can eliminate education requirements.

Aim High to Ensure Success

The job description should enumerate a candidate’s expected skills. For example, you might require “the ability to understand healthcare insurance guidelines as relative to correct coding initiatives,” or “experience in working with multiple reports, graphs, and spreadsheets in Microsoft Excel.”

If these skills aren’t present, existing staff might be able to train and mentor the new employee; but if your staff is already overworked and pressured, they may resent supervising a newbie. Don’t set up your new employee to be viewed as an inconvenience for everyone else. Set the bar high and make sure your job applicants have the necessary skills from the start.

Keep in mind: Listing required skills as part of the job description means existing employees must possess and maintain those skills, as well.

Prioritize Your Needs

Lack of experience can eliminate capable candidates. Consider what’s more important: time or talent? If the job requires solid evaluation and management (E/M) coding experience, for instance, you’ll need to hire someone who already possesses that knowledge. But if the position requires a specific skill set — such as being able to train the adult learner, data entry, or understanding financial reports — you may want to hire someone with less experience, as long as he or she can demonstrate the skill set.

After you’ve outlined the job description, consider the personality, appearance, and communication skills of the candidate. In composing a job posting, illustrate the kind of person you’re looking for. Use language from your organization’s mission, vision, and value statements to attract people with the same philosophy.

Where to Look

Posting to job boards, such as, will likely attract a wide range of applicants. If you need a specific skill set, it’s better to narrow the focus of your search. For example, if you need entry-level staff, contact your local coding or billing school and ask the program director for the name of their top student.

Sometimes, you already know who you want to hire because you’ve met him or her at an AAPC local chapter meeting. Likewise, attending job fairs can arm you with names and resumes of people in your area who are actively seeking work. You can even perform preliminary interviews on the spot.

For positions requiring specific or advanced skills, you can find candidates using resume searches on sites such as LinkedIn. A recruiter or headhunter can also help you locate talented, experienced individuals. The cost of the search might be worth the results. It also never hurts to recruit an employee who’s working elsewhere — particularly if he or she is doing the kind of work you need.

Sorting Through Resumes

Not all resumes are outstanding. If candidates don’t follow application directions, disqualify them. Look for poor formatting, misspelling, and grammatical errors. Anyone who makes a mistake on his or her resume likely won’t be meticulous working for you. Watch out for email addresses that might reveal the personality of the applicant, as well. You may not want to hire, for obvious reasons.

A good resume should contain demographics, including the applicant’s name and credentials on the header. A job objective is a nice feature, but if you have a prospective employee’s resume, it’s probably safe to assume that his or her objective is to obtain a job from you. Education, certification, and skills you’ve noted in your job posting should be clearly outlined.

A high-quality resume also lists experience in the form of outcomes. For example, the resume may outline what the prospective employee has done to make a difference in previous positions. Simple lists of job duties are often irrelevant, and tell very little about the applicant’s skill set.

Look for dates of unemployment, and don’t hesitate to ask what the applicant was doing during that time. If a candidate was unemployed for a long time, that’s not necessarily a deal-breaker. Find out if and how he or she was otherwise occupied, such as being in school, working as a volunteer, or being a full-time parent.

What to Look for During Interviews

Almost everyone looks decent on paper, as long as he or she meets your basic job criteria. Hiring managers have to dig deeper to pick the best candidate.

Start with a quick phone interview to begin weeding out individuals who don’t meet the requirements, who are looking for something outside of what you can provide, or who may not qualify for a more time-consuming onsite interview. It’s better to learn these things in a phone interview, rather than to find out in the first five minutes of an onsite interview. If you’re happy with this initial contact, schedule an onsite interview.

The onsite interview is the candidate’s first opportunity to sell his- or herself to you. Is he or she on time? Does his or her attire satisfy your dress code? Is the candidate prepared to supply you with documentation of his or her certifications, education, and references?

A prepared candidate has researched your facility so he or she understands the kinds of services it provides. The candidate should:

  • Have read the job description and come with good questions such as what a typical workday would be like
  • Have an eye on the future and a five-year plan to briefly discuss with you
  • Be willing to adapt to change and learn new concepts

Because you want all employees to be successful, you need to know and should ask, what tasks the applicant is not willing to do.

