JACS Cancer Hospital HIM Project Improvement Team Julie Callahan, Ashley Diebler, Casey Wilson, Sabrina Chapman Mission Statement • To evaluate the current organizational coding processes to determine improvement measures and to initiate a compliance plan that will ensure our healthcare professionals, clients, thirdparty payers, and other stakeholders are provided with the most accurate and complete billing, as well as data collection/storage/retrieval services. Vision • To be the region’s leader in accurate and complete health information management services, who upholds the highest ethical and legal standards, by following all HIPAA and state laws. Values • Accuracy • Granularity • Comprehensiveness • Precision • Consistency • Relevancy • Accessibility • Timeliness • Currency • Ethicality • Definition Goals • • • • • • • • • • • • Establish ongoing monitoring to identify problems or opportunities to improve quality of coded data Make recommendations for improvement in the Coding Compliance Plan Optimize the coding process Identify variations in coding practices among staff members Determine cause and scope of identified problems Set priorities for resolving identified problems Implement mechanisms for problem-solving through approval of corrective action plans Ensure that corrective action is taken by following up on problems with appropriate monitors Ensure compliance while meeting organizational needs Assess for quality health information management & risk management Decrease over-utilization for healthcare services Use a database management software application to demonstrate the use of database technology for collection storage and retrieval of healthcare data to support ongoing quality assessment Customers/Stakeholders and Customers’ Requirements • Healthcare professionals • Patients • Third-party payers • Registries • Administration Provide the most up-to-date and accurate codes for health records. In order to submit claims that provide the most appropriate reimbursement. Quality Assessment • Audited 30 patient health records with previous code assignments to ensure all codes were up-to-date, correctly assigned, and that no codes were missing. Quality Assessment Tools • • • • • • • Brainstorming Check sheets Emails Discussion boards Graphs Excel spreadsheets PowerPoint Quality Improvement Measures • Coding accuracy classified as: – Correct – Wrong – Missing – Extra Compiled Data Spreadsheet Type of Coding System Used 526 Total Codes (526 total) 5.89% 7.98% ICD-9 Diagnosis (321) 8.17% CPT E/M (89) CPT Pathology (43) CPT Procedure (42) 16.92% 61.03% ICD-9 Procedure (31) ICD-9 Diagnoses Codes Audit Results (321 Total Codes) ICD-9 Procedure Codes Audit Results (31 Total Codes) CPT Procedure Codes Audit Results (42 Total Codes) CPT Pathology Codes Audit Results (43 Total Codes) CPT E/M Codes Audit Results (89 total Codes) Total Number of Codes Audit Results (526 total) 0.95% 15.78% Correct (394) 8.37% Wrong (44) Missing (83) Extra (5) 74.90% Audit Results of Records 159 Total Records Audited 13 Records with Deficiencies (159 total) 7 Number of Records 6 5 4 3 2 1 0 Wrong Dates (1.26%) Missing Dates (3.77%) Record Status Were Never Coded (2.52%) Incomplete Records (0.63%) Correct Codes by Coding System Wrong Codes by Coding System (44 total) 0% 11% ICD-9 Diagnosis (22) 12% CPT E/M (12) 50% CPT Procedure (5) ICD-9 Procedure (5) CPT Pathology (0) 27% Missing Codes by Coding System (83 total) 2% 2% 4% 4% ICD-9 Diagnosis (73) CPT E/M (3) CPT Procedure (3) CPT Pathology (2) ICD-9 Procedure (2) 88% Extra Codes by Coding System (5 total) 20.00% CPT Procedure (4) ICD-9 Diagnosis (1) ICD-9 Procedure (0) 80.00% CPT Pathology(0) CPT E/M (0) Recommendation for Improvement • Coding Compliance Plan • Policies and procedures related to: – Documentation Standards – Documentation Guidelines – Resources all coders should have – Internal audit process – Physician query process – Education and training – Identify risk areas related to coding – Corrective Action – Reporting of compliance issues Quality Improvement Measure: Documentation Standards • • • • • • • • • • • • • • Accuracy Comprehensiveness Consistency Accessibility Currency Definition Granularity Precision Relevancy Timeliness Legibility Authenticity Approved format Policies/procedures • Record should be organized systematically • Only authorized individuals should document, receive, and transcribe • Authors should be clearly identified • Use only approved abbreviations/symbols • All entries should be permanent • Errors should be corrected in appropriate fashion • Use addendums to correct or add info. • Training/education • Structured data in EHR Quality Improvement Measure: Resources for Coders • AHIMA’s Standards of Ethical Coding • CMS and AHIMA’s Official Coding Guidelines & requirements • Facility-based coding guidelines • Any state-specific requirements • Website access to LCDs and NCDs • Updated code books • NCCI edits • Coding Clinics • CPT Assistant • A medical dictionary • A pharmacology reference • An anatomy/physiology