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Clinical Coding
Audit Report

University Hospital Llandough


Cardiff and Vale University Local Health Board

Mr Richard Burdon, ACC, NCS Approved Auditor, NWIS


Mrs Helen Dennis, ACC, NWIS
Clinical Coding Audit – Llandough Hospital

CONTENTS

University Hospital Llandough – Clinical Coding Audit Report ....................................................... 3


Executive Summary ...................................................................................................................... 3
2 Introduction ......................................................................................................................... 8
3 Aims.................................................................................................................................... 9
4 Objectives ........................................................................................................................... 9
5 Background ......................................................................................................................10
6 Methodology .....................................................................................................................13
7 Findings ............................................................................................................................15
8 Conclusions ......................................................................................................................26
9 Recommendations ...........................................................................................................27

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University Hospital Llandough – Clinical Coding Audit Report

Executive Summary

1.1 Introduction

1.1.1 In seeking to undertake an audit of clinical coding services as part of their 2013/14
audit programme, the Wales Audit Office (WAO) has sought assistance from the
NWIS Clinical Classifications Team to undertake audits of clinical coding accuracy
across all Welsh Local Health Boards (LHBs) and Velindre NHS Trust.

1.1.2 This report outlines the findings and recommendations of the NHS Wales
Informatics Service (NWIS) Clinical Classifications Team audit of clinical coding
accuracy at Llandough Hospital.

1.2 Methodology

1.2.1 The sample audited was 99 Finished Consultant Episodes (FCEs), which were
randomly generated from the activity data held within the Patient Episode Database
for Wales (PEDW). Only FCEs from the specialties of General Medicine, General
Surgery and Trauma & Orthopaedics were audited. The period audited covered
episodes with an end date of 1st may 2013 – 31st August 2013 inclusive. Episodes
were also limited to being no longer than 10 days in length.

1.2.2 The locally assigned classification codes were audited against national clinical
coding standards using the information available in the patients’ case notes and
relevant electronic systems (e.g. RADIS).

1.2.3 Attention was also paid to the patient case notes being used by the coders and
auditors in order to assess their impact on the assignment of codes.

1.3 Findings

1.3.1 Below is a breakdown of the error rates:

Code Type Total Number of Total Number of Percentage Correct


Codes Correct Codes
Reviewed
Primary 98 77 78.57%
Diagnosis
Secondary 255 194 76.08%
Diagnosis
Primary 96 87 90.63%
Procedure
Secondary 264 248 93.94%
Procedure

1.3.2 In addition to the percentages given above a number of specific findings were made
by the auditors:

 The most prevalent type of errors uncovered during the audit are errors of omission.
Errors due to codes being omitted account for 63.55% of all errors encountered
during the audit (68 out of 103 errors), and in the case of Secondary Diagnosis
errors account for 81.97% of all errors in that area (50 out of 61 errors).

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 Clinical coding staff do not appear to be consulting histology reports when assigning
codes to an episode. Out of 21 primary diagnosis errors 5 (23.81%) were due to
clinical coding staff not assigning a more specific code that was available from
information contained within histology results that they had access to at the time of
coding the episode.

 The clinical coding staff are consistently incorrectly assigning codes for
haemorrhoids in the primary diagnosis position when they are an incidental finding
or secondary diagnosis. This was the underlying reason for 7 of the 21 (33.33%)
primary diagnosis errors.

 The coding of procedures by the department is of a good standard, in particular the


assignment of secondary procedure codes.

 The clinical coding staff are not consistently applying the national standards below:

o The correct code to apply for arthrosis with mention of more than one site is
M15 Polyarthrosis1
o The correct code to assign for a diagnostic statement of a ‘PR Bleed’ is K92.2
Gastrointestinal haemorrhage, unspecified not K62.5 Haemorrhage of
anus and rectum2.
o Following the introduction of ICD-10 4th Edition in July 2012 the asterisk code
of a dagger and asterisk set of paired codes can be assigned as the primary
diagnosis code3.

1.3.2 When looked at by specialty the percentage of correct codes are:

Code Type Percent Correct in Percent Correct in Percent Correct in


General Surgery General Medicine Trauma & Orthopaedics
Primary Diagnosis 81.82% 77.14% 76.67%

Secondary Diagnosis 74.63% 78.70% 73.75%


Primary Procedure 87.50% 94.29% 89.66%
Secondary Procedure 94.52% 91.55% 95.00%

1.3.3 The case notes used in the audit were generally of a poor standard. A more
detailed account on the medical records is included in the Wales Audit Office report.
The auditors encountered the following issues:

 The physical case notes are often messy and disorganised, with many temporary
folders and loose documents.

 Documentation of diagnoses within the medical record is very poor. In particular the
lack of clinical statements regarding any type of diagnosis is most problematic
within the Trauma and Orthopaedic specialty. Many of the medical records within
this specialty contain no clear diagnosis of a condition for which the patient is
receiving the treatment they are undergoing. The clinical coder is forced to attempt
to identify a primary diagnosis by interpreting the operation sheet itself.

1
NCCS ICD-10 4th Edition Reference Manual (2013), pg XIII-9
2
NCCS ICD-10 4th Edition Reference Manual (2013), pg XI-14
3
NCCS ICD-10 4th Edition Reference Manual (2013), pg 15 ‘Dagger and asterisk system’

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 Within the Trauma and Orthopaedics specialty the discharge summaries contain no
diagnosis of the condition being treated.

 The ‘Bluespier’ sheets (used for capturing information in relation to operations


within the Trauma and Orthopaedics specialty) already have OPCS-4 codes printed
on them when they are received for coding. These codes are selected by clinical
staff and are frequently incorrect. Each sheet also has a diagnosis printed on it;
however the accuracy of these diagnostic statements is questionable as they often
conflict with the body of the medical record.

 Where typed operation sheets were found in the case notes, they were clear and
easy to follow.

 Histology results can often take some time to be reported and are therefore not
available to clinical coding staff at the time of coding.

1.3.4 The above issues were represented across the entire sample of case notes
examined, and appeared to be representative of the general condition of the case
notes.

1.4 Conclusions

1.4.1 The clinical coding of procedures at Llandough Hospital is generally of a high


standard of accuracy.

1.4.2 The clinical coding staff at Llandough Hospital are up to date with their required
training and generally demonstrate a sound grasp of national clinical coding rules
and standards. However, there are problems with the application of certain specific
national standards (see section 1.3.3 above).

1.4.3 The number of errors of omission identified during the audit points to a lack of in-
depth analysis of the medical record prior to assigning codes. Staff appear to be
rushing and demonstrate a lack of care, particularly regarding the assignment of
secondary diagnoses. Errors of omission have also been caused by the incorrect
assignment of codes recording haemorrhoids as the primary diagnosis when they
were incidental findings, and therefore the condition that should have been
assigned in the primary position has not been recorded.

1.4.4 The failure to utilise available histology results in order to assign the most specific
codes to episodes of care has negatively impacted the accuracy of clinical coding
within the department.

1.4.5 The poor standard of documentation across both electronic and physical patient
records has been the direct cause of a number of coding errors. In addition, it
significantly increases the difficulty of assigning accurate codes to patient episodes
for all clinical coding staff.

1.4.6 The presence of OPCS-4 codes, and the lack of certainty surrounding the accuracy
of these codes (as well as the uncertainty regarding the accuracy of any diagnosis
codes selected by the consultants) on the Bluespier operation sheets causes
problems for clinical coding staff when assigning both OPCS-4 and ICD-10 codes.

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1.4.7 Clinical coding staff are not clarifying issues (whether created by poor
documentation or complex clinical issues) with clinicians on a regular basis.

1.4.8 Currently all queries for research regarding anatomy and other clinical queries must
be submitted via the Clinical Coding Manager; none of the clinical coding staff have
routine access to the internet to undertake such research. This is not regarded as
best practice.

1.4.9 Whilst all Llandough Hospital clinical coding staff are fully up to date with the
necessary level of core clinical coding training, the lack of staff with the ACC
qualification prevents the organisation from being assured that its coding staff are
coding to a recognised national standard and makes it impossible to ascribe a base
line level of expertise to the clinical coders within the department.

1.4.10 The lack of a regular programme of audits of the work of clinical coding staff makes
it impossible for the Clinical Coding Manager to be sure of the level of accuracy of
coding being assigned by the department. Coupled with the lack of a PDR process
for staff it is extremely difficult for the department to measure and improve the
quality of its coded data.

1.4.11 The current structure of the clinical coding department is not supportive of the
provision of high quality clinical coded data. The lack of any band 5 supervisory
positions or audit trained staff within the department as a whole, and no
management staff based at Llandough Hospital; coupled with the lack of an ongoing
programme of regular audits does not allow the clinical coding manager to
sufficiently review the quality of the clinically coded data being created by the
clinical coding staff at Llandough Hospital.

1.5 Recommendations

1.5.1 The Llandough Hospital clinical coding department should endeavour to maintain
the good standard of procedure coding accuracy.

1.5.2 All clinical coding staff should continue to maintain their attendance on required
training sessions. In addition all clinical coding staff should ensure that they are
familiar with all current national standards and that their OPCS-4 and ICD-10 books
are annotated appropriately.

1.5.3 Clinical coding staff at Llandough Hospital must ensure that they take adequate
time with each episode to fully extract relevant data and assign codes using the full
4-step coding process. In addition, local training sessions reinforcing the importance
of accurately capturing all relevant information from the medical record should be
arranged as soon as possible.

1.5.4 The Clinical Coding Manager should remind all clinical coding staff of the
importance of using the full medical record as a source of information for clinical
coding. Histology results in particular often provide detailed diagnostic information
that can be used by the clinical coder to assign an accurate code.

1.5.5 An immediate effort should be made to ensure that staff within Llandough Hospital
who have responsibility for clinical case notes and the wider medical record are
aware of the need for good practice regarding their use. In particular, attention
should be drawn the Royal College of Surgeons ‘Standards for Clinical Records’.
Significant issues with individual case notes should be highlighted using the

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relevant local incident reporting procedures in order to ensure that attention is


drawn to this issue and that possible clinical risks are being highlighted.

1.5.6 It is inappropriate for clinicians without the relevant clinical classifications expertise
and understanding of national (UK and Wales) clinical coding standards to identify
clinical classification codes within operational, clinical IT systems. The Clinical
Coding Manager should liaise with the parties responsible for the creation of the
Bluespier sheets regarding the issues of concern they create for the department.

1.5.7 The Clinical Coding Manager should immediately reinforce to all clinical coding staff
the importance of clarifying any issues caused by a lack of clarity in the
documentation with the responsible consultant, as per national standards.

1.5.8 The Clinical Coding Manager should seek to ensure all members of the clinical
coding department staff are given access to the internet as soon as possible, as a
basic resource for research regarding anatomy and other clinical queries.

