In addition to the fine point that Humbabella made, I took your suggestion and asked some actual providers. Here’s feedback from two doc’s I just spoke to (friends both, one in private practice, one at a teaching hospital). Both noted that the Medicare billing rules are neither more nor less complex than those of the myriad of other third-party payers that they must deal with. What they want is one set of rules to work with. This is one of the “cost curve bending” issues that you raise in your first post (but misdiagnosed) - medical providers of all stripes spend silly amounts of time/$$$ trying to find their way through dozens of disparate billing systems. Those dollars are one of the many reasons our system is saturated with costs that don’t actually go into actual care. Give the providers single-payer and costs go down.
As for “jail time” - that’s silliness. In the words of HCFA (the Health Care Financing Administration, previously the Centers for Medicare & Medicaid Services or CMS) Administrator Nancy-Ann Min DeParle, doctors “will not be punished for honest mistakes and we [HCFA] will not make referrals to the Office of the Inspector General for occasional errors.” You make it sound like a mis-code can send a doc to jail and that’s simply not the case.