External Coding Vendors for Coding Services, Reviews and Related Education - Policy REGS.COD.017

Sep 12, 2026

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Policy REGS.COD.017 establishes requirements for using external coding vendors to perform ICD-10-CM/PCS and CPT/related prospective payment group coding and coding review services for outpatient and inpatient medical record documentation. It defines scope across company-affiliated facilities and corporate departments, outlines vendor selection and scheduling through PWMS, and specifies orientation, reporting timelines, and documentation retention. The policy excludes chargemaster reviews and certain physician professional services coding or billing reviews.

LanguageEnglish

CategoryForms

FormatPDF

Pages6

Reading Time2 min

AccessFree to download

Scope

Purpose

Policy Requirements

Procedure

Section I: Selecting and Scheduling External Vendors for Coding Review Services

Vendor Arrangements and Work Order Requirements

Orientation and Training

Reporting and Documentation Retention

| DEPARTMENT: Regulatory Compliance Support | POLICY DESCRIPTION: External Coding Vendors for Coding Services, Reviews and Related Education | | --- | --- | | PAGE: 1 of 6 | REPLACES POLICY DATED: 2/1/10, 5/1/11, 2/1/12 | | EFFECTIVE DATE: October 1, 2015 | REFERENCE NUMBER: REGS.COD.017 | | APPROVED BY: Ethics and Compliance Policy Committee | | | SCOPE: All Company-affiliated facilities including, but not limited to, hospitals , HIM Service Centers (HSC) and all Corporate Departments, Groups and Divisions, including, but not limited to, the following departments:
Facility Health Information Management Department Ancillary Departments
Corporate Regulatory Compliance Support Legal
Case Management/Quality Resource Management Finance
Supply Chain Service Centers
Ethics & Compliance Officers Administration
HealthTrust Workforce Solutions | | --- | | PURPOSE: To ensure that all ICD-10-CM/PCS/CPT coding and coding review services of medical records for outpatient and inpatient visits and education related to such services performed by external vendors are compliant with official coding guidelines, Company coding policies, and other regulatory requirements. | | POLICY: Inpatient coding and coding review services shall include, at a minimum , the assignment and/or the validation of ICD-10CM/PCS diagnosis and procedure codes, MS-DRG, DRG, and/or other mandated prospective payment group assignment, based on supporting medical record documentation.
Outpatient coding and coding review services shall include, at a minimum , the assignment and/or validation of ICD-10-CM/PCS diagnosis code, CPT procedure codes, ASC, APG, APC, or other prospective payment group assignment, and ICD-10-CM/PCS procedure coding, if applicable, based on supporting medical record documentation.
Coding and coding review services will meet the quality and business practice standards established in this policy with either a certified vendor or a vendor that adheres to the policy standards. Certification of vendors is the responsibility of the Corporate Regulatory Compliance Support Department. Contract negotiation is the responsibility of HealthTrust Workforce Solutions. This policy does not apply to chargemaster reviews or coding/billing reviews for physician professional services. | | PROCEDURE: The following procedures outline the process for any facility, Group, Division, or Corporate Department to utilize once they have determined to initiate a coding service or review service by an external coding vendor. Coding review services (Section I) and coding services (Section II) require different steps to be taken.
SECTION I: Selecting and Scheduling External Vendors for Coding Review Services
Any facility, Group, Division, Service Center or Corporate Department requesting a retrospective external coding review service must choose a vendor from the certified vendor list and follow the process outlined below. | | DEPARTMENT: Regulatory Compliance Support | POLICY DESCRIPTION: External Coding Vendors for Coding Services, Reviews and Related Education | | --- | --- | | PAGE: 2 of 6 | REPLACES POLICY DATED: 2/1/10, 5/1/11, 2/1/12 | | EFFECTIVE DATE: October 1, 2015 | REFERENCE NUMBER: REGS.COD.017 | | APPROVED BY: Ethics and Compliance Policy Committee | | The facility may request assistance from Regulatory Compliance Support for clarification and/or determination of the need, scope, and reporting of any external coding review. The facility must select a vendor from the certified vendor list. (See the list of Certified External Vendors for Coding Reviews/Services at the following: Certified External Vendors for Coding Reviews/Services available on the Company’s Intranet site) . A. The facility/HSC must make arrangements for the review through PWMS, not with the vendor directly. 1. All arrangements must be confirmed in writing by completing the Work Order/Provider Agreement for Coding Review Services (See Attachment A) . a. Facil

FAQs

What services are covered by this policy for external vendors?

The policy covers ICD-10-CM/PCS and related coding and coding review services for inpatient and outpatient visits, including assignment/validation of diagnosis and procedure codes and mandated prospective payment group assignments based on supporting documentation.

How must a facility arrange coding review services with an external vendor?

The facility/HSC must arrange through PWMS rather than directly with the vendor, and must confirm arrangements in writing by completing the Work Order/Provider Agreement for Coding Review Services.

When are final reports due after an external vendor engagement?

Final reports must be submitted to the facility or requester and copied to PWMS as agreed in the Work Order/Provider Agreement within 30 days after completion of the engagement.

Sep 12, 2026

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