1.5.9 All clinical coding staff should be encouraged and supported to gain ACC status as
soon as possible.

1.5.10 The Clinical Coding Manager should implement a programme of regular audits of
clinically coded data created by the department as soon as possible. The results of
these should be fed back to clinical coding staff as necessary, and as part of a
yearly PDR process.

1.5.11 The current departmental management team should immediately investigate the
possibility of re-structuring the department to allow the creation of a minimum of 2
supervisory positions.

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2 Introduction

2.1 The Admitted Patient Care data set (APC ds), and the clinically coded data contained
within, is arguably the single most important source of management information in use
within NHS Wales. The availability of timely, complete, accurate-coded APC data are
an essential pre-requisite for numerous current and emerging decision support
processes.

2.2 Welsh LHBs and Velindre NHS Trust are mandated to clinically code the finished
consultant episodes (FCEs) for every patient admitted to a Welsh NHS hospital.
Organisations are required to accurately code information relating to all diagnoses and
procedures relevant to each individual episode of care experienced by a patient.

2.3 Welsh LHBs and Velindre Trust are currently monitored against two national
performance measures of clinical coding completeness. These are:

 95% of all FCEs are clinically coded within 3 months of the episode end date;

 98% of all FCEs are clinically coded for any given rolling 12 month period.

2.4 There are currently no national performance indicators or measures for clinical coding
accuracy.

2.5 Clinical coded data are used for a variety of uses and it impacts on a number of areas
including:

 Healthcare planning (including service reconfiguration);


 Performance management (notably the production of Tier 1 and other Welsh
Government performance indicators and measures);
 Providing the basis of the Risk Adjusted Mortality Index (RAMI), a current WG priority
area.
 Health needs assessment;
 Evaluation of treatment and outcome analysis;
 Benchmarking;
 Chronic disease management (and the linkage of datasets);
 Provision of information for research;
 The production of official statistics and ad-hoc requests;
 Financial costing and resource utilisation mapping;
 Ad hoc requests (be they Ministerial, AQs, media/public and so on);
 Identification of at risk populations;
 Identification of frequency and occurrence of disease;
 The monitoring of (often high cost) services provided by the Welsh Health Specialised
Services Committee (WHSSC);
 Clinical coding data is central to a range of national information initiatives, such as the
annual financial costing process and patient-level costing
 It is current WG policy for healthcare data to be made more readily available to the
general public, media etc. under its ‘transparency’ agenda. Where clinical coding
information is being shared, this will further raise the importance of that data being
accurate and the need for the Service to be assured that this is the case.

2.6 It is a therefore a requirement that clinical coded data are accurate, consistent,
complete and coded in a timely fashion.

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2.7 Clinical coding audit is currently the only means by which it is possible to assure the
accuracy of clinical coded data.

2.8 As part of its 2013/14 audit programme, the Wales Audit Office (WAO) has decided to
audit the quality of clinical coding services across NHS Wales. This programme work
will see the WAO reviewing the processes, procedures, resources and executive
support associated with Welsh clinical coding service, whilst the NHS Wales
Informatics Service (NWIS) Clinical Classifications Team will oversee an audit of
clinical coding accuracy (i.e. the assignment of ICD-10 and OPCS-4 classifications
codes by Welsh clinical coding staff) across Wales.

2.9 Support from NWIS was requested by WAO, as it is recognised that audits of clinical
coding accuracy requires specific clinical coding expertise that is not present within
WAO.

2.10 This report outlines the findings and recommendations of the NHS Wales Informatics
Service (NWIS) Clinical Classifications Team audit of clinical coding accuracy at
Llandough Hospital. The audit was carried out between the 17th and 21st of February
2014 and was undertaken by two Accredited Clinical Coders from NWIS.

3 Aims

3.1 The aim of this audit was to assess the accuracy of the clinically coded data produced
by Llandough hospital by comparing the codes assigned by the clinical coding
department against national clinical coding standards.

3.2 This report aims to provide a benchmark that can be used by the clinical coding
department within Llandough Hospital and Cardiff and Vale University Local Health
Board, to identify areas for improvement within the organisation and aid in the
identification and planning of future training needs. Conclusions and recommendations
based on areas of both good and poor practice found are provided to achieve this.

3.3 It also aims to evaluate the quality of the source documentation used by the coders
and the local policies and procedures used at Llandough Hospital.

4 Objectives

4.1 The objectives for the audit were:

 To assess the clinical coding data against national clinical coding standards;
 To identify and report areas of good and bad practice;
 To review and assess the accuracy of the source documentation used for clinical
coding;
 To assess the level of clinical involvement with the coding department and to what
degree this impacts on the coding process and coding accuracy;
 To make recommendations designed to support future improve in the accuracy of
clinically coded data within the hospital;
 Highlight training issues within the department.

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5 Background

5.1 Llandough Hospital is one of two hospitals within the Cardiff and Vale ULHB at which
clinical coding staff are based, the other being the University Hospital of Wales (UHW)

5.2 Demographics & Staffing

5.2.1 Cardiff and Vale ULHB generated a total of 153,368 Finished Consultant Episodes
(FCEs) in the 2012/13 financial year. Of these, Llandough Hospital generated
46,263 FCEs.

5.2.2 Clinical coding staff at Llandough Hospital assign codes to episodes that take place
in both acute and community hospital sites within the Health Board.

5.2.3 Cardiff and Vale ULHB achieved 88.2% completeness for clinical coding as of the
submission date at the end of March 2014, and 90.1% completeness for the rolling
12 months to March 2014. This is below the target amounts of 95% and 98%.

5.2.4 The Clinical Coding Department is part of the Information Management and
Technology Directorate. The management team within the department currently
consists of an acting band 6 Clinical Coding Manager based at UHW, with
responsibility for all clinical coders in the ULHB. There is currently a vacant post for
a band 5 Assistant Clinical Coding Manager. The department has 31 clinical coders
– 23 based at UHW and 8 based in Llandough. The table below gives a breakdown
of the whole Time Equivalents (WTE) by site:

Whole Time Equivalents (WTE) by Site


Band Llandough UHW Total
3 1.00 9.31 10.31
4 6.22 11.26 17.48
5 - - -
6 - 1.00 1.00

5.2.5 During the period being audited there was 1 WTE band 5 vacancy within the UHW
coding department.

5.2.6 Coders range in experience in the coding department from 22 years to 1 year and 9
months as coders.

5.2.7 The Llandough Hospital has clinical coders based centrally within 2 adjacent open
plan offices located inside the main hospital building.

5.2.8 During the period of time examined by this audit the coding department had a
backlog of approximately 19,000 FCEs.

5.3 Workloads

5.3.1 Cardiff and Vale ULHB clinical coding staff do not have an expected amount of FCEs
that they are expected to code per day or per year as individuals. Instead, the
department as a whole is expected to code 600 FCEs per day. This is not covered in
the department’s Clinical Coding Policy document, nor is the clinical coding staff
made aware of this target as part of any Personal Development Review (PDR)
process.

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5.3.2 The clinical coding department aims to achieve 100% completeness for a given
month by the 10th working day of the following month.

5.3.3 In order to reduce the outstanding backlog of uncoded episodes within the
department, extensive use was made during the period of the audit of third party
contracted clinical coding staff. These contractors worked only on historical backlog
episodes, with current episodes of coding being undertaken by regular staff within the
department.

5.3.4 In addition to their general clinical coding role, members of the department are also
responsible for changing any errors in the information held on the Patient
Administration System regarding the patient episode that they identify whilst
assigning codes.

5.3.5 The table below shows the amount of FCEs each coder produced in the period 1st of
April to 31st of December 2013, against the expected workload for individual coders
(this has been averaged to 4836 FCEs per year based on the department target of
600 FCEs per day, and then pro-rata reduced to the amount expected in the 9 month
period for which productivity figures were available):

Hours Expected FCE Notes


worked FCE per coded:
per year Apr-Dec
week Apr-Dec 2013
2013
30.0 3627 2448
37.5 3627 4506
28.9 3627 3723
33.0 3627 8927
37.5 3627 3916
28.9 3627 2734
37.5 3627 1999
37.5 3627 3657
Total 29016 31910

5.4 Training

5.4.1 None of the clinical coding staff at Llandough Hospital hold the ACC qualification.

5.4.2 All of the clinical coders meet the minimum training requirements of having
completed the Clinical Coding Foundation Training Course and a Clinical Coding
Refresher Training Course within the last 3 years.

5.4.3 There is currently no NCS approved Clinical Coding trainer or auditor on site. All the
department’s training needs are currently met by D&A Consulting; a commercial
company supplying clinical coding training who provide all training services to NHS
Wales via a national training contract agreed with NWIS.

5.4.4 The department has a detailed induction process for all new staff which is set-out in
the departments Clinical Coding Policy document. The policy document itself has
not been updated since February 2012.

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5.4.5 New staff begin in the department as band 3 Trainee Clinical Coders. After 18
months they are able to sit an internal assessment in order to progress to the role of
a band 4 Clinical Coder. This internal assessment is created and marked by the
clinical coding manager.

5.4.6 All band 4 clinical coders are expected to mentor band 3 trainee clinical coders as
necessary.

5.4.7 As well as assigning classifications codes to inpatient episodes, the Clinical Coding
Department also assigns codes to outpatient activity (approximately 3020 in the
2013 calendar year).

5.4.8 Workloads at Llandough Hospital are divided primarily by means of clinical


specialties, with each member of the clinical coding staff being assigned a specialty
they are responsible for. Due to the case-mix of the hospital and the numbers of
FCEs involved, some specialties require multiple members of the clinical coding
staff assigned to them, whilst other clinical coders may be responsible for several
smaller specialties. There is no rota for alternating staff across specialties, and
many coders do not rotate to different specialties at all. In addition to this, some
staff are also allocated work by other methods as necessary, such as by ward or by
consultant.

5.4.9 Clinical coding staff at Llandough Hospital do not currently undergo any PDR
reviews.

5.5 Assignment of codes

5.5.1 Coding is carried out using the Medicode clinical coding encoder system from 3M.
This interfaces with the Cardiff and Vale UHB Patient Administration System (PAS),
PMS. Medicode is installed individually on the computers of clinical coding staff,
rather than using a central networked incidence of the system, which limits some of
the functionality of the system (such as not being able to centrally amend issues or
make changes which then automatically apply across the Medicode of all clinical
coding staff, or use Medicode's inbuilt coding validation reports to identify basic
errors in assigned codes).

5.5.2 Codes are assigned to episodes using both the ICD-10 4th Edition and OPCS 4.6
classifications.

5.5.3 The main source documentation used at Llandough Hospital is the patient’s
physical case notes. In addition to this, the clinical coding staff have access to
electronic discharge summaries for all three specialties being audited. They also
have access to GP letters, test results and scan results through the clinical portal
system.

5.5.4 Only some of the clinical coding staff within Cardiff and Vale ULHB have access to
the internet, though all have access to the intranet.

