# What changes can a Billing Specialist/Biller (not CPC) make?



## kstine713 (May 31, 2019)

Hello!

    I have two questions in relation to this: 

    1.) Can I get some clarification around what changes are appropriate for a Biller to make if they are not a certified coder?  For instance, are they able to add modifiers based on what an insurance requires without consulting the physician?  Also, if the physician added 10 diagnosis codes to a claim, and didn't link the correct diagnosis to one of the procedure codes, can a biller "re-link" diagnosis codes to procedure codes, if they are not actually changing any of the diagnosis codes?

    2.) If a provider sends a message to a biller with changes that need to be made to diagnoses or procedures, based on that message from the provider, are the billers okay to make changes to the provider's progress note, or does the provider have to make the change in their note since the biller isn't a certified coder?

Thank you!
Kaytie


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## thomas7331 (May 31, 2019)

There are no regulations governing who can assign codes.  Ultimately, the practice owners and their managers are responsible for the accuracy of the codes since they're the ones to whom payment is made.  The answers to your questions above are ones that all practices have to make, based on how they wish to optimize the resources they have available and to balance the need to operate efficiently while minimizing risk and ensuring quality coding.  These are business decisions, not regulatory requirements, so there is no general rule for this - each practice needs to look at how well their coders, billers and providers are able to handle the coding and documentation tasks.  For specialties with complex coding needs, a certified coder may work best, but for practices that have straightforward coding without much complexity, it may be sufficient to allow a biller or provider to handle all their coding themselves.


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## RDK720 (Jun 18, 2019)

Hi. This is from Noridian. 

Another point, if the provider is requesting to change or changes the EHR *AFTER* submission of the claim, this would constitute fraud. 

*Documentation Guidelines for Amended Medical Records*
*Elements of a Complete Medical Record*
When records are requested, it is important that you send all associated documentation that supports the services billed within the timeframe designated in the written request. Sometimes that information may come from a visit or test performed earlier than the claim in question. Elements of a complete medical record may include:

Physician orders and/or certifications of medical necessity
Patient questionnaires associated with physician services
Progress notes of another provider that are referenced in your own note
Treatment logs
Related professional consultation reports
Procedure, lab, x-ray and diagnostic reports
Billing provider notes for billed date of service
*Amended Medical Records*
Late entries, addendums, or corrections to a medical record are legitimate occurrences in documentation of clinical services. A late entry, an addendum or a correction to the medical record, bears the current date of that entry and is signed by the person making the addition or change.
*Late Entry:* A late entry supplies additional information that was omitted from the original entry. The late entry bears the current date, is added as soon as possible, is written only if the person documenting has total recall of the omitted information and signs the late entry.
Example: A late entry following treatment of multiple trauma might add:_ "The left foot was noted to be abraded laterally. John Doe MD 06/15/09"_
*Addendum:* An addendum is used to provide information that was not available at the time of the original entry. The addendum should also be timely and bear the current date and reason for the addition or clarification of information being added to the medical record and be signed by the person making the addendum.
Example: An addendum could note_: "The chest x-ray report was reviewed and showed an enlarged cardiac silhouette. John Doe MD 06/15/09"_
*Correction:* When making a correction to the medical record, never write over, or otherwise obliterate the passage when an entry to a medical record is made in error. Draw a single line through the erroneous information, keeping the original entry legible. Sign or initial and date the deletion, stating the reason for correction above or in the margin. Document the correct information on the next line or space with the current date and time, making reference back to the original entry.
Correction of electronic records should follow the same principles of tracking both the original entry and the correction with the current date, time, reason for the change and initials of person making the correction. When a hard copy is generated from an electronic record, both records must show the correction. Any corrected record submitted must make clear the specific change made, the date of the change, and the identity of the person making that entry.
*Falsified Documentation*
Providers are reminded that deliberate falsification of medical records is a felony offense and is viewed seriously when encountered. Examples of falsifying records include:

Creation of new records when records are requested
Back-dating entries
Post-dating entries
Pre-dating entries
Writing over, or
Adding to existing documentation (except as described in late entries, addendums and corrections)
Corrections to the medical record legally amended prior to claims submission and/or medical review will be considered in determining the validity of services billed. If these changes appear in the record following payment determination based on medical review, only the original record will be reviewed in determining payment of services billed to Medicare.
Appeal of claims denied on the basis of an incomplete record may result in a reversal of the original denial if the information supplied includes pages or components that were part of the original medical record, but were not submitted on the initial review.
*Resources*

Section 1833(e) Title XVIII of the Social Security Act (No Documentation)
Section 1842(a)(1)(c) of the Social Security Act (Carrier Audits)
Section 1862(a)(1)(A) of Title XVIII of the Social Security Act (Medical Necessity)
Schott, Sharon. "How Poor Documentation Does Damage in the Court Room." Journal of AHIMA 74, no. 4 (April 2003): 20-24
Dougherty, Michelle. "Maintaining a Legally Sound Health Record." Journal of AHIMA 73, no. 8 (April 2003): 64A-G
Last Updated Aug 14, 2018


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## kstine713 (Jun 25, 2019)

RDK720 said:


> Hi. This is from Noridian.
> 
> Another point, if the provider is requesting to change or changes the EHR *AFTER* submission of the claim, this would constitute fraud.
> 
> ...




Would you be able to provide the link from where you pulled this?  Extremely helpful, thank you!


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## RDK720 (Jun 25, 2019)

kstine713 said:


> Would you be able to provide the link from where you pulled this?  Extremely helpful, thank you!



Hi. Link below and hope it helps 

https://med.noridianmedicare.com/we.../documentation-guidelines-for-amended-records


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