Medical Coding Audit Prevention for 2024 Healthcare Compliance Strategy

With Q4 of 2023 coming around the corner, it’s time to start looking at plans for 2024. It might not seem like it should make your short list of priorities, but medical coding audits should be on the mind of your leadership team today – specifically looking for ways to get in front of them. 

Healthcare providers will be in a much better position next year if they take the remainder of 2023 to step back, look for current issues, and devise ways to prevent and respond. You might feel prepared since you recently reviewed your strategy around medical coding and medical coding audit processes – but I want to stress the fact that the healthcare landscape is much more volatile than it has been in the past. Issues around COVID and labor shortages mean that taking another, updated look will likely be highly beneficial to your long-term organizational health. I see this broadly playing out from three potential angles:

Early Action

If an organization starts early in identifying issues like upcoding (billing for services that weren't provided) and employee supervision issues, they’ll be able to make smart adjustments to revenue cycle processes and outsourcing strategies. These should be aligned with current and coming challenges – and these coming challenges aren’t just hypothetical. CMS is sending multiple signals that providers should expect an increase in medical coding audits.  

Program Design

We can look to CMS’ 7 core compliance requirements for some guidance on taking action. Element VI is Suggest an Effective System for Routine Monitoring, Auditing, and Identification of Compliance Risks. The agency highlights the importance of internal monitoring and audits, including external audits to keep up with compliance with CMS requirements and general compliance program effectiveness. 

Billing and Outsourcing Strategy

To prepare for 2024, most providers will also need to turn their medical coding teams and departments into “centers of excellence” – investing in staff training, smart KPI creation and monitoring, process improvement, and in many cases, tapping into the type of outsourcing relationships that fit their unique needs. 

Remember, revenue cycle management has changed. We’re now functioning in a volatile environment where ongoing adjustments are necessary. Thankfully, providers have never had so many tools and options at their disposal.