5.5.5 Histology results are available to clinical coding staff. However, the time taken by
the pathology department to create the histology report often means that the report
is not available at the time of the coder assigning codes to the episode. In this
circumstance the clinical coding staff are required to keep a record of the patient
details and periodically check if the report is available (though there is no formal

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written process for this). Once it is available, the coder then makes any necessary
amendments to the assigned clinical codes to ensure they are accurate.

5.5.6 The clinical coding department at Llandough Hospital employs a single 0.47 WTE
clinical coding support staff whose role is to retrieve and return case notes for the
clinical coding staff in order to maximise the amount of time they can spend
assigning codes. In addition they also identify and locate missing uncoded episodes
for the department. Due to the volume of patient episodes however, some clinical
coding staff are still required to collect and return case notes.

5.5.7 The retrieval and coding of deceased patient records is prioritised within the
department, followed by the retrieval and coding of the Trauma & Orthopaedic and
Cardiothoracic specialties.

5.5.8 They do not make use of Read Codes, Clinical Terms or SNOMED-CT.

5.6 Previous Audits and Recommendations

5.6.1 The last external audit was carried out in 2008 by the National Leadership and
Innovation Agency for Healthcare (NLIAH). Although a draft report was created, no
formal report of the audit was ever presented to the ULHB.

5.6.2 There is no process of regular audits in place at Llandough Hospital although


coding checks are conducted in an ad hoc fashion as required. Results from these
are fed back to the individual clinical coding staff involved, and any issues identified
are e-mailed to all members of the clinical coding staff.

5.6.3 The Clinical Coding Manager does not regularly run any validation reports to
identify basic errors in the coded data (see 5.5.1).

5.6.4 A number of clinicians are involved in the validation of their clinically coded data.

6 Methodology

6.1 A pre-audit questionnaire regarding details of the organisation of clinical coding


services in the LHB was completed by the Clinical Coding Manager.

6.2 A list of 270 FCEs, drawn from three specialties, was randomly generated from the
Patient Episode Database for Wales (PEDW) – the national database of APC ds
activity data. PEDW is managed and maintained by NWIS.

6.3 The planned number of episodes audited was 30 from each of the 3 specialties below:

 General Medicine
 General Surgery
 Trauma and Orthopaedic.

6.4 The episodes audited were limited to those with an episode end date of 1st may 2013
– 31st August 2013 inclusive. Episodes were also limited to being no longer than 10
days in length.

6.5 Staff at Llandough Hospital were required to provide the auditors with access to the
written case note records associated with the requested FCEs.

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6.6 The clinical coding record for each episode was generated from Medicode and a copy
attached to the relevant set of case notes.

6.7 The auditors then assessed the locally coded data against the National Clinical Coding
Standards (see Appendix 1) and the Welsh Clinical Coding Standards (see Appendix
2) using ICD-10 and OPCS 4.6 classifications.

6.8 Codes were audited as one of 4 types:

 Primary Diagnosis codes (i.e. the main condition treated);


 Secondary Diagnosis codes (including External Cause Codes and Morphology
Codes);
 Primary Procedure codes;
 Secondary Procedure codes (including Chapter Z site codes).

6.9 Any errors were assigned to an Error Type (see Appendix 3), which specified the exact
nature of the error. This information was then tabulated to calculate the statistical
information required (see Appendix 2)

6.10 The errors are of two general types – non-coder errors and coder errors. Non-coder
errors are those errors identified as being due to a factor external to the individual
coder, such as an encoder system which automatically re-sequences codes, or a local
coding policy which instructs the coder to assign codes in a way which contravenes
national standards. Coder errors are errors in the coding made by the coder
themselves.

6.11 For statistical reasons and due to the judgemental nature of a code being ‘relevant’ to
an episode, those error types where coding staff have assigned more codes than the
auditor deems relevant (i.e. ‘overcoding’) are not counted as errors when calculating
the error percentages. However, the numbers of these errors are reported and
examples given for information and training purposes.

6.12 An analysis of the errors is given in Appendix 1.

6.13 The recommended minimum percentage of correct codes are:

 90% for Primary Diagnosis and Primary Procedure


 80% for Secondary Diagnosis and Secondary Procedures

The Accredited Clinical Coding (ACC) exam also stipulates a minimum requirement of
90% accuracy for all clinical coding staff sitting the National Clinical Coding
Qualification (NCCQ) exam. Furthermore, the above targets are consistent with the
requirements set out in the NHS England Information Governance Toolkit requirement
505 (attainment level 2) and audits of coded data carried out by NCS auditors on
English Coders.

6.14 Case notes which did not contain the episode to be audited were marked as ‘Unsafe
To Audit’ (UTA) and removed from the sample and replaced.

6.15 A total of 98 episodes were examined.

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7 Findings

7.1 The percentages of correctly assigned codes are given below:

Code Type Total Number of Total Number of Percentage Correct


Codes correct codes
Primary Diagnosis 98 77 78.57%

Secondary Diagnosis 255 194 76.08%


Primary Procedure 96 87 90.63%
Secondary Procedure 264 248 93.94%

The percentage of codes that were correct was below the recommended level in both
primary and secondary diagnosis coding. However, the percentage was above the
recommended level in both primary and secondary procedure coding.

7.2 When looked at by specialty, the percentage of correct codes is:

Code Type Percent Correct in Percent Correct in Percent Correct in


General Surgery General Medicine Trauma & Orthopaedics
Primary Diagnosis 81.82% 77.14% 76.67%

Secondary Diagnosis 74.63% 78.70% 73.75%


Primary Procedure 87.50% 94.29% 89.66%
Secondary Procedure 94.52% 91.55% 95.00%

It should be noted that of the 98 episodes examined 44 (44.90%) contained no errors


in any position. A breakdown of the error types assigned is given below at section 7.4
onwards.

7.3 In addition to the percentages given above a number of specific findings were made by
the auditors:

 The most prevalent type of errors uncovered during the audit are errors of omission.
Errors due to codes being omitted account for 63.55% of all errors encountered during
the audit (68 out of 103 errors), and in the case of Secondary Diagnosis errors account
for 81.97% of all errors in that area (50 out of 61 errors).

 Clinical coding staff do not appear to be consulting histology reports when assigning
codes to an episode. Out of 21 primary diagnosis errors 5 (23.81%) were due to
clinical coding staff not assigning a more specific code that was available from
information contained within histology results that they had access to at the time of
coding the episode.

 The clinical coding staff are consistently incorrectly assigning codes for haemorrhoids
in the primary diagnosis position when they are an incidental finding or secondary
diagnosis. This was the underlying reason for 7 of the 21 (33.33%) primary diagnosis
errors.

 The coding of procedures by the department is of a good standard, in particular the


assignment of secondary procedure codes.

 The clinical coding staff are not consistently applying the national standards below:

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o The correct code to apply for arthrosis with mention of more than one site is
M15 Polyarthrosis4
o The correct code to assign for a diagnostic statement of a ‘PR Bleed’ is K92.2
Gastrointestinal haemorrhage, unspecified not K62.5 Haemorrhage of
anus and rectum5.
o Following the introduction of ICD-10 4th edition in July 2012 the asterisk code
of a dagger and asterisk set of paired codes can be assigned as the primary
diagnosis code6.

7.4 Unsafe to Audit (UTA)

There was one episode which was marked as UTA (1.01% of the total number of sets
of case notes looked at). As per the methodology described above, they were removed
from the audit and replaced.

Example:
There was no information in the medical notes pertaining to the episode to be audited.

7.5 Primary Diagnosis Codes

The primary diagnosis was correct in 78.57% of the episodes audited (77 of the 98
primary diagnoses).

These were broken by specialty as follows:-

 General Surgery primary diagnosis correct - 81.82 % (27 out of the total of 33)
 General Medicine primary diagnosis correct - 77.14% (27 out of the total of 35)
 Trauma and Orthopaedic primary diagnosis correct - 76.67% (23 out of the total of 30)

A breakdown of the errors in primary diagnoses by their associated error types is given
below (see Appendix 3 for a detailed explanation of the error keys):

Error Type Number of Errors Percentage of FCEs with Error


PD3 7 7.14%
PD4 2 2.04%
PDIS 3 3.06%
PDO 7 7.14%
PDD 1 1.02%
PDI 1 1.02%

7.5.1 Primary Diagnosis Incorrect at Third Character Level (PD3)

There were seven primary diagnosis errors incorrect at third character level (7.14%).
Example:
ULHB Coding Auditor Coding
Z03.8 Observation for other suspected Z08.0 Follow up examination after surgery for
diseases and conditions malignant neoplasm
Z85.0 Personal history of malignant neoplasm of
digestive organs

4
NCCS ICD-10 4th Edition Reference Manual (2013), pg XIII-9
5
NCCS ICD-10 4th Edition Reference Manual (2013), pg XI-14
6
NCCS ICD-10 4th Edition Reference Manual (2013), pg 15 ‘Dagger and asterisk system’

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The information in this patient’s medical notes stated that they were attending for
follow up examination after previous surgery for a malignant neoplasm. The code
assigned by the clinical coder is therefore incorrect as it does not record this.

7.5.2 Primary Diagnosis Incorrect at Fourth Character Level (PD4)

There were two primary diagnosis errors incorrect at fourth character level (2.04%).

Example:
ULHB Coding Auditor Coding
K80.2 Calculus of gallbladder without K80.1 Calculus of gallbladder with other
cholecystitis cholecystitis

The information in the medical record for this episode of care stated that the patient
had calculus of the gallbladder with chronic cholecystitis. The clinical coder has
chosen the wrong code from the tabular list to assign7.

7.5.3 Primary Diagnosis Incorrectly Sequenced (PDIS)

There were three primary diagnosis errors which were incorrectly sequenced (3.06%).

Example:
ULHB Coding Auditor Coding
M51.1† Lumber and other intervertebral disc G55.1* Nerve root and plexus compression in
disorders with radiculopathy intervertebral disc disorders
G55.1* Nerve root and plexus compression in M51.1† Lumber and other intervertebral disc
intervertebral disc disorders disorders with radiculopathy
Z88.0 Personal history of allergy to penicillin Z51.2 Other chemotherapy
Z88.0 Personal history of allergy to penicillin

The information in this episode of care showed that it was the nerve root compression
that was being treated. Therefore it is appropriate to assign the asterisk code for nerve
root compression in the primary position, as per the standard introduced in ICD-10 4th
Edition8.

7.5.4 Primary Diagnosis Omitted (PDO)

There were seven primary diagnosis omission errors (7.14%).

Example:
ULHB Coding Auditor Coding
I84.9 Unspecified haemorrhoids without R19.4 Change in bowel habit
complication
K57.3 Diverticular disease of large intestine Z80.0 Family history of malignant neoplasm of
without perforation or abscess digestive organs
Z80.0 Family history of malignant neoplasm I84.9 Unspecified haemorrhoids without
of digestive organs complication
K57.3 Diverticular disease of large intestine
without perforation or abscess

7
NCCS ICD-10 4th Edition Reference Manual (2013), pg 5 ‘Individual codes’
8
NCCS ICD-10 4th Edition Reference Manual (2013), pg 15 ‘Dagger and asterisk system’

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The clinical information in this episode of care stated that the patient was being
admitted for investigations due to a change in bowel habit and a family history of bowel
cancer. The haemorrhoids were an incidental finding of the colonoscopy9.