Behavioral interviewing is helpful to gauge how people will perform on the job when faced with certain situations. Ask thoughtful questions, such as, “Tell me about a time when a colleague created a problem for you.” What you want to hear is that the applicant was able to work it out with the colleague. Also, ask the applicant, “What would happen if I asked you to do something you didn’t agree with?” This gives you a bit of insight into how she would handle ethical dilemmas.

Set a 15-20 minute time limit for the onsite interview. If, after that time, it’s evident the applicant isn’t appropriate for the position, end the interview and politely tell the person that his or her skills don’t match your needs. Follow up later with a polite “Thank you for applying” email. Other courtesy options include offering to forward the applicant’s resume to other employers and providing constructive feedback about why you couldn’t hire the candidate.

If several applicants have similar job qualifications, the decision may be a matter of who appears to fit most comfortably with the existing staff. It may be helpful to involve the rest of the team when interviewing a potential hire. This can be stressful for the candidate, and time consuming for staff, but it also gives staff some ownership in the new employee’s success.

Tell Candidates about Background Checks

Inform potential new hires of any background checks you intend to make. If you accept federal money (e.g., Medicare), you must make sure your candidate is not on the Office of Inspector General’s (OIG) exclusion list. Other background checks might include a Social Security trace, a criminal record search, employment history verification, a search of the sex offender registry, and AAPC certification verification. Alerting the candidate in advance allows him or her to give approval (which you should get in writing), and to back out gracefully if any of these searches would uncover something embarrassing.

You might also check LinkedIn, Facebook, and Twitter, and perhaps perform a Google search. People have a right to their personal lives, but you want to identify any candidate whose public image is racist, inappropriate, or vulgar. This is also an excellent opportunity to discuss your company’s social media policy.

Many organizations also require a pre-employment physical and drug testing. Inform your candidates of these requirements if they are a requirement of employment.

Pre-employment Skills Testing Done Right

Testing can help you determine which candidates have the most knowledge of a particular coding specialty or skill. Some coding functions, however, are open to interpretation, such as E/M coding, and may not provide an accurate picture of the candidate’s skill set. Use testing only if it’s critical to evaluate the candidate’s ability to do the job, and only if you can provide full access to his or her real work environment.

To be fair, provide candidates with the tools they would need in their everyday work environment. Failing to replicate the workplace in a test situation places the candidate at a disadvantage, and prevents you from getting a clear picture of his or her skill level.

When you have several solid candidates, it may be helpful to pull their information together into a spreadsheet where you can compare their skills, experience, and other qualifications. Note any comments you made, concerns you had, questions that candidates handled particularly well, and the candidates’ availability or other logistical issues (such as commute time). Pay attention to applicants who took time to thank you for their interviews. This comparison allows you to pinpoint the candidate who rises above all others.

Pam Brooks, CPC, CPC-H, is the coding manager at Wentworth Douglass Hospital in Dover, N.H. She supervises a staff of multi-specialty coders and developed a team of medical auditors and educators, surgical specialty coders, and documentation improvement specialists. Brooks started in a mental health billing office and moved into management of an eating disorders practice. She earned a Bachelor of Science degree in Adult Education and Workplace Training from Granite State College and is completing a master’s in Health Administration from St. Joseph’s College, Maine. Brooks is a member of the Seacoast-Dover local chapter and sits on the AAPC Chapter Association board of directors, Region 1. She is a frequent contributor and speaks throughout New England and nationally regarding coding and career development topics.

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Ramp Up Your Compliance Training

7Atlis provides a clear path to sure-footed compliance education and training.

By Michelle Ann Richards, CPC, CPCO, CPMA, CPPM

The Patient Protection and Affordable Care Act of 2010 mandates all practices, regardless of size, implement a compliance program. Although a deadline for doing this has yet to be announced, it’s always better to be prepared. If your practice or organization does not have a written policy in its compliance plan for physician and staff training and education, now is the time to do so.

