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Clinical Coding Usage Policy

Heidi Compliance

Compliance•27 August 2026•

Table of Contents

  • 1. Clinical Coding Tool Description

  • 2. Accuracy, not optimisation

  • 3. Human review is mandatory

  • 4. AI limitations and no warranty of accuracy

  • 5. Customer responsibilities and prohibited uses

  • 6. Data, privacy and access

  • 7. Third-party classification content

  • 8. Errors, changes and availability

  • 9. General

1. Clinical Coding Tool Description

1.1 The Clinical Coding Tool is an educational and assistive tool. It is designed to help qualified clinical coders, billing staff and other authorised users identify the codes that most accurately reflect what is recorded in the clinical documentation for an encounter.

1.2 The Clinical Coding Tool analyses clinical session context and, where an integration is enabled, relevant patient context from the Customer's electronic health record. It surfaces candidate codes, the classification rules or descriptors those candidates rely on, and the passages of documentation that support them.

1.3 Every output of the Clinical Coding Tool is a suggestion for human consideration. Outputs are not determinations, not instructions, and not a submitted code. Nothing the Clinical Coding Tool produces is submitted to any payer, funder, insurer or government body by Heidi.

1.4 The Clinical Coding Tool is an administrative and revenue-cycle tool. It is not clinical decision support, it does not diagnose, and it must not be used to inform clinical care decisions. Heidi does not supply the Clinical Coding Tool as a medical device and it must not be used as one.

2. Accuracy, not optimisation

2.1 The Clinical Coding Tool is designed and operated to promote coding accuracy. Its purpose is to help the Authorised User arrive at the code that correctly reflects the documented clinical reality, whether that code attracts a higher, lower or identical payment than the code the Authorised User would otherwise have selected.

2.2 Heidi does not design, tune, train, market or measure the Clinical Coding Tool to increase Customer revenue. Specifically, the Clinical Coding Tool does not:

2.2.1 preferentially suggest a code because it attracts a higher payment, weighting, DRG, HRG or item fee;

2.2.2 prompt an Authorised User that an encounter is close to a payment threshold, or invite additional documentation in order to cross one;

2.2.3 suggest, imply or encourage that clinical documentation be added, amended or embellished for the purpose of supporting a different code;

2.2.4 apply automated rules that depart from the applicable classification standards or code descriptors; or

2.2.5 rank, score or reward Authorised Users or Customers by reference to reimbursement outcomes.

2.3 Where the Clinical Coding Tool displays funding or reimbursement information, it does so only to give the Authorised User context for a coding decision that is already supported by the documentation. Such information is an estimate only, is never presented as a target, and may be disabled at a Customer's request.

2.4 Upcoding: the assignment of a code that is not supported by the clinical documentation, in order to obtain a higher payment, is a prohibited use of the Clinical Coding Tool under clause 5. If an Authorised User believes an output has nudged them toward a code the documentation does not support, they should reject the suggestion and report it to Heidi so it can be investigated.

3. Human review is mandatory

3.1 The Clinical Coding Tool must not be used in isolation. Every suggested code must be independently reviewed by a suitably qualified Authorised UserIt is the sole responsibility of the Customer and each Authorised User to review each output, and to identify and correct any error, omission or inaccuracy in it, before it is using or relying on it. No output may be accepted, recorded, submitted or otherwise relied on until that review has been performed by a suitably qualified Authorised User.

3.2 The Authorised User remains the coder of record. Responsibility for the final code set assigned to an encounter rests entirely with the Authorised User and the Customer, and is not shared with, transferred to, or discharged by Heidi.

3.3 In reviewing an output, the Authorised User must satisfy themselves that the suggested code is supported by the clinical documentation for that encounter, is consistent with the applicable classification standards and coding conventions, and complies with the Customer's own coding policies and any applicable payer, funder or contractual rules.

3.4 The Customer must ensure that Authorised Users hold the qualifications, credentials and training required in their jurisdiction to perform clinical coding, and that they are not permitted to accept outputs without review. Automated or bulk acceptance of outputs without human review is a prohibited use.

3.5 The Clinical Coding Tool does not replace, reduce or substitute for the Customer's own coding audit, quality assurance, clinical governance or internal review processes. Those processes should continue unchanged.

4. AI limitations and no warranty of accuracy

4.1 The Clinical Coding Tool uses artificial intelligence. AI systems can and do make mistakes. Outputs may be incomplete, may omit a code that should have been assigned, may include a code that should not have been assigned, may misinterpret clinical language, abbreviations or negation, or may reflect classification rules that have since been updated.

4.2 The Clinical Coding Tool does not include medical advice of any kind. Heidi does not guarantee that any code suggested will be accepted, paid, funded or reimbursed by any payer, insurer, funder or government body, and gives no assurance as to coverage, tariff, grouping, weighting or payment outcome.