7.5.5 Information available at the time of audit not available at the time of coding (PDI)

There was one primary diagnosis errors due to information being available to the
auditors that was not available at the time of coding (1.02%).

Example:
ULHB Coding Auditor Coding
R22.4 Localised swelling, mass and lump, D17.2 Benign lipomatous neoplasm of skin and
lower limb subcutaneous tissue of limbs
M8850/0 Lipoma NOS

The clinical information in this episode of care stated that the patient had a lump on
their calf, but during the episode the lump was excised and a diagnosis of a lipoma
was made on the histopathology report. The clinical coder has not checked the
histology result when it became available in order to amend the assigned codes to
reflect the correct diagnosis10.

7.5.6 Primary Diagnosis Documentation Issue (PDD)

There was one primary diagnosis error due to documentation issues (1.02%).

Example:
ULHB Coding Auditor Coding
M89.35 Hypertrophy of bone pelvic region M24.85 Other specified joint derangements, not
and thigh elsewhere classified pelvic region and thigh
M76.15 Psoas tendinitis, pelvic region and M89.35 Hypertrophy of bone Pelvic region and
thigh thigh
J45.9 Asthma, unspecified M76.15 Psoas tendinitis, pelvic region and thigh
F17.1 Mental and behavioural disorders due J45.9 Asthma, unspecified
to use of tobacco
Z88.0 Personal history of allergy to penicillin F17.1 Mental and behavioural disorders due to
use of tobacco
Z88.6 Personal history of allergy to analgesic Z88.0 Personal history of allergy to penicillin
agent
Z88.6 Personal history of allergy to analgesic
agent

The information in this patient’s medical notes made it was extremely difficult to
ascertain the primary diagnosis due to lack of accurate documentation. The primary
diagnosis was not overtly stated within the medical record, and the Bluespier operation
sheet was organised by anatomical area of the hip, relating separately the parts of the
procedure performed on each area. This made identifying the procedure and reason
for it particularly difficult. As the patient was referred to as having a ‘Snapping Hip’, and
it was this that was mainly treated by the procedure undertaken, the primary diagnosis
code assigned by the auditor is to record this condition.

9
NCCS ICD-10 4th Edition Reference Manual (2013), pg 9 ‘Primary Diagnosis’
10
NCCS ICD-10 4th Edition Reference Manual (2013), pg 9 ‘Specificity’

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7.6 Secondary Diagnosis Codes Including External Cause and Morphology Codes

The secondary diagnoses codes were 76.08% correct (194 out of the total 255
secondary diagnoses).

These were broken down by specialty as follows:

 General Surgery secondary diagnosis correct – 74.63% (50 out of the total of 67)
 General Medicine secondary diagnosis correct – 78.70% (85 out of the total of 108)
 Trauma and Orthopaedic secondary diagnosis correct – 73.75% (59 out of the total of
80)

A breakdown of the errors by their associated error types is given below (see
Appendix 3 for detailed explanation of error keys):

Error Key Number of Errors Percentage of Secondary Diag


with Error
SD3 3 1.18%
SD4 5 1.96%
SDO 47 18.43%
SDNR 7 -
MCI 3 1.18%
MCO 3 1.18%

7.6.1 Secondary Diagnosis Incorrect at Third Character Level (SD3)

There were three secondary diagnoses incorrect at third character level (1.18%).

Example:
ULHB Coding Auditor Coding
D37.4 Neoplasm of uncertain or unknown D37.4 Neoplasm of uncertain or unknown
behaviour of oral cavity and digestive organs behaviour of oral cavity and digestive organs
M8261/1 Villous adenoma NOS M8261/1 Villous adenoma NOS
K62.5 Haemorrhage of anus and rectum K92.2 Gastrointestinal haemorrhage, unspecified

The information in this patient’s notes stated that they had haematochezia which is
bleeding per rectum (PR) not a haemorrhage of the rectum itself11.

7.6.2 Secondary Diagnosis Incorrect at Fourth Character Level (SD4)

There were five secondary diagnoses incorrect at fourth character level (1.96%).

11
NCCS ICD-10 4th Edition Reference Manual (2013), pg XI-14

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Example:
ULHB Coding Auditor Coding
K80.2 Calculus of gallbladder without K80.2 Calculus of gallbladder without
cholecystitis cholecystitis
K83.4 Spasm of sphincter of oddi K82.4 Cholesterolosis of gallbladder

The information in this patient’s notes stated that they were suffering from
Cholesterolosis of the gallbladder not a spasm of the sphincter of oddi. Therefore the
correct code to assign would be K82.4.

7.6.3 Secondary Diagnosis Not Relevant (SDNR)

There were seven secondary diagnoses assigned which were not relevant.

Example:
ULHB Coding Auditor Coding
K56.2 Volvulus K56.2 Volvulus
T88.4 Failed or difficult intubation Z88.8 Personal history of allergy to other drugs,
medicaments and biological substances

There was no indication of failed or difficult intubation in the medical record for this
episode of care. The information in the record stated that there was difficulty
introducing the colonoscope during the procedure undertaken, however the scope is
not a tube and it is not therefore appropriate to use the code T88.4.

7.6.4 Secondary Diagnosis Omitted (SDO)

There were forty seven secondary diagnoses omitted (18.43%).

Example:
ULHB Coding Auditor Coding
M51.1† Lumber and other intervertebral disc G55.1* Nerve root and plexus compressions in
disorders with radiculopathy intervertebral disc disorders (M50-M51 dagger)
G55.1* Nerve root and plexus compressions M51.1† Lumber and other intervertebral disc
in intervertebral disc disorders (M50-M51 disorders with radiculopathy
dagger)
Z88.0 Personal history of allergy to penicillin Z51.2 Other chemotherapy
Z88.0 Personal history of allergy to penicillin

The information in this episode of care stated that the patient was being admitted for a
sacral epidural injection it is therefore required to assign the code Z51.2 in a
secondary position12.

12
NCCS ICD-10 4th Edition Reference Manual (2013), pg XXI-16

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7.6.5 Morphology Code Incorrect (MCI)

There were three incorrect morphology codes assigned (1.18%).

Example:
ULHB Coding Auditor Coding
D12.5 Benign neoplasm of colon, rectum, D12.5 Benign neoplasm of colon, rectum, anus
anus and anal canal Sigmoid colon and anal canal Sigmoid colon
M8140/0 Adenoma NOS M8210/0 Adenomatous polyp
D12.8 Benign neoplasm of colon, rectum, D12.8 Benign neoplasm of colon, rectum, anus
anus and anal canal and anal canal
M8140/0 Adenoma NOS M8210/0 Adenomatous polyp

The clinical information in the medical record for this episode of care stated that the
lesions were adenomatous polyps; however the clinical coder has assigned a code for
an adenoma of a type ‘Not Otherwise Stated’.

7.6.6 Morphology Code Omitted (MCO)

There were three morphology codes omitted (1.18%).

Example:
ULHB Coding Auditor Coding
R22.4 Localised swelling, mass and lump, D17.2 Benign lipomatous neoplasm of skin and
lower limb subcutaneous tissue of limbs
M8850/0 Lipoma NOS

The clinical information in this episode of care stated that the patient had a lump on
their calf, but during the episode the lump was excised and a diagnosis of lipoma was
made on the subsequent histopathology report. The clinical coder has not checked the
histology result when it became available in order to amend the assigned codes to
reflect the correct diagnosis13.

7.7 Primary Procedure Codes

There were 96 primary procedure codes assigned.

The primary procedure was correct in 90.63% of the episodes audited (87 of the 96
primary procedures).

These were broken down by specialty as follows:

 General Surgery primary procedures correct – 87.50% (28 out of the total of 32)
 General Medicine primary procedures correct – 94.29% (33 out of the total of 35)
 Trauma and Orthopaedic primary procedures correct – 89.66% (26 out of the total of
29)

A breakdown of the errors by their associated error types are shown below (see
Appendix 3 for detailed explanation of the error keys):

13
Welsh Standard: Icd-10 Classification Neoplasm Morphology Coding -
http://nww.classificationstandards.wales.nhs.uk/

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Error Key Number of Errors Percentage of Primary


Procedures with Error
PP3 2 2.08%
PP4 4 4.17%
PPO 2 2.08%
PPD 1 1.04%

7.7.1 Primary Procedure Incorrect at Third Character Level (PP3)

There were two primary procedure codes incorrect at third character level (2.08%).

Example:
ULHB Coding Auditor Coding
W20.1 Primary open reduction of fracture of W23.1 Secondary open reduction of fracture of
long bone and extramedullary fixation using bone and intramedullary fixation HFQ
plate NEC
W31.4 Cancellous chip autograft of bone Y66.3 Harvest of bone from iliac crest
W31.9 Other autograft of bone unspecified Z71.8 Specified ulna NEC
Z71.8 Specified ulna NEC Z94.2 Right sided operation
Z94.2 Right sided operation Y80.4 Intravenous anaesthetic NEC
Y66.3 Harvest of bone from iliac crest
Z94.2 Right sided operation
Y71.3 Revisional operations NOC
Y80.4 Intravenous anaesthetic NEC

The information in the medical record for this episode of care stated that this was
revisional / secondary reduction of the fracture and intramedullary fixation together
with a bone graft. Secondary open reductions of fractures are assigned codes from
W23. The codes W23.1 and W23.2 have the abbreviation HFQ (However Further
Qualified) in the descriptor, meaning that no additional detail in the operation
documentation will require code assignment. Due to this the code for a graft of bone to
the ulna is not required in addition14.

7.7.2 Primary Procedure Incorrect at Fourth Character Level (PP4)

There were four primary procedure codes incorrect at fourth character level (4.17%).

Example:
LHB Coding Auditor Coding
H22.9 Diagnostic endoscopic examination of H22.1 Diagnostic fibreoptic examination of colon
colon unspecified and biopsy of lesion of colon
Y84.8 Other anaesthetic, other specified Z28.2 Caecum

The clinical information in this episode of care stated that the patient had a biopsy of
the caecum in addition to the examination. The clinical coder has not assigned the
correct 4th character to record this.

14
Clinical Coding Instruction Manual OPCS-4.6, pg 30

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7.7.3 Primary Procedure Omitted (PPO)

There were two primary procedures omitted (2.08%).

Example:
ULHB Coding Auditor Coding
H51.3 Stapled haemorrhoidectomy P23.7 Posterior colporrhaphy with mesh
reinforcement
Y84.2 Sedation NEC H51.3 Stapled haemorrhoidectomy
Y84.2 Sedation NEC

The information in this episode of care stated that the patient had both a rectocele and
haemorrhoids so a repair of the rectocele was carried out as well as the
haemorrhoidectomy. The repair of the rectocele is a more significant procedure than
the haemorrhoidectomy; therefore it should be assigned as the primary procedure.
7.7.4 Primary Procedure Documentation Issue (PPD)

There was one primary procedure code error due to documentation issues (1.04%).

