| Course | HIM 600 Managing Compliance |
|---|---|
| Module | Module 5 |
| Paper type | graduate milestone designing the structure of a coding compliance program |
| Length | About 1,030 words, 6 pages |
| Format | APA 7 student paper |
| School | Southern New Hampshire University |
| Program | MS Health Information Management |
| Updated | October 2026 |
Free sample paper for HIM 600 Module 5
Final Project Milestone Two: Who Owns It and What the Rules Say. Structure of the Coding Compliance Program at Sawtooth Bone and Joint
[Student Name]
Southern New Hampshire University
HIM 600: Managing Compliance
Final Project Milestone Two
[Instructor Name]
[Date]
The organization, setting and figures below are a composite written as a model document. No real employer, client, colleague or patient is described.
Final Project Milestone Two: Who Owns It and What the Rules Say. Structure of the Coding Compliance Program at Sawtooth Bone and Joint
The record review in Milestone One found that 45% of sampled top-level office visits and 55% of same-day injection visits billed with modifier 25 at Sawtooth Bone and Joint were not supported by documentation, and it traced those errors to missing training, permissive templates and the absence of feedback. This milestone designs the structure that will address those causes: who is accountable, what the written rules say, how people learn them, how concerns are raised and what happens when rules are broken. Auditing, monitoring and the response to findings are developed in the next two parts of the project. The design follows the federal general compliance program guidance, which treats these parts as working functions rather than documents (U.S. Department of Health and Human Services, Office of Inspector General [HHS-OIG], 2023), and it is sized for a physician-owned group of 38 physicians, not a health system.
Oversight and Accountability
The practice will appoint a compliance officer, the role I currently hold part time, with the time increased to half of a full position for the first two years. The officer will report directly to the three managing partners and will meet with them in a closed session each quarter, without the administrator present, so that reports about physicians or management are not filtered. The officer will not report to the billing manager, because the program must be able to question billing decisions.
A compliance committee will gather every month through the first year, then every three months. Its members are one managing partner, two physicians from different subspecialties, the practice administrator, the billing manager, the lead coder and the physical therapy manager, with outside health care counsel available as needed. The committee approves policies, reviews audit results and corrective actions and decides when a matter must go to counsel. Minutes will record decisions and owners. The managing partners will receive a written compliance report twice a year and must formally accept it, which puts on record that the owners saw each finding.
Written Policies
Each new policy answers a finding or a known risk. Table 1 lists the seven policies, what each requires and the evidence that prompted it. A policy is approved by the committee, signed by every clinician and coder and reviewed every year or whenever guidelines change.
Table 1. Coding Compliance Policies and Their Basis
| Policy | Core requirement | Basis |
|---|---|---|
| Office visit documentation | Level chosen from documented decision making or recorded total time; templates may not suggest a level | 45% of 99215 visits unsupported |
| Modifier 25 | Separate visit billed with an injection only when a distinct problem or substantial new evaluation is documented | 55% of modifier 25 claims unsupported |
| Copied documentation | History and lists may be copied after review; examination findings recorded fresh; copied text shown in a different color | 28% of notes repeated a prior exam |
| Coder queries | Coders query the author when documentation conflicts or does not support a code, using non-leading questions | Claims released without review |
| Advanced practice billing | Visits billed under the physician only when the physician's participation is documented | Two visits billed under the wrong number |
| Referral and vendor arrangements | No free staff, space or services from parties that receive referrals; all contracts reviewed by counsel | Brace supplier offer |
| Overpayments and refunds | Identified overpayments quantified and returned within the federal deadline | Refunds owed from the record review |
Note. Prepared by the author from the Milestone One review and the practice's current arrangements.
Training and Education
Training is role-based. All staff complete an hour each year on the compliance program, the reporting line and the fraud and abuse laws. Physicians and advanced practice providers complete two hours on the office visit guidelines and modifier 25, built around de-identified notes from our own review, followed by a short coding test in which each clinician levels five sample notes. Coders complete the same content plus query writing. In a two-phase study of orthopedic clinicians, Balusu et al. (2026) showed that how sure people felt about their coding said little about how well they coded, while focused teaching on the current rules did raise accuracy, so the test matters more than attendance. A clinician who scores below 80% repeats the session with the lead coder within a month. New clinicians complete the training before their first claims are released.
Reporting and Communication
Staff can raise concerns with the compliance officer in person, by email or through an anonymous telephone and web line run by an outside vendor, which is advertised in every clinic and in the employee handbook. Every report is logged, acknowledged within two business days if the reporter is known and resolved or escalated within thirty. A written non-retaliation policy, signed by the managing partners, protects anyone who reports in good faith. The officer will also send every employee a short update each quarter describing, without names, what kinds of concerns were raised and what changed as a result, so that people see reports lead somewhere.
Consequences and Culture
Policies need consequences that apply to everyone. The practice will use a graduated approach: education for a first error, focused review of the clinician's claims for a repeated pattern and referral to the managing partners for refusal to correct or for deliberate misconduct, which may affect compensation or partnership standing. The rule that matters most is consistency, because a program that excuses its highest billers teaches everyone that the rules are optional. Kaptein (2011) found that unethical behavior in organizations was lower where expectations were clear, leaders modeled them, employees could discuss dilemmas openly and misconduct was consistently addressed. The structure here is meant to build those conditions, not only to punish. The practice will also add a compliance measure, the clinician's audit accuracy rate, to the annual review of every physician, alongside productivity.