4.3 To the maximum extent permitted by law and subject to clause 10.2, the Clinical Coding Tool and all outputs are provided on an “as is” and “as available” basis, without warranty of any kind, whether express, implied or statutory, including any implied warranty of merchantability, fitness for a particular purpose, accuracy, or non-infringement. Heidi does not warrant that outputs are accurate, complete, current, coding-compliant, audit-proof, or fit for submission to any payer, funder or regulator.

4.4 Any accuracy, performance or benchmark figures Heidi publishes describe measured performance under specified test conditions. They are not a warranty of performance on any particular encounter, dataset, specialty or Customer environment.

4.5 The Clinical Coding Tool may indicate a level of confidence in a suggestion. Confidence indicators are directional only and do not reduce the review obligation in clause 3.

5. Customer responsibilities and prohibited uses

5.1 The Customer is solely responsible for its own claims, billing, invoicing, activity reporting, funding submissions and financial reporting, including for the accuracy, completeness and lawfulness of anything it submits to any payer, insurer, funder, health service, revenue authority or government body. Heidi is not the submitter of, and accepts no responsibility for, any claim, return or report the Customer makes.

5.2 The Customer is responsible for maintaining the internal controls, sign-off, audit trails and record-keeping that its regulatory, contractual and financial-reporting obligations require, and for retaining the documentation that supports each code it submits.

5.3 The Customer must not, and must not permit any Authorised User to:

5.3.1 use the Clinical Coding Tool to assign or support a code that is not supported by the clinical documentation for the encounter;

5.3.2 amend, supplement or backdate clinical documentation for the purpose of supporting a higher-paying code;

5.3.3 configure, prompt or use the Clinical Coding Tool with the objective of maximising reimbursement rather than achieving coding accuracy;

5.3.4 accept outputs in bulk, automatically, or without qualified human review;

5.3.5 use the Clinical Coding Tool to inform clinical care, diagnosis or treatment decisions;

5.3.6 sublicense, resell, assign or transfer access to the Clinical Coding Tool, or supply its outputs, to any third party, or operate it as a service bureau, coding outsourcer or time-sharing service, except as expressly permitted in writing;

5.3.7 remove, obscure or alter any copyright, trademark, licence, version or proprietary notice displayed by the Clinical Coding Tool;

5.3.8 hold the Clinical Coding Tool out to any third party as a certified, guaranteed or compliance-assuring coding solution;

5.3.9 use the Clinical Coding Tool other than in a jurisdiction and configuration for which it has been made available.

5.4 The Customer must promptly notify Heidi if it becomes aware of any output that appears to systematically favour higher-paying codes, any material coding error pattern, or any regulatory enquiry, audit or investigation concerning codes generated with the assistance of the Clinical Coding Tool.

6. Data, privacy and access

6.1 Heidi processes clinical and patient information for the Clinical Coding Tool as a processor, business associate or equivalent on the Customer's behalf, in accordance with the applicable Data Processing Agreement or Business Associate Agreement and the Heidi Privacy Policy.

6.2 Access to patient information is scoped to what is reasonably necessary to code the relevant encounter. Broader or longitudinal record access is used only where the coding purpose requires it, and is logged.

6.3 Clinical Coding Tool inputs, processing, workflow metadata and outputs remain within the Customer's applicable regional environment, consistent with Heidi's regional data residency controls.

6.4 Heidi maintains audit logging of coding activity, including outputs generated, outputs accepted and outputs overridden, and makes relevant logs available to the Customer to support the Customer's audit and compliance obligations.

6.5 Heidi does not use Customer clinical data to train or improve models for the benefit of other customers unless the data has been de-identified to the standard applicable in the relevant jurisdiction, or the Customer has expressly agreed in writing to that use.

7. Third-party classification content

7.1 Code sets, classifications, groupers, descriptors and related materials used by the Clinical Coding Tool may be licensed from third parties. Use of the Clinical Coding Tool is subject to the terms on which that content is licensed, including any restriction on the territory in which it may be used, and any prohibition on redistribution, extraction or derivative use.

7.2 The Customer acknowledges that it obtains no right, title or interest in third-party classification content beyond the right to use it through the Clinical Coding Tool for its own coding purposes.

7.3 Where Heidi is required by a licensor to pass on specific end-user conditions or reporting obligations, those conditions are set out in the applicable jurisdiction annex and form part of these Terms.

8. Errors, changes and availability

8.1 Heidi maintains a process for receiving, triaging and resolving reported coding errors, and for notifying affected Customers where an error may have a material effect on codes already generated.

8.2 Heidi may update the Clinical Coding Tool, including its models, code sets and rules, to improve accuracy or reflect changes in classification standards. Material changes affecting coding behaviour will be communicated to the Customer.

8.3 Heidi may vary these Terms. Where a variation is material, Heidi will give the Customer reasonable notice before it takes effect.

9. General

10.1 In these Terms: “Authorised User” means an individual the Customer permits to access the Clinical Coding Tool; “Customer” means the organisation that has contracted with Heidi; “encounter” means a clinical episode, admission, visit or consultation to which coding is applied.

10.2 These Terms do not constitute legal, coding, billing, tax or regulatory advice. The Customer should obtain its own advice on its coding, billing and reporting obligations.