Example:
ULHB Coding Auditor Coding
W89.1 Endoscopic chondroplasty T83.2 Division of muscle
Z90.2 Hip NEC Z57.8 Specified muscle of hip or thigh
W83.3 Endoscopic shaving of auricular W89.11 Endoscopic chondroplasty
cartilage
Z90.2 Hip NEC Z84.3 Hip joint
Z94.2 Right sided operation W08.5 Partial excision of bone
Y80.3 Inhalation anaesthetic NEC Z76.9 Femur NEC
W83.8 Therapeutic endoscopic operations on
other articular cartilage
Y05.5 Debridement of organ NOC
Z84.3 Hip joint
Z94.2 Right sided operation
Y80.3 Inhalation anaesthetic NEC

The Bluespier operation sheet for this episode was organised by anatomical area of
the hip, relating separately the parts of the procedure performed on each area. This
made identifying the overall procedure and reason for it particularly difficult. As the
patient was referred to as having a ‘Snapping Hip’, and it was this that was mainly
treated by the procedure undertaken, the primary diagnosis code assigned by the
auditor is to record this condition. Therefore the code assigned as the primary
procedure by the auditor was the one which represented the treatment of the
‘Snapping Hip’ – in this case the division of the patient’s muscle.

7.8 Secondary Procedure Codes

There were 264 secondary procedures codes assigned.

These secondary procedure codes were 93.94% correct (248 out of the 264 secondary
procedures).

They were broken down by specialty as follows:

 General Surgery secondary procedure correct – 94.52% (69 out of the total of 73)

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 General Medicine secondary procedure correct – 91.55% (65 out of the total of 71)
 Trauma and Orthopaedic secondary procedure correct – 95.00% (114 out of the total
of 120)

A breakdown of the errors by their associated error types are shown below (see
Appendix 3 for detailed explanation of error keys):

Error Key Number of Errors Percentage of Secondary


Procedures with Error
SP3 2 0.76%
SP4 5 1.89%
SPO 9 3.41%
SPNR 8 -

7.8.1 Secondary Procedure Incorrect at Third Character Level (SP3)

There were two secondary procedure codes incorrect at third character level (0.76%).

Example:
ULHB Coding Auditor Coding
H22.1 Diagnostic fibreoptic examination of H22.1 Diagnostic fibreoptic examination of colon
colon and biopsy of lesion of colon and biopsy of lesion of colon
Z27.6 Ileum Z28.2 Caecum

The furthest point reached on the examination of the colon was the terminal ileum but
since a biopsy of the caecum was also carried out the correct code assignment should
be for the site of the biopsy as this takes precedence over the site reached by the
endoscope15.

7.8.2 Secondary Procedure Incorrect at Fourth Character Level (SP4)

There were five secondary procedure codes incorrect at fourth character level (1.89%).

Example:
ULHB Coding Auditor Coding
H22.1 Diagnostic fibreoptic examination of H22.1 Diagnostic fibreoptic examination of
colon and biopsy of lesion of colon colon and biopsy of lesion of colon
Z28.5 Descending colon Z28.5 Descending colon
Y84.2 Sedation NEC Y84.2 Sedation NEC
G45.9 Diagnostic fibreoptic examination of G45.1 Diagnostic fibreoptic examination of
upper gastrointestinal tract, unspecified upper gastrointestinal tract and biopsy of
lesion of upper gastrointestinal tract
Z27.4 Duodenum Z27.4 Duodenum
Y82.3 Application of local anaesthetic NEC Y82.3 Application of local anaesthetic NEC

The clinical information in this episode of care states that during the diagnostic
fibreoptic examination of the upper gastrointestinal tract a biopsy of the duodenum was
also carried out. The clinical coder has not assigned the correct 4th character code to
record this.

15
Clinical Coding Instruction Manual OPCS-4.6, pg H-4

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7.8.3 Secondary Procedure Omitted (SPO)

There were nine secondary procedures omitted (3.41%).

Example:
ULHB Coding Auditor Coding
H51.3 Stapled haemorrhoidectomy H51.3 Stapled haemorrhoidectomy
Y80.3 Inhalation anaesthetic NEC H48.1 Excision of polyp of anus
Y84.2 Sedation NEC Y80.3 Inhalation anaesthetic NEC
Y84.2 Sedation NEC

The patient’s medical record for this episode of care stated that as well as the stapled
haemorrhoidectomy an excision of an anal polyp was also carried out.

7.8.4 Secondary Procedure Not Relevant (SPNR)

There were eight secondary procedure codes assigned which were not relevant.

Example:
ULHB Coding Auditor Coding
T20.2 Primary repair of inguinal hernia using T20.2 Primary repair of inguinal hernia using
inset of prosthetic material inset of prosthetic material
Y75.8 Minimal access to abdominal cavity Y75.5 Laparoscopic ultrasonic approach to
Other specified abdominal cavity
Z94.2 Right sided operation Z94.2 Right sided operation
Y80.1 Inhalation anaesthetic using muscle Y80.1 Inhalation anaesthetic using muscle
relaxant relaxant
Y75.8 Minimal access to abdominal cavity
Other specified
Y80.4 Intravenous anaesthetic NEC

The code for minimal access to abdominal cavity (Y75.-) was coded in the first
secondary position to the open code with which it is associated which is correct,
however it was also assigned again further down in the code sequence which is not
required. The duplicate code was removed as not relevant, as was a duplicate
anaesthetic code which had also been assigned.

7.9 Case Note Findings

7.9.1 The case notes used in the audit were generally of a poor standard. A more detailed
account on the medical records is included in the Wales Audit Office report. The
auditors encountered the following issues:

 The physical case notes are often messy and disorganised, with many temporary
folders and loose documents.

 Documentation of diagnoses within the medical record is very poor. In particular the
lack of clinical statements regarding any type of diagnosis is most problematic
within the Trauma and Orthopaedic specialty. Many of the medical records within
this specialty contain no clear diagnosis of a condition for which the patient is
receiving the treatment they are undergoing. The clinical coder is forced to attempt
to identify a primary diagnosis by interpreting the operation sheet itself.

 Within the Trauma and Orthopaedics specialty the discharge summaries contain no
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diagnosis of the condition being treated.

 The ‘Bluespier’ sheets (used for capturing information in relation to operations


within the Trauma and Orthopaedics specialty) already have OPCS-4 codes printed
on them when they are received for coding. These codes are selected by clinical
staff and are frequently incorrect. Each sheet also has a diagnosis printed on it;
however the accuracy of these diagnostic statements is questionable as they often
conflict with the body of the medical record.

 Where typed operation sheets were found in the case notes, they were clear and
easy to follow.

 Histology results can often take some time to be reported and are therefore not
available to clinical coding staff at the time of coding.

7.9.2 The above issues were represented across the entire sample of case notes
examined, and appeared to be representative of the general condition of the case
notes.

8 Conclusions

8.1 The clinical coding record for each episode was generated from Medicode and a
copy attached to the relevant set of case notes.

8.2 The clinical coding staff at Llandough Hospital are up to date with their required
training and generally demonstrate a sound grasp of national clinical coding rules
and standards. However, there are problems with the application of certain specific
national standards (see section 1.3.3 above).

8.3 The number of errors of omission identified during the audit points to a lack of in-
depth analysis of the medical record prior to assigning codes. Staff appear to be
rushing and demonstrate a lack of care, particularly regarding the assignment of
secondary diagnoses. Errors of omission have also been caused by the incorrect
assignment of codes recording haemorrhoids as the primary diagnosis when they
were incidental findings, and therefore the condition that should have been assigned
in the primary position has not been recorded.

8.4 The failure to utilise available histology results in order to assign the most specific
codes to episodes of care has negatively impacted the accuracy of clinical coding
within the department.

8.5 The poor standard of documentation across both electronic and physical patient
records has been the direct cause of a number of coding errors. In addition, it
significantly increases the difficulty of assigning accurate codes to patient episodes
for all clinical coding staff.

8.6 The presence of OPCS-4 codes, and the lack of certainty surrounding the accuracy
of these codes (as well as the uncertainty regarding the accuracy of any diagnosis
codes selected by the consultants) on the Bluespier operation sheets causes
problems for clinical coding staff when assigning both OPCS-4 and ICD-10 codes.

8.7 Clinical coding staff are not clarifying issues (whether created by poor documentation
or complex clinical issues) with clinicians on a regular basis.

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8.8 Currently all queries for research regarding anatomy and other clinical queries must
be submitted via the Clinical Coding Manager; none of the clinical coding staff have
routine access to the internet to undertake such research. This is not regarded as
best practice.

8.9 Whilst all Llandough Hospital clinical coding staff are fully up to date with the
necessary level of core clinical coding training, the lack of staff with the ACC
qualification prevents the organisation from being assured that its coding staff are
coding to a recognised national standard and makes it impossible to ascribe a base
line level of expertise to the clinical coders within the department.

8.10 The lack of a regular programme of audits of the work of clinical coding staff makes it
impossible for the Clinical Coding Manager to be sure of the level of accuracy of
coding being assigned by the department. Coupled with the lack of a PDR process
for staff it is extremely difficult for the department to measure and improve the quality
of its coded data.

8.11 The current structure of the clinical coding department is not supportive of the
provision of high quality clinical coded data. The lack of any band 5 supervisory
positions or audit trained staff within the department as a whole, and no management
staff based at Llandough Hospital; coupled with the lack of an ongoing programme of
regular audits does not allow the clinical coding manager to sufficiently review the
quality of the clinically coded data being created by the clinical coding staff at
Llandough Hospital.

9 Recommendations

9.1 The Llandough Hospital clinical coding department should endeavour to maintain the
good standard of procedure coding accuracy.

9.2 All clinical coding staff should continue to maintain their attendance on required
training sessions. In addition all clinical coding staff should ensure that they are
familiar with all current national standards and that their OPCS-4 and ICD-10 books
are annotated appropriately.

9.3 Clinical coding staff at Llandough Hospital must ensure that they take adequate time
with each episode to fully extract relevant data and assign codes using the full 4-step
coding process. In addition, local training sessions reinforcing the importance of
accurately capturing all relevant information from the medical record should be
arranged as soon as possible.

9.4 The Clinical Coding Manager should remind all clinical coding staff of the importance
of using the full medical record as a source of information for clinical coding.
Histology results in particular often provide detailed diagnostic information that can
be used by the clinical coder to assign an accurate code.

9.5 An immediate effort should be made to ensure that staff within Llandough Hospital
who have responsibility for clinical case notes and the wider medical record are
aware of the need for good practice regarding their use. In particular, attention should
be drawn the Royal College of Surgeons ‘Standards for Clinical Records’. Significant
issues with individual case notes should be highlighted using the relevant local

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incident reporting procedures in order to ensure that attention is drawn to this issue
and that possible clinical risks are being highlighted.