Conclusion
This structure gives Sawtooth an accountable officer who can speak to the owners without a filter, policies that answer what the records showed, training that tests understanding, a reporting line people can trust and consequences that do not depend on who made the error. The next milestone adds the auditing cycle and the response to findings, which will show whether this structure actually changes how the practice bills.
References
Balusu, S. S., Patel, M. S., Williams, A. J., Kalkman, J., Latack, K. A., & Day, C. S. (2026). Coding and billing education with new documentation guidelines: Investigating orthopedic provider confidence and accuracy. Journal of Healthcare Management, 71(5), 335-346. https://doi.org/10.1097/JHM-D-24-00228
Kaptein, M. (2011). Understanding unethical behavior by unraveling ethical culture. Human Relations, 64(6), 843-869. https://doi.org/10.1177/0018726710390536
U.S. Department of Health and Human Services, Office of Inspector General. (2023). General compliance program guidance. https://oig.hhs.gov/compliance/general-compliance-program-guidance/
What the HIM 600 Module 5 instructions ask for
Module Five of HIM 600 brings the second milestone of the final project, which designs the structure of the compliance program. Most prompts expect four to five pages in APA 7 that describe oversight and reporting relationships, the written policies and procedures, training and education, lines of communication and the consequences for violations. Each part should respond to what your record analysis found rather than restate generic program elements. Explain who the compliance officer reports to and why, who sits on the committee and what it decides. List the policies with their core requirements, describe training by role and how understanding will be checked, and set out reporting channels and non-retaliation. Close by showing how the structure supports the auditing and response plan to come.
How this HIM 600 Module 5 final project milestone two example is built
Sawtooth Bone and Joint's structure starts from Milestone One's unsupported claims. The compliance officer reports to the three managing partners in closed quarterly sessions rather than to billing, and a committee of physicians, administration, coding and therapy staff approves policies and reviews audits. Table 1 lists seven policies, each tied to evidence, from a modifier 25 rule answering the 55% error rate to a vendor policy prompted by the brace supplier offer. Training is role-based with a five-note coding test, supported by Balusu and colleagues' finding that confidence did not predict accuracy. An outside hotline, a non-retaliation policy, graduated consequences grounded in Kaptein's work on ethical culture and an accuracy measure in physician reviews complete the HIM 600 milestone.
Where the HIM 600 Module 5 rubric puts the points
Graders of the HIM 600 second milestone usually look for a structure that includes every element of an effective program, a rationale for reporting relationships that protects independence, policies that respond to identified risks, training matched to roles with a way to measure learning, accessible reporting channels with protection from retaliation and consequences applied consistently. The higher levels go to designs scaled realistically to the organization, with named roles, meeting frequencies and timelines. Linking each element back to the record analysis shows continuity across the project. Writers who address culture as well as rules, and who explain how leaders will be held to the program, tend to score better. Organized tables and correct APA 7 citations also count.
HIM 600 Module 5 help: the mistakes that cost points
Structure papers for HIM 600 tend to slip by copying the seven elements as headings with a sentence under each, placing the compliance officer under the billing department, writing policies unrelated to any finding or describing training only by hours attended. Some drafts also forget to say how physicians who resist will be handled. If your project centers on a hospital coding department, a health system or another kind of organization, send your Milestone One findings and the prompt so the structure can be scaled to that setting. Details about who currently owns billing decisions help a great deal. Our HIM 600 milestones tie every policy and training choice to evidence and keep the officer independent.
Get HIM 600 Module 5 written to your instructions
Send your HIM 600 Milestone Two guidelines with your Milestone One findings or the course case. We will write a program structure with an independent reporting line, a committee, policies traced to your findings, role-based training with a check of understanding, reporting channels and consistent consequences. It arrives in 24 to 48 hours, and the first one is free. The paper above is an original model document written by our desk, not a submitted student paper and not an official Southern New Hampshire University document.
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HIM 600 Module 5 questions, answered
Where can I find a free HIM 600 Module 5 Milestone Two sample?
The whole HIM 600 Milestone Two paper is shown on this page, setting out oversight, seven policies tied to audit findings, tested training, a reporting line and graduated consequences for an orthopedic group.
Who should a compliance officer report to?
Ideally to the governing body or owners, with direct access that does not run through billing or finance, so the officer can raise concerns about any department or leader without a filter.
What policies belong in a coding compliance program?
Policies on documentation and level selection, modifiers, copied text, coder queries, billing for advanced practice providers, referral and vendor arrangements and the handling of overpayments are common, chosen according to the organization's risks.
How should compliance training be evaluated?
By testing what people can do afterward, such as leveling sample notes correctly, rather than counting attendance, and by retraining those who score below a set threshold.
How does Milestone Two connect to the rest of the HIM 600 project?
It builds the structure that responds to Milestone One's record analysis, and Milestone Three then adds the auditing cycle and the response to findings before everything comes together in the final proposal.