Erica E. Remer, MD, CCDS | Published on 1/31/2022
Confusion continues to obfuscate the intent of this new regulation, creating uncertainty for coding, billing and compliance.
There is a hierarchy in coding: the Official Coding and Reporting Guidelines and the American Health Association (AHA) Coding Clinics give recommendations on how to derive the correct code, but the ultimate, definitive source is the Tabular List.
Final rules are often lengthy, which I will attest to as someone who has slogged through their thousands of pages; however, David Glaser, an esteemed lawyer on Monitor Mondays, recently explained to me that the actual regulation is short. What you read in the Federal Register is the Preamble, the commentary, the exposition, similar to the Official Guidelines.
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