HIM 600 Module 7 Final Project Milestone Three Example

Reviewed by Delia Ravenscroft, MSN, RN

This HIM 600 Module 7 Final Project Milestone Three sample explains how an organization responds once an audit finds problems and how it proves its fixes worked. It was prepared for SNHU HIM 600 (HIM-600), where the third milestone asks MS Health Information Management students to plan the investigation, reporting, repayment and corrective action that follow compliance findings. At a composite 38-physician orthopedic and spine group in Boise, a record review found 29 of 60 sampled claims unsupported. The milestone quantifies and refunds those claims, describes the decision with counsel about reviewing earlier years, distinguishes a routine refund from a disclosure to federal authorities, sets out eight corrective actions with owners, deadlines and measures and schedules re-audits that will show whether accuracy improved.

CourseHIM 600 Managing Compliance
ModuleModule 7
Paper typegraduate milestone on responding to compliance findings and corrective action
LengthAbout 1,030 words, 6 pages
FormatAPA 7 student paper
SchoolSouthern New Hampshire University
ProgramMS Health Information Management
UpdatedOctober 2026

Free sample paper for HIM 600 Module 7

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Final Project Milestone Three: Paying Back and Fixing the Cause. Response and Corrective Action at Sawtooth Bone and Joint

[Student Name]

Southern New Hampshire University

HIM 600: Managing Compliance

Final Project Milestone Three

[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.

What this page is doingThe title pairs the two duties that follow a finding.
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Final Project Milestone Three: Paying Back and Fixing the Cause. Response and Corrective Action at Sawtooth Bone and Joint

Finding errors creates obligations. Once Sawtooth Bone and Joint, the composite Idaho orthopedic practice in this project, learned from its record review that 18 of 40 top-level office visits and 11 of 20 injection visits billed with modifier 25 were not supported, it could no longer treat those claims as uncertain. This milestone sets out the practice's response: investigating the scope of the problem, returning money it was not entitled to, deciding whether any matter must be disclosed, correcting the causes and checking that the corrections hold. Federal guidance describes responding to detected problems and developing corrective action as an element of an effective program, and it stresses that a response should address root causes rather than only the individual errors (U.S. Department of Health and Human Services, Office of Inspector General [HHS-OIG], 2023).

What this page is doingThe introduction frames findings as obligations.
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Investigating the Scope

The record review was a probe, so it shows that a problem exists but not how large it is. The compliance officer, the billing manager and outside health care counsel met within a week of the findings. Counsel advised that the practice must make a reasonable, timely effort to learn whether the same errors extend to earlier claims. The committee therefore approved a statistically valid random sample of office visits billed as 99215 and injection visits with modifier 25 from January 2022, when the group adopted its current templates, through the review period. An outside coding firm will draw and review the sample, under a written sampling design, which lets the per-claim error found in the sample be projected across every claim in the period. Counsel directs the work so that legal advice about the results is protected. The review is scheduled to finish within ten weeks, well inside the period federal rules allow for a good-faith investigation before an overpayment must be returned.

What this page is doingThe look-back is designed to be timely and defensible.
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Refunding What Is Owed

For the 29 claims already found unsupported, the overpayment is the difference between what was paid and what the documented level or service supports. For the 18 office visits, that is the difference between the 99215 payment and the 99214 or 99213 payment. For the 11 modifier 25 claims, the separately billed visit should not have been paid at all. The billing manager calculated each amount by payer. Medicare and Medicaid overpayments will be returned through the contractors' voluntary refund process with an explanation of the reason and the claims affected, and commercial payers will receive refunds under their contract terms. If the look-back sample shows a pattern, the extrapolated amount will be refunded the same way.

What this page is doingRefunds are calculated by claim and by payer.
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Refund or Disclosure

Not every overpayment needs to be reported to federal investigators. Ordinary billing errors, such as levels that are too high because clinicians misunderstood the guidelines, are corrected through refunds to the payer. The federal self-disclosure protocol is meant for conduct that may violate criminal, civil or administrative law beyond a simple overpayment, such as kickbacks or knowingly false billing, and disclosure under it can lead to a lower multiplier on damages than an investigation would (U.S. Department of Health and Human Services, Office of Inspector General, 2021). Nothing in the record review suggests intentional misconduct. Counsel will, however, review two matters before the refund decision is final: whether any clinician continued high-level billing after being told it was unsupported and whether the brace supplier's offer was ever accepted at any clinic. Either could change the answer.

What this page is doingThe milestone explains when disclosure is required and what could change it.
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Corrective Action Plan

Table 1 lists the corrective actions. Each has a single owner, a deadline and a measure that shows whether it worked. The actions target the causes found in Milestone One rather than only the clinicians whose claims were wrong.

Table 1. Corrective Action Plan

ActionOwnerDeadlineMeasure of success
Remove level suggestions from office visit templatesEHR analyst30 daysNo template displays a suggested level
Default injection template to a brief pre-procedure noteEHR analyst30 daysTemplate change in production
Claim edit holding modifier 25 on repeat injections for reviewBilling manager45 daysEdit active; held claims reviewed within 2 days
Guideline training with five-note coding testLead coder60 daysAll clinicians tested; 80% pass or retrained
Prospective review for clinicians below 90% accuracyLead coderStarts at 30 daysTwo consecutive monthly samples at 90% or better
Copied documentation policy and color displayCompliance officer60 daysPolicy signed by all clinicians; display active
Advanced practice billing rule and system checkBilling manager45 daysNo visits billed under a physician without documented participation
Written decline of supplier staffing offerPractice administrator7 daysLetter on file

Note. Owners report progress at each monthly compliance committee meeting.

