3rd Annual Association of Clinical Documentation Improvement Specialists Conference Bridging the CDI gap: Bringing the clinical/coding reconciliation process together Margi Brown, RHIA, CCS, CCS-P, CPC, CCDS Lynne Spryszak, RN, CCDS, CPC-A Objectives of this presentation: • Identify successful CDI infrastructure models • Learn how to use each other’s strengths to build a strong process • Use differences to “close the gap” • Develop a “full-circle” reconciliation process Program Foundation/Infrastructure Who needs to be involved? • Build a solid foundation of support – Administrative support/Steering Committee • • • • CEO CFO CMO/VP Medical Affairs/Chief of Staff VP Nursing – HIM Director – Director of CDI Who has responsibility? • CDI Program Reporting structure – HIM and CDI reporting to same level of administration • • • • • • • Facilitates decision-making Eliminates barriers d/t differing facility goals Understands global effect of program Support for change Champions growth – invested in success Promotes program within organization Ability to approve program changes – Staffing – Focus of program Importance of program leaders • CFO (Chief Financial Officer) – Understands: • Financial impact of program – Payer benefits – Impact on operating budget » DNFB, A/R • How improved profiling affects business – Fiscal responsibility • Approves budget/spending – CDI FTEs Importance of program leaders • CEO (Chief Executive Officer) – Hospital’s “top dog” • Top level of Administrative Tree – Influence • • • • Medical Staff Nursing HIM All other departments Importance of program leaders • CMO (Chief Medical Officer)/VPMA (Vice President of Medical Affairs)/Chief of Medical Staff – Responsibilities: • Support/facilitate physician education • Support physician participation – Access to staff meetings • Support CDI Process – Medical staff involvement » Inclusion on medical staff agendas » Physician compliance – Final medical authority in query follow-up process Importance of program leaders • CNO (Chief Nursing Officer)/VP of Nursing/ Director of Nursing – May have responsibility for CDS – Understanding of CDI goals • Documentation drives data – Nursing documentation • Impacts data • Patient care • Ability to effect change – Required documentation: forms, templates, EMR fields, etc. – Participation of Nurse Practitioners, other second level providers with documentation privileges – Support goals of documentation improvement Importance of program leaders • HIM Director – Approves CDI/Coding policies and procedures – May have responsibility for CDS as well as coders (overall program administrator) – Approves procedural changes – Final responsibility for actions of HIM department • Coder participation • Coding turnaround time • Compliance Importance of program leaders • CDI Director – Provides guidance – Access to resources – Liaison between CDS and upper management – Responsible for • • • • Program outcomes Meeting goals Staffing Training Importance of program leaders Importance of program leaders • Key Points – Success depends upon involvement of the executive committee – Collaboration within and between administrative levels essential – Program organizational structure not as important as strong leadership at each level – Ongoing communication is pivotal to success The blended model The “Blended” Model: HIM and RN teams The blended model What each profession brings to the team The blended model • HIM Strengths – Knowledge of coding rules and regulations – Training/Education 2 - 4 (or >) years of formal learning including: • • • • Anatomy & Physiology Pharmacology Medical Terminology Health Information Management – – – – – Inpatient coding/billing Physician (Professional) coding/billing Specialty training Legal/Ethical Issues in Healthcare Reimbursement Methodology • • • • • Outpatient coding/billing ED coding/billing Health Data Management Computer Systems Clinical Data Management The blended model • RN Strengths – Clinical (hands-on) assessment experience – Training/Education 2 – 4 (or >) years of formal learning including: Anatomy & Physiology Pharmacology Medical Terminology Pathophysiology Nutrition Microbiology Pediatric/Adult Growth and Development Psychology Ethics Clinical Practice Chemistry The blended model HIM 50% RN 50% 100 % Success = 50% + 50% Effort! The blended model • Teams – Respect differing values & viewpoints – Share the “load” – Define goals – Develop processes – Avoid blame/shame – Focus on the problem, not the people – Persistent – Work together… The blended model Success depends on everyone knowing their job and then doing it! The blended model • Responsibilities of the Coder: – – – – – – Ethical behavior Accurate code assignment Productivity benchmarks Data management Confidentiality Adherence to internal policies and procedures • Facility • Coding • Employee – Adherence to rules and regulations • • • • AHIMA Code of Ethics “Official Coding Guidelines for ICD-9” Coding Clinic State regulations – Continuing education – Training and development The blended model • Responsibilities of the CDS – Ethical behavior – Facilitate improvements in provider diagnostic documentation – Collaborate in data reporting (diagnoses) • • • • Specificity Clinically appropriate Supported by medical record Ensure “complete” record – Adherence to internal policies and procedures • Coding • CDI • Employee – Adherence to external rules and regulations • AHIMA? • ???? Are there any? The blended model While CDI team members may be subject to the same internal policies (employee, safety, body mechanics, etc.), determining whether the CDS’ are governed by coding rules and regulations and whether their goals are the same as the coders’ has been much disputed and the subject of controversy. • This “double standard” creates an “us” versus “them” mentality. – Impedes or eliminates trust – Creates conflict – Prevents collaboration – Diminishes credibility – Team working as individuals rather than partners Perspective: Do you see what I see? Case study The patient is a 78-year-old female who presented with a 2-day history of black tarry stools. This patient denied any abdominal pain, nausea, vomiting or diarrhea, also, no chest pain, no fevers or chills. The patient denied any recent trauma or change in medication. The patient had a significant history of use of aspirin, Plavix, and Coumadin. The patient denied any gross blood in stool or history of any ulcers in her GI tract or cancers of the GI tract. Initial laboratory work revealed hemoglobin level of 8.1 and hematocrit of 24.8, which was down from a baseline level of 10.4 hemoglobin in August 2009. Her INR was 4.4 as well. Troponins were negative x3 sets and chest x-ray was clear. Upon admission, warfarin, Plavix, and aspirin were held and she was transfused 2 units of packed red blood cells followed by H and H q.6 hours. She was also given IV fluids and placed on a Nexium drip. Case study On April 3rd, she was again found to be weak, tired, and also experienced a bowel movement that was positive for blood. Her hemoglobin had initially responded to the first 2 units of blood to a level of 9.6 but had again decreased to 8.6. She was given 1 more unit of packed red blood cells and GI was consulted for endoscopy. EGD was performed, which revealed no active source of bleeding. Also, colonoscopy was performed which revealed no source of bleeding as well. Case study • DISCHARGE DIAGNOSES: 1. Osteoporosis 2. Dementia 3. Osteoarthritis (OA) 4. Coronary artery disease (CAD) 5. Type 2 diabetes 6. Gastroesophageal reflux disease (GERD) 7. Peripheral vascular disease (PVD) 8. Depression 9. Hyperlipidemia 10. Hypertension 11. Acute gastrointestinal (GI) bleed How good are your ‘eyes’? Through a coder’s eyes: 1. Acute GI bleed – Due to ? 2. H/H low – – – – – Query needed for ?anemia & type ?blood loss ?acute on chronic 3. GERD 4. Hx aspirin use 5. (Code the rest of discharge diagnoses listed) – – – EDG Colonoscopy Transfusion How good are your eyes? Through a nurse’s eyes: 1. Why was the patient on Plavix and Coumadin? 2. Was patient taking her medication appropriately – she has dementia a) Was this then a “poisoning” or is it an “averse effect”? 3. Pt placed on Nexium drip – did the doctor suspect an upper GI bleed? 4. Should I ask the GI guy if he suspects a cause of bleeding even though the scopes were negative? 5. Did the patient have blood loss anemia or was it a combination – blood loss, iron deficiency, other? The medical record • Coders: – Identify documented conditions (diagnoses) • Focus on what IS documented, not what isn’t – Focus on “who” documented – Identify and interpret conflicting information – Interpret operative reports – Understand the difference between what is apparent and what is “code-able” – Process records efficiently and within defined time frames (can’t get bogged down in one record) The medical record • Nurses: – Synthesize random bits of information into a diagnosis • Pulmonary infiltrates + Levaquin = Pneumonia • Absent bowel sounds = Ileus • Increased pulse, edema, and “wet” breath sounds = CHF – “Leap to conclusions” – Don’t need to see the word to know it exists – Aren’t necessarily concerned with specificity • Bronchitis or COPD – what’s the difference – it’s all SOB • Altered mental status = more work! • Why do I care if it’s systolic heart failure? They all get Lasix! • I can’t read the progress notes either - when in doubt, I guess! The medical record • Coders typically – Review thousands of records each year – Look at all the documentation, while thinking coding, guidelines, and is it all supported? • All clinician documentation, all reports, progress notes, orders … – Are happy to have a discharge summary at the time of coding. • Compares the discharge summary to the body in the chart to make sure all is consistent. – Have the “whole enchilada” available for coding • Well, maybe half an enchilada if there’s no d/c summary… – Reviews all other information and digs into the nursing notes when searching for a missing link… – Generally don’t place a lot of emphasis on the ED notes, (for coding purposes), but use for the introduction (framework of the patient – what occasioned