reference Quality Improvement Measure: Internal Audit Process • Internal audits conducted weekly • If 10% or greater of submitted claims get denied conduct internal audits daily until % of denial is 5% – HIM coding manager or supervisor will perform internal audits using claim analysis checklist • Random selection of 5 records per coder will be audited • Random selection of 10 records per federal payer and 5 records per physician will be audited • All trends and coding errors analyzed to determine reason for coding errors • Audit results presented to coding staff, supervisors, physicians, and corporate compliance officer • Coders to maintain accuracy of 100% or greater – Below 100% subject for review and/or corrective action • Revisions to policies/procedures and systems edits; additional education/training; disciplinary action Quality Improvement Measure: Query Process • • • • • • Query when documentation fails to meet the following criteria regarding any significant reportable condition/procedure: – Legibility – Completeness – Clarity – Consistency – Precision – **Do NOT question a provider’s clinical judgment Query should include all appropriate information according to form Query should follow facility-approved query form Query should be in a timely manner whether concurrent, retrospective, post-bill design, or a combination of the three Providers response is required within 48 hrs. Consequences for noncompliance Providers response documented in progress note, discharge summary, or query as part of the formal health record. Quality Improvement Measure: Education and Training • Provided for – – – – • Form: – – – – • Physicians Coders Clinical documentation specialists Other ancillary departments (Case management, wound care, laboratory, nutrition, etc.) Webinars: provide reliable, expert, and timely information Audio seminars Online education In-class Topics: – – – – – AHIMA ICD-10-CM EHR Implementation American Recovery & Reinvestment Act of 2008 Recovery Audit Contractors (RACs) Quality Improvement Measure: Risk Areas Related to Coding Issues • • • • • • • • • • Only bill for items/services actually rendered DO NOT upcode to enhance reimbursement DO NOT unbundle to enhance reimbursement DO NOT bill for discharge when a transfer occurred DO NOT bill for outpatient services rendered with inpatient stays if follows 72-hr window rule DO NOT assign codes resulting in DRG with higher payment if not supported by documentation (DRG Creep) DO NOT make code selection on radiology, laboratory, or any other diagnostic test result ALWAYS follow coding guidelines unless payer specifies otherwise in writing and are approved by HIM manager ALWAYS read ALL clinical documentation ALWAYS query physician when documentation is unclear Quality Improvement Measure: Corrective Action • Corrective actions for resolving problems identified during coding audits include: – Revisions to policies and procedures – Process improvements – Education of coders, physicians, and/or organizational staff depending on the nature of the identified problem – Revision or addition of routine monitoring activities – Revisions to the chargemaster – Additions, deletions, or revisions to systems edits – Documentation of improvement strategies – Disciplinary action Quality Improvement Measure: Reporting of Coding Compliance Issues • All employees are required to promptly report any good faith belief of a violation of the laws and regulations that govern JACS Cancer Hospital • No employee will suffer any penalty or retribution for reporting in good faith any suspected misconduct or noncompliance • Any employee who fails to report knowingly suspected misconduct or noncompliance may be subject to disciplinary action • Any employee who purposely makes a knowingly false accusation will be subject to appropriate discipline • Compliance concerns may be reported to the department supervisor, manager, or compliance officer either orally or written • Individuals may also report anonymously at the JACS hotline which is open 24 hours a day and 7 days a week • All reports will be referred to the compliance department Benefits of Coding Compliance Plan • Improved coding accuracy • Relevant physician and coder education • Decrease in denials • Improved physician documentation • Proactive research into variations from benchmark data and their underlying causes • Timely identification, correction, and prevention of potential coding compliance risks References • • • • • Johns, M. L. (2011). Health information management technology: An applied approach. (3rd ed.). Chicago, IL: AHIMA. Schraffenberger, L. (2012). Basic ICD-10-CM/PCS and ICD-9-CM coding. Chicago, IL: AHIMA. Schraffenberger, L. A. & Kuehn, L. (2011). Effective management of coding services. (4th ed.). Chicago, IL: AHIMA. Shaw, P. L. & Elliott, C. (2012). Quality and performance improvement in healthcare: A tool for programmed learning. (5th ed.). Chicago, IL: AHIMA. Smith, G.I. (2012). Basic current procedural terminology and HCPCS coding. Chicago, IL: AHIMA.