What this page is doingEvery action has an owner, a deadline and a measure.
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Clinician Feedback

Each clinician whose claims were sampled receives a private meeting with the lead coder to go through the specific notes, what supported or failed to support the code and how the note could have been written. Burks et al. (2022) identified the lack of a feedback system as one of the main reasons outpatient billing stays inaccurate, and Sawtooth's clinicians had never seen a coder's view of their notes. The meetings are framed as education. Only a clinician who continues the same errors after training and prospective review moves to the graduated consequences described in Milestone Two.

What this page is doingFeedback is personal, specific and educational.
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Proving the Fix Held

Corrective action is not complete until a later audit shows improvement. The compliance officer will repeat the same probe design three months after the training deadline and again at six months. The targets are at least 90% accuracy for top-level office visits and modifier 25 claims and no copied examination findings that contradict the assessment. If the targets are missed, the committee will revisit the causes rather than repeat the same training. Results, refunds and actions will be documented in a single file that shows the practice found the problem, paid back what it owed and fixed what caused it.

What this page is doingRe-audits with targets close the loop.
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Conclusion

Sawtooth's response turns an uncomfortable finding into a record of good faith: a timely look-back under counsel, refunds by claim and payer, a reasoned decision about disclosure, corrective actions with owners and measures and re-audits to confirm the change. The final proposal will bring this response together with the program's structure and audit plan.

What this page is doingThe conclusion connects to the final proposal.
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References

Burks, K., Shields, J., Evans, J., Plumley, J., Gerlach, J., & Flesher, S. (2022). A systematic review of outpatient billing practices. SAGE Open Medicine, 10. https://doi.org/10.1177/20503121221099021

U.S. Department of Health and Human Services, Office of Inspector General. (2021). OIG's health care fraud self-disclosure protocol. https://oig.hhs.gov/compliance/self-disclosure-info/

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 7 instructions ask for

For the HIM 600 Module Seven milestone, the final project turns to what an organization does after it finds compliance problems. A typical submission runs four to five pages in APA 7 and covers investigating how far the problem extends, quantifying and returning overpayments, deciding whether a matter must be disclosed to a government agency, correcting root causes and confirming that corrections worked. Use the findings from your record analysis and the structure you designed in Milestone Two. Explain the role of legal counsel and why a probe sample may need to be followed by a larger review. Present corrective actions with owners, deadlines and measures, preferably in a table, and finish with a schedule of follow-up audits and the targets they must meet.

How this HIM 600 Module 7 final project milestone three example is built

Sawtooth Bone and Joint starts from 29 unsupported claims and a counsel meeting within a week. An outside firm draws a statistically valid sample back to January 2022, when the templates changed, inside the window for a good-faith investigation. Refunds are calculated claim by claim and payer by payer. The paper separates ordinary refunds from the federal self-disclosure protocol, naming two facts counsel must check first. Table 1 lists eight corrective actions, from removing level suggestions in templates to a written decline of the supplier's staffing offer. Private note-by-note feedback answers Burks and colleagues' point about missing feedback, and HIM 600 re-audits at three and six months aim for 90% accuracy.

Where the HIM 600 Module 7 rubric puts the points

Third-milestone rubrics in HIM 600 commonly reward an investigation that is timely and proportionate, correct handling of overpayments and refunds, an accurate distinction between refunding a payer and disclosing potential misconduct, corrective actions that address root causes, clear accountability through owners and deadlines and a plan to verify results. Strong papers involve counsel at the right points and explain why. Graders look for measures of success that are observable, such as an edit in production or an accuracy rate, rather than statements that training occurred. Treating clinicians fairly while still holding them to the standard shows maturity. A well-organized table and correct APA 7 citations for federal guidance round out the higher scores.

HIM 600 Module 7 help: the mistakes that cost points

Response plans in this course often slip by promising to fix errors without refunding the money already received, by sending every overpayment to the federal self-disclosure protocol, by listing actions without owners or deadlines or by ending at training without any follow-up audit. Some also treat a ten-claim probe as the final word on how much is owed. If your milestone uses a hospital, a payer audit result or a different set of findings from the course case, send them along with your earlier milestones and the response will be built around them. Notes on who has authority in your setting help assign realistic owners. Our HIM 600 milestones refund first, decide disclosure with reasons, assign every action and re-audit.

Get HIM 600 Module 7 written to your instructions

Send the HIM 600 Milestone Three guidelines along with your earlier milestones or audit findings. You will receive a response plan covering the look-back, refunds by payer, the disclosure decision, a corrective action table with owners, deadlines and measures and follow-up audits with targets, completed within 24 to 48 hours, with the first request 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.

More HIM 600 papers and related MS Health Information Management samples

HIM 600 Module 7 questions, answered

Where can I find a free HIM 600 Module 7 Milestone Three sample?

The complete HIM 600 Milestone Three paper appears on this page, covering refunds, a counsel-led look-back, the disclosure decision and an eight-step corrective action plan for an orthopedic group.

What should a corrective action plan include?

Each action should target a root cause and have a named owner, a deadline and a measure that shows whether it worked, followed by a re-audit to confirm the improvement.

When should a practice use the OIG self-disclosure protocol?

When conduct may violate fraud and abuse laws beyond a simple overpayment, such as kickbacks or knowingly false billing. Routine billing errors are usually refunded to the payer instead.

How are overpayments from coding errors calculated?

By comparing what was paid with what the documentation supports for each claim, and, when a pattern is found, by extrapolating from a statistically valid sample to the full set of affected claims.

Why involve legal counsel after an audit?

Counsel helps decide how far back to look, whether disclosure is required and how to protect legal advice, and can direct the look-back review so its findings are handled appropriately.