Awareness Is the First Step

Training is an essential element of a compliance program. If a practice or medical organization’s employees are not aware of compliance laws and office policies pertaining to their specific job descriptions, you can’t hold them accountable for the problems they may unwittingly create.

Best practices for ensuring your employees receive appropriate compliance training:

  • Have a job description for every position.
  • Define effective and engaging training that coordinates with your employees’ job descriptions.
  • Motivate your employees to learn more.
  • Track and document employees’ compliance training.
  • Measure Training Outcomes

To develop ongoing training and fulfill education requirements, best practices are to measure outcomes and determine whether current teaching methods are effective. For training to be effective, it should make a strong impression, produce a response from your employees, and be useful. Conduct competency testing to measure comprehension, and it’s a good idea to use pre- and post-training questionnaires to determine an employee’s engagement during the training. Also, provide employees with an avenue for expressing opinions about the training and for suggesting future trainings or resources that will help them.

Overall, training should be delivered, received, understood, and retained effectively. There is a variety of teaching methods you can use. A few examples are:

  • Interactive training
  • In-person training sessions
  • One-on-one training
  • Group training
  • Monthly newsletters or bulletins

Who Should Be Trained?

All personnel, employees, leadership, independent contractors, and agents should be educated on the significance of your compliance program. Be sure everyone understands the goal is to ensure a culture of compliance within your organization. As with any change in an organization, if employees are aware of why and how new policies will affect them personally, they will be less resistant to the changes.

Everyone should be educated in their role and adhere to the practice’s compliance program. They should understand their duty to report misconduct, the procedures and methods to report suspected misconduct, confidentiality and when and where confidentiality ends, and the non-retaliation policy for good faith reporting.

Each person in each department also should be educated and trained in the specific areas applicable to that department. All new employees should receive initial training regarding the compliance program and specific job-related compliance training as soon as possible after their date of hire.

Better Training Documentation Is Key

All internal and external education and training updates for all staff members should be required at least annually. These updates include making changes or updates to your compliance program, holding job-specific seminars, attending Medicare and Medicaid insurance update conferences, etc. It’s best practice to keep a record of when training takes place and a list of attendees.

You probably keep compliance training documentation on Excel spread sheets. This year, AAPC has a better solution for you: 7Atlis compliance solution software (See “The Only Compliance Management Software You’ll Ever Need” sidebar on the next page for more information).

Get Help with Training and Education

AAPC’s 7Atlis builds your foundation for training by adding all employees and linking them into key departments to help determine what training and education is required for each employee. 7Atlis then allows the core user to manage each employee’s compliance with his or her training and education requirements, so you will know when to upload training certificates and send reminders to the employee when they are due for upcoming training. It also provides deadlines for when training needs to be completed.

All training and education is based off of best practices and federal guidelines for compliance. Each module consists of interactive education that keeps staff members engaged in the learning process. Upon completion of each education module, the employee is prompted to take a quiz. Instant results are sent to the core user to be kept in the employee’s file.

Per OIG compliance guidelines, all training material should take into account the skills, knowledge, and experience of the individual — 7Atlis follows this guidance precisely.

You can keep records of each individual’s attendance at all training and education seminars, containing the outline and/or content of training. During annual audits these training records should be reviewed to insure training requirements have been met. 7Atlis allows the core user to pull up a snapshot file of training and education that will tell you in one glance who is non-compliant and who needs follow up.

Stay Compliant and Educated

There are constant changes to federal regulations, and many practices get caught up in their daily operations and forget about the compliance component of their business. Don’t let the government knocking on your door be a shocking reminder. Find out what it’s like to be confident about compliance; register for a free demo of 7Atlis today.

Michelle Ann Richards, CPC, CPCO, CPMA, CPPM, has 20 years of practice management experience and holds a Bachelor of Science in Health Care Administration. She has been an auditing and compliance consultant for AAPC since 2008 and is compliance manager, AAPC Compliance Division. Richards teaches the CPPM® boot camp and is a member of the Elyria, Ohio, local chapter. You can reach her at

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