AACCA Role and Status

Organizational Status of the Clinical Coder and/or Clinical Auditor Within a Healthcare Organization.

The American Association of Clinical Coders and Auditors, Inc. (AACCA) is a non-profit professional organization dedicated solely to the clinical coder and clinical auditor profession and, as such, is responsible for developing standards as they relate to clinical coding and clinical auditing of medical and surgical documentation, both for the medical profession and for the hospital industry.

The AACCA believes that the effectiveness of clinical coding and clinical auditing in a healthcare organization is directly related to the reporting relationship and organizational status of the clinical coders and clinical auditors.  Therefore, the AACCA takes the position that the clinical coder and clinical auditor should report on an authoritative level to the Chief Financial Officer and to the Board of Directors through its audit committee, if there is one, to ensure the greatest degree of independence and the support for a wide range of audit coverage.  For those organizations without a governing board overseeing operations direction, e.g. individual medical groups and individual hospitals within a system where there is no local governing board, the clinical coding and clinical auditing functions answer directly to the CFO and the Chief Executive Officer.

Administrative matters should be handled through someone within the organization who has sufficient authority (such as a compliance officer) and status to ensure that clinical coding and clinical auditing recommendations are addressed by operating management.  This person could also be the CFO.

The clinical coding and clinical auditing functions, purpose, goals, objectives, responsibilities, authority, and specific limitations to its authority, and the key relationships it maintains, should be delineated in a written affidavit.  Statements made in the affidavit should be agreed to, approved, and supported by both organizational management and its board of directors or equivalent body.

AACCA’s position is an adaptation to clinical coding and clinical auditing from a typically non-clinical Standards of Practice, but expands the authority and reporting to operational management.  At this time AACCA’s position is that clinical coding and auditing should be independent of the activities being audited.  This independence is achieved through both organizational status and objectivity.  The organizational status should be sufficient for the clinical coders and clinical auditors functions to carry out their work freely, to have complete access to all activities, records, and personnel, and to gain the cooperation of those whom they are auditing, in full compliance with Medicare, OIG and HIPAA regulations.

Joyce L. Thomas, MHA
Executive Director
April 4, 2003

Role and Organizational Status of the Clinical Coding and Clinical Auditing Function within a Healthcare Organization

The American Association of Clinical Coders and Auditors, Inc. a non-profit professional membership organization, is dedicated solely to the clinical coding and clinical auditing profession, and, as such, is responsible for developing standards as they relate to compliance with various OIG, Medicare, and HIPAA regulations, that will assist the healthcare industry.

The emergence and prevalence of clinical documentation and coding audits by hospitals and medical groups, has led to the development of a new audit position within healthcare organizations.  The position is typically staffed by Registered Nurses and other clinical professionals whose primary responsibilities are to promote the accuracy and integrity of medical and surgical documentation, the resulting CPT/HCPCS  and ICD9-CM coding which results in medical and hospital billing, and to identify discrepancies in charge capture, documentation, and systems.  As a result of these audits, recommendations are made to improve procedures, strengthen controls, enhance revenue, and improve cash flow.  To better define the role and organizational status of these positions, three key issues are addressed below:  

	Title
	Reporting Relationships
	Role Expansion

Although the primary responsibilities performed by clinical coders and clinical auditors are similar, there is little industry consistency in their various job titles.  The AACCA believes that the effectiveness of clinical coders and clinical auditors in these positions will be enhanced by the use of a standard job title.  Such standardization will provide a readily recognizable identity, will accurately associate the positions with the clinical coding and clinical auditing functions, will support continuing professional development, and will unify clinical coders and clinical auditors in this role; therefore, the  AACCA takes the position that the following titles be adopted as standard job titles:  

	RN-Coder® - This is a Registered Nurse who has successfully completed the AACCA Clinical Coding Certification examination and is in good standing as a member of AACCA and maintains certification thru continuing professional education annually;
	RN-Auditor® - This is a Registered Nurse who has successfully completed the AACCA Clinical Auditing Certification examination and is in good standing as a member of AACCA and maintains certification thru continuing professional education annually;
	Certified Clinical Coder® - This is a clinically-prepared professional, such as a Physician, Physicians Assistant, Physical Therapist, or Paramedic who has successfully completed the AACCA Clinical Auditing Certification examination and is in good standing as a member of AACCA and maintains certification thru continuing professional education annually;
	Certified Clinical Auditor® - This is a clinically-prepared professional, such as a Physician, Physicians Assistant, Physical Therapist or Paramedic who has successfully completed the AACCA Clinical Auditing Certification examination and is in good standing as a member of AACCA and maintains certification thru continuing professional education annually.

Consistent with, “Organizational States of the Clinical Coding and Clinical Auditing Function within a Healthcare Organization,” AACCA also believes that the value and effectiveness of clinical coders and clinical auditors is directly related to their reporting relationships and organizational states.  Clinical Coders and Clinical Auditors should not be positioned in departments to which many of their recommendations apply, and should not report, either directly or indirectly, to operating managers responsible for addressing their recommendations.  Such reporting relationships also limit the potential to expanding the clinical coder’s and clinical auditor’s role beyond revenue and compliance auditing.

The clinical coding and clinical auditing function, by virtue of its prescribed reporting relationships and organizational status, has support from sufficient levels of authority to conduct a wide range of activities, to have its recommendations addressed, and to ensure that its independence and objectivity are maintained.  Therefore, AACCA takes the position that clinical coders and clinical auditors should report directly to the chief financial officer.

The broadening of clinical coding and clinical audit teams and department expertise will benefit a medical group, a hospital or system, through a heightened understanding of the clinical component of healthcare services while clinical coders and auditors have ready access to professional auditing standards and recognized financial practices.  The combination of clinical, coding, financial and operational audit expertise can improve the quality of healthcare, the reimbursement of health care services by Medicare and other third-party payers, and increase the value of audit services and recommendations.

The AACCA believes that clinical coders and clinical auditors should be more fully utilized in areas such as operational reviews of clinical departments and medical groups, assisting healthcare providers to position their groups and facilities for optimal compliance with Medicare, OIG and HIPAA regulations, for optimal third-party reimbursement for all clinical services provided, and other related activities.  Therefore it is the AACCA’s position that the scope of the clinical coder’s and clinical auditor’s responsibilities be significantly expanded beyond revenue and compliance auditing.  This expansion of scope can best be achieved within the clinical coding and clinical auditing function where authority should already exist to conduct a wide range of activities.

Joyce L. Thomas, MHA
Executive Director

April 4, 2003