October 15, 2015


I verify all the information my clients send me as part of my services.

My question is the word “facilitate”. If I find that the diagnosis code they have given me is not a billable code, where do I fall between fairly innocuous to "orange is the new black" exposure by letting them know that it is not a billable code and they need to provide a more detailed code? I am not telling them it is wrong – just not complete. This will be a problem as we enter the ICD 10 era.

Thank you for your help in this manner and the valuable advice you provide in your newsletters.



Good question, and again I would refer back to your services agreement.  You want to make sure it is clear in your agreement (1) you are not responsible for code selection; (2) the client in indemnifying you for their code selection; (3) your liability is limited – and set forth in what amount; and (4) if you are providing claims scrubbing services, you again, disclaim liability.  

My take on what you describe below is claims scrubbing – you are not directing towards a new code selection and you are requiring client direction on any final submission.  Just make sure your contract matches your services.  

Dear Jennifer,

Thank you for your timely post.  We have been providing revenue cycle management services to physicians and physician groups for the past 20 years.  ICD-10 has proven to be the most challenging change that we have been forced to get our clients to rally around.  We started educating our clients over 12 months before the expected 2014 ICD-10 implementation date and kept right through even when it was delayed, anticipating the 2015 effective date.  My advice? Physicians, your billers need your involvement!  Billers, you need to educate your physicians!  This is a team effort and everyone will either win or lose if/when claims start getting denied.  Get someone, or some people, to “champion” the cause in your practice our your billing company/department.  We developed an ICD-10 committee, including certified coders, operations folks and managers,  to make sure we were doing everything we possibly could to be ready. Do not take this lightly.  It can have a disastrous effect on your financial well-being. 


Barry Haitoff | CEO

Medical Management Corporation of America
1620 Route 22, Brewster, NY 10509 | www.mmcoa.com
T: 845-363-4833 | C: 845-494-6596
F: 845-278-8796 | bhaitoff@mmcoa.com


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Contact Jennifer at Jennifer@Kirschenbaumesq.com or  at (516) 747-6700 x. 302.