Adding associates also introduces compliance risk

A booming economy is an exciting thing to witness. People are happier; stress seems to subside. You can feel it in your practice as well — the exuberance of growth tempered by the stress of needing to add an associate to help accommodate the growth of your practice. Onboarding new associates can be problematic in transitioning patients to them, learning their strengths and weaknesses and educating them on policies and procedures unique to your practice. Of course, medical coding and compliance issues add an additional layer of complexity. Let’s discuss common pitfalls.


New associates need to be credentialed by each individual third-party plan contracted with your practice in order to see those patients, unless your state happens to have legislation that allows them to do so while the credentialing is in process.

I have seen practitioners audited for services an uncredentialed doctor within their practice provided for insured patients. It’s easy to detect — either the uncredentialed providers NPI isn’t part of the plan, or, worst yet, the credentialed doctor’s NPI is used on the claim, but the medical record shows that the services were provided by the uncredentialed doctor. There isn’t a good defense for this. I have seen the penalties for this range from having to pay back the monetary value for all of the services provided by the uncredentialed doctor to removal of all doctors from the plan.


Habits are hard to break. New associates in a practice may have learned their medical record-keeping skills, and subsequent coding and compliance practices, from a number of sources. These may not be consistent with what you are doing. Create a clear, concise and compliant medical records and coding policy applicable in your geographic location. Keep in mind the new practitioner may not be familiar with your zip-code specific rules regarding medical necessity of clinical procedures or how your EMR functions. Why is this so important as the business owner? Even though the new associate is on the hook for coding liability, because each line item service is billed under their NPI, your business is on the hook financially because it is the business’s NPI that received the funds, and it is the party responsible for any financial liability in an audit.


Institute an onboarding session regarding your clinic’s policies of coding vision vs. medical, ordering special ophthalmic testing, providing surgical services, and testing in clinical labs. Some questions this session may answer: Do you use both the 920XX and 992XX codes appropriately, or do you use just one set or another? How do you handle providing comprehensive eye examinations for individuals with diabetes? How do you communicate with other physicians in your community? How do all of these get recorded in the medical record? All of these little things often create problems if not addressed early.


Having a clear, comprehensive process of credentialing, medical record creation, coding and compliance is critical to success. Create opportunities for a new associate to learn by giving them ownership of the process. Doing so will provide benefits of growth while simultaneously mitigating the risk. OM