I am doing a little catching up on "independence" guidance per AICPA guidelines (American institute of CPAs). The basic theory is that providing attestation services (reviewing financial information to verify to its accuracy)- that these services should be independent of the client. That there are inherent conflicts that can arise when a CPA is not independent. For example, if I owned a company that I was selling to you- if I told you I was a CPA, so you should trust me that the financials are accurate, would or should you trust my opinion?
No. You should not trust my opinion, because there is not independence in appearance or in mind. 

We may not be held to the AICPA standards of independence, but we hold to the values. Bern Medical provides a review of the procedures performed to discover certain procedures that were never billed. We are independent of the billing company and of the provider. We just care about discovering opportunities and/or verifying that all items were captured. 

Can a similar review be done by the billing company or the billing department? Of course, if they developed or acquired the technology or spent significant time. Auditing selections could also be made to help make discoveries. But when you are around 98-99% capture- you likely won't discover anything through selections- let alone all items that were missed.

But the real problem with having the review done by people that perform the billing function is independence. Stated from AICPA section 100-1 on IndependenceIndependence is defined as:

  1. Independence of mind—The state of mind that permits the performance of an attest service without being affected by influences that compromise professional judgment, thereby allowing an individual to act with integrity and exercise objectivity and professional skepticism.
  2. Independence in appearance—The avoidance of circumstances that would cause a reasonable and informed third party, having knowledge of all relevant information, including safeguards fn 2 applied, to reasonably conclude that the integrity, objectivity, or professional skepticism of a firm or a member of the attest engagement team had been compromised.


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