9.6 It is inappropriate for clinicians without the relevant clinical classifications expertise
and understanding of national (UK and Wales) clinical coding standards to identify
clinical classification codes within operational, clinical IT systems. The Clinical
Coding Manager should liaise with the parties responsible for the creation of the
Bluespier sheets regarding the issues of concern they create for the department.

9.7 The Clinical Coding Manager should immediately reinforce to all clinical coding staff
the importance of clarifying any issues caused by a lack of clarity in the
documentation with the responsible consultant, as per national standards.

9.8 The Clinical Coding Manager should seek to ensure all members of the clinical
coding department staff are given access to the internet as soon as possible, as a
basic resource for research regarding anatomy and other clinical queries.

9.9 All clinical coding staff should be encouraged and supported to gain ACC status as
soon as possible.

9.10 The Clinical Coding Manager should implement a programme of regular audits of
clinically coded data created by the department as soon as possible. The results of
these should be fed back to clinical coding staff as necessary, and as part of a yearly
PDR process.

9.11 The current departmental management team should immediately investigate the
possibility of re-structuring the department to allow the creation of a minimum of 2
supervisory positions.

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Appendix 1: National Standards for Clinical Coding

Information on Clinical Coding Standards

When clinically coding healthcare activity, it is vital that coders adhere to national standards
so as to ensure that clinically coded data is comparable across Wales (and beyond) and is of
the highest quality.

The two classifications used to record clinical coding data in Wales are:

 International Statistical classification of Diseases and related Health Problems 10th


Revision (ICD-10) – Currently on its 4th Edition, this classification is used to record
Diagnoses and morbid conditions affecting a patient during a hospital stay.

 Office of Population, Census and Surveys Classification of Interventions and


Procedures version 4.6 (OPCS-4.6) – This classification is used to record
interventions and procedures used in the treatment of patient during a hospital stay.

At an international level, the overarching principles and standards associated with the coding
of diagnostic information (ICD-10) are determined by the World Health Organisation (WHO).
At a UK level, interpretation and any amendments to these standards is overseen by the
NHS Classifications Service (NCS) as part of the Health & Social Care Information Centre
(HSCIC) within NHS England. NCS are also responsible for maintain and developing the
standards associated with the coding of procedures (OPCS-4).

In their national role, NCS develop and maintain a range of standards, reference, instruction
manuals and training materials for clinical coders in relation to the ICD-10 and OPCS-4
classifications.

The principal documents containing the national standards for Welsh coders are:

 The National Clinical Coding Standards ICD-10 4th Edition Reference Manual;
 ICD-10 Volumes I to III;
 The Clinical Coding Instruction Manual OPCS-4.6;
 OPCS-4.6 Volumes I and II;
 The Coding Clinic;
 The Welsh Standards;
 NHS Wales Clinical Coding Change Notifications (CCCNs).

In addition to formal standards and change notices, the NHS Wales Informatics Service
Clinical Classifications Team also provide Welsh coders with a range of additional
documentation that are intended to be sources of guidance and clarification, but do NOT
constitute national standards:

 NHS Wales Clinical Coding Communications (CCCs);


 The NHS Wales Clinical Coding Helpline;
 The NCS Data Standards Helpline;

Welsh Clinical Coding Standards:

As described above, Welsh clinical coders follow the UK national standards for clinical
coding. However, there are a small number of differences in the clinical coding standards

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applied in Wales, which are designed to reflect the differences in business requirements for
clinically coded data between NHS Wales and the rest of the UK.

These Wales-specific standards are known as the Welsh Clinical Coding Standards, which
are introduced and updated via Clinical Coding Change Notices (CCNs). CCCNs were
introduced in 2009 and are used to communicate a new or changed Welsh standard to the
Service. They are approved by the Welsh Information Standards Board (WISB) and
published by the NWIS Clinical Classifications Team.

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Appendix 2: Analysis of Errors

Analysis of Errors: Overall


Number %
Total number of episodes examined 99

UTA Unsafe to audit 1

Actual number of episodes examined 98

Primary Diagnosis

Number of primary diagnoses correct 77 78.57%

Non Coder Error

PDI Information not available at time of coding 1 1.02%


PDD Primary Diagnosis Documentation issue 1 1.02%
PDM Primary diagnosis coded to Management Specification 0.00%
PDC Primary diagnosis coded to Clinician Specification 0.00%
PDSC Primary Diagnosis coded due to System Constraint 0.00%

Coder Error

PD3 Primary Diagnosis Incorrect - 3-character level 7 7.14%


PD4 Primary Diagnosis Incorrect - 4-character level 2 2.04%
PD5 Primary Diagnosis Incorrect - 5-character level 0 0.00%
PDIS Primary Diagnosis Incorrectly Sequenced 3 3.06%
PDO Primary Diagnosis Omitted 7 7.14%
Total Errors 21 21.43%

Secondary Diagnosis

Number of secondary diagnoses 255

Number of Secondary diagnoses correct 194 76.08%

Non Coder Error

SDI Information not available at the time of coding 0 0.00%


SDD Secondary Diagnosis Documentation issue 0 0.00%

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SDM Secondary Diagnosis Coded to Management Specification 0 0.00%


SDC Secondary Diagnosis Coded to Clinician Specification 0 0.00%
SDSC Secondary Diagnosis Coded due to System Constraint 0 0.00%

Coder Error

SD3 Secondary Diagnosis Incorrect - 3-character level 3 1.18%


SD4 Secondary Diagnosis Incorrect - 4-character level 5 1.96%
SD5 Secondary Diagnosis Incorrect - 5-character level 0 0.00%
SDIS Secondary Diagnosis Sequencing 0 0.00%
SDO Secondary Diagnosis Omitted 47 18.43%
SDNR Secondary Diagnosis not relevant 7
ECI External Cause Code Incorrect 0 0.00%
ECO External Cause Code Omitted 0 0.00%
ECNR External Cause Code Not Relevant 0
MCI Morphology Code Incorrect 3 1.18%
MCO Morphology Code Omitted 3 1.18%
MCNR Morphology Code Not Relevant 0 23.92%
Total Errors 61

Primary Procedures

Number of Primary Procedures 96

Number of primary procedures correct 87 90.63%

Non Coder Error

PPI Information not available at the time of coding 0 0.00%


PPD Primary Procedure Documentation issue 1 1.04%
PPM Primary Procedure Coded to Management Specification 0 0.00%
PPC Primary Procedure Coded to Clinician Specification 0 0.00%
PPSC Primary Procedure Coded due to System Constraint 0 0.00%

Coder Error

PP3 Primary Procedure Incorrect - 3-character level 2 2.08%


PP4 Primary Procedure Incorrect - 4-character level 4 4.17%
PPIS Primary Procedure Incorrectly Sequenced 0 0.00%
PPO Primary Procedure Omitted 2 2.08%
PPNR Primary Procedure Not Relevant 0 9.38%
Total Errors 9

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Secondary Procedures

Number of Secondary Procedures 264

Number of Secondary procedures correct 248 93.94%

Non Coder Error

SPI Information not available at the time of coding 0 0.00%


SPD Secondary Procedure Documentation issue 0 0.00%
SPM Secondary Procedure Coded to Management Specification 0 0.00%
SPC Secondary Procedure Coded to Clinician Specification 0 0.00%
SPSC Secondary Procedure Coded due to System Constraint 0 0.00%

Coder Error

SP3 Secondary Procedure Incorrect - 3-character level 2 0.76%


SP4 Secondary Procedure Incorrect - 4-character level 5 1.89%
SPIS Secondary Procedure Incorrectly Sequenced 0 0.00%
SPO Secondary Procedure Omitted 9 3.41%
SPNR Secondary Procedure Not Relevant 8 6.06%
Total Errors 16

Not counted as errors - included for reference only

Field is automatically calculated - no need to insert figure

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Analysis of Errors: General Medicine


Number %
Total number of episodes examined 35

UTA Unsafe to audit 0

Actual number of episodes examined 35

Primary Diagnosis

Number of primary diagnoses correct 27 77.14%

Non Coder Error

PDI Information not available at time of coding 0.00%


PDD Primary Diagnosis Documentation issue 0 0.00%
PDM Primary diagnosis coded to Management Specification 0.00%
PDC Primary diagnosis coded to Clinician Specification 0.00%
PDSC Primary Diagnosis coded due to System Constraint 0.00%

Coder Error

PD3 Primary Diagnosis Incorrect - 3-character level 2 5.71%


PD4 Primary Diagnosis Incorrect - 4-character level 0 0.00%
PD5 Primary Diagnosis Incorrect - 5-character level 0.00%
PDIS Primary Diagnosis Incorrectly Sequenced 1 2.86%
PDO Primary Diagnosis Omitted 5 14.29%
Total Errors 8 22.86%

Secondary Diagnosis

Number of secondary diagnoses 108

Number of Secondary diagnoses correct 85 78.70%

Non Coder Error

SDI Information not available at the time of coding 0.00%


SDD Secondary Diagnosis Documentation issue 0 0.00%
SDM Secondary Diagnosis Coded to Management Specification 0.00%
SDC Secondary Diagnosis Coded to Clinician Specification 0.00%

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SDSC Secondary Diagnosis Coded due to System Constraint 0.00%

Coder Error

SD3 Secondary Diagnosis Incorrect - 3-character level 0 0.00%


SD4 Secondary Diagnosis Incorrect - 4-character level 0 0.00%
SD5 Secondary Diagnosis Incorrect - 5-character level 0.00%
SDIS Secondary Diagnosis Sequencing 0.00%
SDO Secondary Diagnosis Omitted 20 18.52%
SDNR Secondary Diagnosis not relevant 2
ECI External Cause Code Incorrect 0 0.00%
ECO External Cause Code Omitted 0 0.00%
ECNR External Cause Code Not Relevant
MCI Morphology Code Incorrect 3 2.78%
MCO Morphology Code Omitted 0 0.00%
MCNR Morphology Code Not Relevant 21.30%
Total Errors 23

Primary Procedures

Number of Primary Procedures 35

Number of primary procedures correct 33 94.29%

Non Coder Error

PPI Information not available at the time of coding 0.00%


PPD Primary Procedure Documentation issue 0.00%
PPM Primary Procedure Coded to Management Specification 0.00%
PPC Primary Procedure Coded to Clinician Specification 0.00%
PPSC Primary Procedure Coded due to System Constraint 0.00%

Coder Error

PP3 Primary Procedure Incorrect - 3-character level 0 0.00%


PP4 Primary Procedure Incorrect - 4-character level 2 5.71%
PPIS Primary Procedure Incorrectly Sequenced 0.00%
PPO Primary Procedure Omitted 0 0.00%
PPNR Primary Procedure Not Relevant 5.71%
Total Errors 2

