"Coding and billing training on the federal health care program requirements may be necessary for certain members of the physician practice staff. The OIG understands that most physician practices do not employ a professional coder and that the physician is often primarily responsible for all coding and billing. However, it is in the practice’s best interest to ensure that individuals who are directly involved with billing, coding, or other aspects of the federal health care programs receive extensive education specific to that individual’s responsibilities. Training may be conducted either in-house or by an outside source. Training at outside seminars, instead of internal programs and in-service sessions, may be an effective way to achieve the practice’s training goals. The OIG recommends that there be at least an annual training program for all individuals involved in the coding and billing aspects of the practice. Ideally, new billing and coding employees will be trained as soon as possible."