Secondary Procedures

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Number of Secondary Procedures 71

Number of Secondary procedures correct 65 91.55%

Non Coder Error

SPI Information not available at the time of coding 0.00%


SPD Secondary Procedure Documentation issue 0.00%
SPM Secondary Procedure Coded to Management Specification 0.00%
SPC Secondary Procedure Coded to Clinician Specification 0.00%
SPSC Secondary Procedure Coded due to System Constraint 0.00%

Coder Error

SP3 Secondary Procedure Incorrect - 3-character level 1 1.41%


SP4 Secondary Procedure Incorrect - 4-character level 3 4.23%
SPIS Secondary Procedure Incorrectly Sequenced 0 0.00%
SPO Secondary Procedure Omitted 2 2.82%
SPNR Secondary Procedure Not Relevant 0 8.45%
Total Errors 6

Not counted as errors - included for reference only

Field is automatically calculated - no need to insert figure

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Analysis of Errors: T&O


Number %
Total number of episodes examined 30

UTA Unsafe to audit 0

Actual number of episodes examined 30

Primary Diagnosis

Number of primary diagnoses correct 23 76.67%

Non Coder Error

PDI Information not available at time of coding 0.00%


PDD Primary Diagnosis Documentation issue 1 3.33%
PDM Primary diagnosis coded to Management Specification 0.00%
PDC Primary diagnosis coded to Clinician Specification 0.00%
PDSC Primary Diagnosis coded due to System Constraint 0.00%

Coder Error

PD3 Primary Diagnosis Incorrect - 3-character level 3 10.00%


PD4 Primary Diagnosis Incorrect - 4-character level 0 0.00%
PD5 Primary Diagnosis Incorrect - 5-character level 0.00%
PDIS Primary Diagnosis Incorrectly Sequenced 2 6.67%
PDO Primary Diagnosis Omitted 1 3.33%
Total Errors 7 23.33%

Secondary Diagnosis

Number of secondary diagnoses 80

Number of Secondary diagnoses correct 59 73.75%

Non Coder Error

SDI Information not available at the time of coding 0.00%


SDD Secondary Diagnosis Documentation issue 0 0.00%
SDM Secondary Diagnosis Coded to Management Specification 0.00%
SDC Secondary Diagnosis Coded to Clinician Specification 0.00%

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SDSC Secondary Diagnosis Coded due to System Constraint 0.00%

Coder Error

SD3 Secondary Diagnosis Incorrect - 3-character level 1 1.25%


SD4 Secondary Diagnosis Incorrect - 4-character level 1 1.25%
SD5 Secondary Diagnosis Incorrect - 5-character level 0.00%
SDIS Secondary Diagnosis Sequencing 0.00%
SDO Secondary Diagnosis Omitted 18 22.50%
SDNR Secondary Diagnosis not relevant 2
ECI External Cause Code Incorrect 0 0.00%
ECO External Cause Code Omitted 0 0.00%
ECNR External Cause Code Not Relevant
MCI Morphology Code Incorrect 0 0.00%
MCO Morphology Code Omitted 1 1.25%
MCNR Morphology Code Not Relevant 0 26.25%
Total Errors 21

Primary Procedures

Number of Primary Procedures 29

Number of primary procedures correct 26 89.66%

Non Coder Error

PPI Information not available at the time of coding 0.00%


PPD Primary Procedure Documentation issue 1 3.45%
PPM Primary Procedure Coded to Management Specification 0.00%
PPC Primary Procedure Coded to Clinician Specification 0.00%
PPSC Primary Procedure Coded due to System Constraint 0.00%

Coder Error

PP3 Primary Procedure Incorrect - 3-character level 1 3.45%


PP4 Primary Procedure Incorrect - 4-character level 0 0.00%
PPIS Primary Procedure Incorrectly Sequenced 0 0.00%
PPO Primary Procedure Omitted 1 3.45%
PPNR Primary Procedure Not Relevant 10.34%
Total Errors 3

Secondary Procedures

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Number of Secondary Procedures 120

Number of Secondary procedures correct 114 95.00%

Non Coder Error

SPI Information not available at the time of coding 0.00%


SPD Secondary Procedure Documentation issue 0.00%
SPM Secondary Procedure Coded to Management Specification 0.00%
SPC Secondary Procedure Coded to Clinician Specification 0.00%
SPSC Secondary Procedure Coded due to System Constraint 0.00%

Coder Error

SP3 Secondary Procedure Incorrect - 3-character level 1 0.83%


SP4 Secondary Procedure Incorrect - 4-character level 0 0.00%
SPIS Secondary Procedure Incorrectly Sequenced 0 0.00%
SPO Secondary Procedure Omitted 5 4.17%
SPNR Secondary Procedure Not Relevant 5 5.00%
Total Errors 6

Not counted as errors - included for reference only

Field is automatically calculated - no need to insert figure

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Analysis of Errors: General Surgery


Number %
Total number of episodes examined 34

UTA Unsafe to audit 1

Actual number of episodes examined 33

Primary Diagnosis

Number of primary diagnoses correct 27 81.82%

Non Coder Error

PDI Information not available at time of coding 1 3.03%


PDD Primary Diagnosis Documentation issue 0.00%
PDM Primary diagnosis coded to Management Specification 0.00%
PDC Primary diagnosis coded to Clinician Specification 0.00%
PDSC Primary Diagnosis coded due to System Constraint 0.00%

Coder Error

PD3 Primary Diagnosis Incorrect - 3-character level 2 6.06%


PD4 Primary Diagnosis Incorrect - 4-character level 2 6.06%
PD5 Primary Diagnosis Incorrect - 5-character level 0.00%
PDIS Primary Diagnosis Incorrectly Sequenced 0 0.00%
PDO Primary Diagnosis Omitted 1 3.03%
Total Errors 6 18.18%

Secondary Diagnosis

Number of secondary diagnoses 67

Number of Secondary diagnoses correct 50 74.63%

Non Coder Error

SDI Information not available at the time of coding 0 0.00%


SDD Secondary Diagnosis Documentation issue 0 0.00%
SDM Secondary Diagnosis Coded to Management Specification 0.00%
SDC Secondary Diagnosis Coded to Clinician Specification 0.00%

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SDSC Secondary Diagnosis Coded due to System Constraint 0.00%

Coder Error

SD3 Secondary Diagnosis Incorrect - 3-character level 2 2.99%


SD4 Secondary Diagnosis Incorrect - 4-character level 4 5.97%
SD5 Secondary Diagnosis Incorrect - 5-character level 0 0.00%
SDIS Secondary Diagnosis Sequencing 0.00%
SDO Secondary Diagnosis Omitted 9 13.43%
SDNR Secondary Diagnosis not relevant 3
ECI External Cause Code Incorrect 0.00%
ECO External Cause Code Omitted 0.00%
ECNR External Cause Code Not Relevant
MCI Morphology Code Incorrect 0 0.00%
MCO Morphology Code Omitted 2 2.99%
MCNR Morphology Code Not Relevant 25.37%
Total Errors 17

Primary Procedures

Number of Primary Procedures 32

Number of primary procedures correct 28 87.50%

Non Coder Error

PPI Information not available at the time of coding 0.00%


PPD Primary Procedure Documentation issue 0.00%
PPM Primary Procedure Coded to Management Specification 0.00%
PPC Primary Procedure Coded to Clinician Specification 0.00%
PPSC Primary Procedure Coded due to System Constraint 0.00%

Coder Error

PP3 Primary Procedure Incorrect - 3-character level 1 3.13%


PP4 Primary Procedure Incorrect - 4-character level 2 6.25%
PPIS Primary Procedure Incorrectly Sequenced 0.00%
PPO Primary Procedure Omitted 1 3.13%
PPNR Primary Procedure Not Relevant 12.50%
Total Errors 4

Secondary Procedures

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Number of Secondary Procedures 73

Number of Secondary procedures correct 69 94.52%

Non Coder Error

SPI Information not available at the time of coding 0.00%


SPD Secondary Procedure Documentation issue 0.00%
SPM Secondary Procedure Coded to Management Specification 0.00%
SPC Secondary Procedure Coded to Clinician Specification 0.00%
SPSC Secondary Procedure Coded due to System Constraint 0.00%

Coder Error

SP3 Secondary Procedure Incorrect - 3-character level 0 0.00%


SP4 Secondary Procedure Incorrect - 4-character level 2 2.74%
SPIS Secondary Procedure Incorrectly Sequenced 0 0.00%
SPO Secondary Procedure Omitted 2 2.74%
SPNR Secondary Procedure Not Relevant 3 5.48%
Total Errors 4

Not counted as errors - included for reference only

Field is automatically calculated - no need to insert figure

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Appendix 3: Error Keys

Unsafe to Audit Error Key


UTA UNSAFE TO AUDIT
The auditor is unable to audit the coded clinical data against the source documentation.
For example:
There is no clinical information regarding the episode in the auditor’s source documentation to
support the auditor’s code assignment.

Primary Diagnosis Error Keys

Coder Error
PD3 PRIMARY DIAGNOSIS INCORRECT AT THREE CHARACTER LEVEL
The primary diagnosis code has been allocated to an incorrect three character code.
Or, where it is clear the code allocated to classify the disease or health related problem is
incorrect at third character level and incorrectly sequenced within a secondary field.

PD4 PRIMARY DIAGNOSIS INCORRECT AT FOUR CHARACTER LEVEL


The primary diagnosis code has been allocated to an incorrect fourth character.
Or, where it is clear the code allocated to classify the disease or health related problem is
incorrect at fourth character level and incorrectly sequenced within a secondary field.

PD5 PRIMARY DIAGNOSIS INCORRECT AT FIVE CHARACTER LEVEL


The primary diagnosis code has been allocated to an incorrect fifth character.
Or, where it is clear the code allocated to classify the disease or health related problem is
incorrect at fifth character level and incorrectly sequenced within a secondary field.

PDIS PRIMARY DIAGNOSIS INCORRECTLY SEQUENCED


The primary diagnosis code recorded by the auditor has been accurately coded but not
sequenced as the primary diagnosis by the coder.

PDO PRIMARY DIAGNOSIS OMITTED


The primary diagnosis recorded by the auditor has not been recorded by the coder in any
diagnosis field. This error key should not be assigned when it is clear that the coder has
attempted to record the correct primary diagnosis. In such instances the error key PD3 Primary
diagnosis incorrect at three character level should be assigned.

Non-Coder Error
PDI INFORMATION AVAILABLE AT THE TIME OF AUDIT NOT AVAILABLE AT
THE TIME OF CODING
Information available to the auditors was not available at the time of coding. This is where
information regarding the episode became available after the episode was coded. This error
key is not to be used if the information was not accessed by the clinical coder at the point of
coding, for example, with histopathology reports.
This error key would also be assigned by the auditor when the source documentation used at
the time of coding did not contain all pertinent information required for accurate and complete
coding and the coder did not have access to this information, for example, coding from
proforma with no access to the case notes.

PDD PRIMARY DIAGNOSIS DOCUMENTATION ISSUE

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The auditor’s code allocated from the source documentation differs from that of the Trusts due
to unclear or inconsistent information.
For example:
Inconsistency between information recorded by clinical staff contained on source
documentation and it is not clear which is correct
The source documentation is illegible.

PDM PRIMARY DIAGNOSIS CODED TO MANAGEMENT SPECIFICATION


There is a clear and documented directive from management to contravene coding to national
standards.
For example:
by adding or optimising the coded clinical data to alter the derived HRG.

PDC PRIMARY DIAGNOSIS CODED TO CLINICIAN SPECIFICATION


There is a clear and documented directive from clinicians to contravene coding to national
standards or capture those instances where a clinician has requested that coding be done in a
particular way as it more accurately captures the diagnosis.
For example:
by recording codes that suit individual preference.

PDSC PRIMARY DIAGNOSIS CODED DUE TO SYSTEM CONSTRAINT


Due to the system that the Organisation uses the primary diagnosis codes is technically
incorrect at some level, omitted or sequenced incorrectly.

Secondary diagnosis error key descriptions

Coder Error
SD3 SECONDARY DIAGNOSIS INCORRECT AT THREE CHARACTER LEVEL
The secondary diagnosis code has been allocated to an incorrect three character code.
Or, where it is clear the code allocated to classify the disease or health related problem is incorrect
at third character level and incorrectly sequenced.

SD4 SECONDARY DIAGNOSIS INCORRECT AT FOUR CHARACTER LEVEL


The secondary diagnosis code has been allocated to an incorrect four character code.
Or, where it is clear the code allocated to classify the disease or health related problem is incorrect
at fourth character level and incorrectly sequenced.

SD5 SECONDARY DIAGNOSIS INCORRECT AT FIVE CHARACTER LEVEL


The secondary diagnosis code has been allocated to an incorrect five character code.
Or, where it is clear the code allocated to classify the disease or health related problem is incorrect
at fifth character level and incorrectly sequenced.

SDNR SECONDARY DIAGNOSIS NOT RELEVANT


The secondary diagnosis code recorded by the coder is not relevant to the episode of care.

SDO SECONDARY DIAGNOSIS OMITTED


Diagnosis that has been recorded by the auditor as relevant but is missing from the Organisation’s
recorded episode. This error key should not be assigned when it is clear that the coder has
attempted to record the correct secondary diagnosis. In such instances the error key SD3

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Secondary diagnosis incorrect at three character level should be assigned.

SDIS SECONDARY DIAGNOSIS INCORRECT SEQUENCING


The sequencing of the secondary codes contravenes national standards. This error key can only
be assigned for error in the following national standards:
Outcome of delivery (Z37 and Z38 if not well baby)
Specific coding conventions in ICD-10 i.e. use additional code
Extent of body surface in burns (T31, T32)
Where an external cause of injury code is incorrectly sequenced
ECI EXTERNAL CAUSE CODE INCORRECT
The external cause code recorded by the Organisation is incorrect at any character level. If the
external cause code is incorrect due to a documentation issue, then the appropriate non coder error
key must be assigned instead - i.e. SDD or SDI.

ECO EXTERNAL CAUSE CODE OMITTED


The external cause code has been omitted from the Organisation’s recorded episode.

ECNR EXTERNAL CAUSE CODE NOT RELEVANT


The external cause code recorded by the coder is not relevant to the episode of care. If the
external cause has recorded due to a system constraint then SDSC must be assigned.

Non-Coder Error
SDI INFORMATION AVAILABLE AT THE TIME OF AUDIT NOT AVAILABLE AT
THE TIME OF CODING
See PDI.

SDD SECONDARY DIAGNOSIS DOCUMENTATION ISSUE


The auditor’s code allocated from the source documentation differs from that of the Trusts due
to unclear or inconsistent information.
For example:
Inconsistency between information recorded by clinical staff contained on source
documentation and it is not clear which is correct
The source documentation is illegible.

SDM SECONDARY DIAGNOSIS CODED TO MANAGEMENT SPECIFICATION


There is a clear and documented directive from management to contravene coding to national
standards.
For example:
by adding or optimising the coded clinical data to alter the derived HRG.

SDC SECONDARY DIAGNOSIS CODED TO CLINICIAN SPECIFICATION


There is a clear and documented directive from clinicians to contravene coding to national
standards or capture those instances where a clinician has requested that coding be done in a
particular way as it more accurately captures the diagnosis.
For example:
by recording codes that suit individual preference.

SDSC SECONDARY DIAGNOSIS CODED DUE TO SYSTEM CONSTRAINT


Due to the system that the Organisation uses, codes are technically incorrect at some level,

Document: 20140626 Llandough Audit Report v1.0 Date: 26/06/2014


Authors: Richard Burdon, Helen Dennis Version: 1.0 (Final)
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Clinical Coding Audit – Llandough Hospital

omitted or sequenced incorrectly. This includes external cause codes that are not relevant to
the episode of care, but have been recorded due to system constraint.

Primary procedure error key descriptions

Coder Error
PP3 PRIMARY PROCEDURE INCORRECT AT THREE CHARACTER LEVEL
The primary procedure code has been allocated to an incorrect three character code.
Or, where it is clear the code allocated to classify the procedure or intervention is incorrect at
third character level and incorrectly sequenced within a secondary field.
Where the procedure code has been incorrectly assigned to an OPCS-4 principal category
instead of the principal category’s associated extended category, the error key PP4 Primary
procedure incorrect at four character level should be assigned

PP4 PRIMARY PROCEDURE INCORRECT AT FOUR CHARACTER LEVEL


The primary procedure code has been allocated to an incorrect four character code.
Or, where it is clear the code allocated to classify the procedure or intervention is incorrect at
fourth character level and incorrectly sequenced within a secondary field.

PPIS PRIMARY PROCEDURE INCORRECTLY SEQUENCED


The primary procedure or intervention code recorded by the auditor has been accurately coded
but not sequenced as the primary procedure by the coder.

PPO PRIMARY PROCEDURE OMITTED


The primary procedure recorded by the auditor has not been recorded by the coder in any
procedure field. This error key should not be assigned when it is clear that the coder has
attempted to record the correct primary procedure. In such instances the error key PP3
Primary procedure incorrect at three character level should be assigned.
PPNR PRIMARY PROCEDURE NOT RELEVANT
The primary procedure recorded by the coder is not relevant to the episode of care.

Non-Coder Error
PPI INFORMATION AVAILABLE AT THE TIME OF AUDIT NOT AVAILABLE AT
THE TIME OF CODING
See PDI.

PPD PRIMARY PROCEDURE DOCUMENTATION ISSUE


The auditor is unable to code the clinical data from the source documentation and compare
against that of the Trusts due to unclear or inconsistent information.
For example:
Inconsistency between information recorded by clinical staff contained on the source
documentation and it is not clear which is correct
The source documentation is illegible.

PPM PRIMARY PROCEDURE CODED TO MANAGEMENT SPECIFICATION


There is a clear and documented directive from management to contravene coding to national
standards.
For example:
by adding or optimising the coded clinical data to alter the derived HRG.

Document: 20140626 Llandough Audit Report v1.0 Date: 26/06/2014


Authors: Richard Burdon, Helen Dennis Version: 1.0 (Final)
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Clinical Coding Audit – Llandough Hospital

PPC PRIMARY PROCEDURE CODED TO CLINICIAN SPECIFICATION


There is a clear and documented directive from clinicians to contravene coding to national
standards or capture those instances where a clinician has requested that coding be done in a
particular way as it more accurately captures the intervention that occurred.
For example:
by recording codes that suit individual preference.

PPSC PRIMARY PROCEDURE CODED DUE TO SYSTEM CONSTRAINT


Due to the system that the Organisation uses codes are technically incorrect at any level,
omitted or sequenced incorrectly.

Secondary Procedure error key descriptions

Coder Error
SP3 SECONDARY PROCEDURE INCORRECT AT THREE CHARACTER LEVEL
The secondary procedure code has been allocated to an incorrect three character code.
Or, where it is clear the code allocated to classify the procedure or intervention is incorrect at
third character level and incorrectly sequenced.
Where the procedure code has been incorrectly assigned to an OPCS-4 principal category
instead of the principal category’s associated extended category, the error key SP4 Primary
procedure incorrect at four character level should be assigned

SP4 SECONDARY PROCEDURE INCORRECT AT FOUR CHARACTER LEVEL


The secondary procedure code has been allocated to an incorrect four character code.
Or, where it is clear the code allocated to classify the procedure or intervention is incorrect at
fourth character level and incorrectly sequenced.

SPIS SECONDARY PROCEDURE INCORRECTLY SEQUENCED


The Organisation has not sequenced the procedure coding according to the rules and
conventions of the classification.
For example:
See use as secondary code when associated with…

SPO SECONDARY PROCEDURE OMITTED


Secondary procedure that has been recorded by the auditor as relevant but is missing from the
Organisation’s recorded episode. This error key should not be assigned when it is clear that the
coder has attempted to record the correct secondary procedure. In such instances the error
key SP3 Primary procedure incorrect at three character level should be assigned.

SPNR SECONDARY PROCEDURE NOT RELEVANT


The secondary procedure code recorded by the coder is not relevant to the episode of care.

Non-Coder Error
SPI INFORMATION AVAILABLE AT THE TIME OF AUDIT NOT AVAILABLE AT
THE TIME OF CODING

Document: 20140626 Llandough Audit Report v1.0 Date: 26/06/2014


Authors: Richard Burdon, Helen Dennis Version: 1.0 (Final)
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Clinical Coding Audit – Llandough Hospital

See PDI.

SPD SECONDARY PROCEDURE DOCUMENTATION ISSUE


The auditor is unable to code the clinical data from the source documentation and compare
against that of the Trusts due to unclear or inconsistent information.
For example:
Inconsistency between information recorded by clinical staff contained on the source
documentation and it is not clear which is correct
The source documentation is illegible.

SPM SECONDARY PROCEDURE CODED TO MANAGEMENT SPECIFICATION


There is a clear and documented directive from management to contravene coding to national
standards.
For example:
by adding or optimising the coded clinical data to alter the derived HRG.

SPC SECONDARY PROCEDURE CODED TO CLINICIAN SPECIFICATION


There is a clear and documented directive from clinicians to contravene coding to national
standards or capture those instances where a clinician has requested that coding be done in a
particular way as it more accurately captures the intervention that occurred.
For example:
by recording codes that suit individual preference.

SPSC SECONDARY PROCEDURE CODED DUE TO SYSTEM CONSTRAINT


Due to the system that the Organisation uses codes are technically incorrect at any level,
omitted or sequenced incorrectly.

Document: 20140626 Llandough Audit Report v1.0 Date: 26/06/2014


Authors: Richard Burdon, Helen Dennis Version: 1.0 (Final)
Page 48 of 48

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