the admission to the hospital) – Take pride in their work The medical record • Nurses typically – Focus on the abnormals: lab results, vital signs, mental status, x-rays – Focus on the clinical, not the record – Don’t see things as contradictions • Renal failure = renal insufficiency – Rarely “challenge” a physician’s diagnosis – Only use the progress notes if there’s no “check box” – Are task-oriented • • • • Assess patient Pass medications Sign-off orders Document by exception – Take pride in their work What’s the answer? • • • • Respect our similarities Appreciate our differences Share what we know Be willing to admit what we don’t know and ask for help • Appreciate each other’s limitations – Time – Opportunity – Expertise • Keep our “eyes on the prize” – accurate data! • Collaborate in devising solutions Comprehensive approach • CDS perform concurrent reviews and Coders perform retrospective reviews to: – Identify opportunities • Diagnosis specificity/accuracy – Request clarification as needed • Priorities – align, but the scope or focus may be a little different – CDS • • • • Physician documentation: accurate, specific, clinically supported HACs CORE measures Medical Necessity – Coders • Coding the record: accurate, specific, clinically supported, also meeting the above (to an extent) Observations • Neither group can do it alone – – or should have to • What one person misses, another one may catch – “have each others’ backs” • Wearing different “glasses” makes us see things differently • One group can help the other – “many hands make light work” One solution? • Never only one solution • Process is dynamic • Enlist support: – Medical staff – Nursing – Ancillary care – Quality – Finance – Managers • Be willing to compromise on the small issues and collaborate on the big issues Drawing the circle Assigning the DRG DRG/MS-DRG assignment Aiming for the most accurate … 40 The driver = The principal diagnosis • The principal diagnosis (PDx) is the initial “driver” to the (one) MDC…. • Then driving on to the most specific DRG/MS-DRG • With of course several factors involved PDx: Principal diagnosis • Coding guideline for inpatient hospital cases for the Principal diagnosis = “that condition established after study to be chiefly responsible for occasioning the admission of the patient to the hospital for care.” • How does the term “principal” dx differ from the clinician’s definition? (Most severe? most acute?) MDC listing The bucket list Medical Diagnosis Start with medical first • The starting point is always the medical diagnosis. – Determines the correct MDC • Medical diagnoses are grouped to DRGs within that MDC • MDC assignment does not change d/t surgical procedure • Correct starting point “drives” the DRG assignment ⇒Incorrect starting point, incorrect ending point 45 DRG bucket options Post- MS- Acute DRG DRG Special Pay DRG MDC TYPE FY 2010 MS-DRG Title Weights Geo metric mean LOS Arith metic mean LOS 186 187 188 Yes Yes Yes No No No 04 04 04 MED MED MED PLEURAL EFFUSION W MCC PLEURAL EFFUSION W CC PLEURAL EFFUSION W/O CC/MCC 1.5917 1.0620 0.7612 5.5 3.9 2.9 7.1 5.0 3.6 189 No No 04 MED 1.3455 4.7 6.0 190 Yes No 04 MED 1.2076 4.7 5.8 191 Yes No 04 MED 0.9622 4.0 4.8 192 193 194 195 Yes Yes Yes Yes No No No No 04 04 04 04 MED MED MED MED PULMONARY EDEMA & RESPIRATORY FAILURE CHRONIC OBSTRUCTIVE PULMONARY DISEASE W MCC CHRONIC OBSTRUCTIVE PULMONARY DISEASE W CC CHRONIC OBSTRUCTIVE PULMONARY DISEASE W/O CC/MCC SIMPLE PNEUMONIA & PLEURISY W MCC SIMPLE PNEUMONIA & PLEURISY W CC SIMPLE PNEUMONIA & PLEURISY W/O CC/MCC 0.7175 1.4378 0.9976 0.7095 3.2 5.3 4.3 3.3 3.8 6.6 5.1 3.9 291 292 293 304 305 Yes Yes Yes No No No No No No No 05 05 05 05 05 MED MED MED MED MED HEART FAILURE & SHOCK W MCC HEART FAILURE & SHOCK W CC HEART FAILURE & SHOCK W/O CC/MCC HYPERTENSION W MCC HYPERTENSION W/O MCC 1.4609 0.9740 0.6940 1.0242 0.5959 5.0 3.9 2.9 3.7 2.2 6.4 4.7 3.4 4.8 2.8 1.2188 4.0 5.3 0.8207 3.0 3.8 0.5710 0.5128 0.7215 0.5404 2.1 1.9 2.5 1.7 2.6 2.3 3.1 2.1 308 No No 05 MED 309 No No 05 MED 310 311 312 313 No No No No No No No No 05 05 05 05 MED MED MED MED CARDIAC ARRHYTHMIA & CONDUCTION DISORDERS W MCC CARDIAC ARRHYTHMIA & CONDUCTION DISORDERS W CC CARDIAC ARRHYTHMIA & CONDUCTION DISORDERS W/O CC/MCC ANGINA PECTORIS SYNCOPE & COLLAPSE CHEST PAIN Procedures Surgical Procedure Is there a surgical procedure? • If a procedure is done, you then drive from medical to the surgical side of the MDC. • However; not in all cases. – Not all procedures will drive to the surgical side: • Example: Biopsy • Closed, percutaneous, open … Non-surgical procedures CMS non -surgical procedures are coded, but does not impact the DRG assignment • • • • • • • • Chest tube Cystoscopy Defibrillation EGD Electroshock therapy Endotracheal intubation ERCP Foley catheter • • • • • • • • Gastric tube I&D Intrathecal catheter Lumbar puncture Paracentesis Peritoneal dialysis Spinal tap Subclavian line • Swan-Ganz catheter • Temporary pacemaker • Thoracentesis 49 Procedures: One too many • The PDx as the driver is still the determining factor in many cases for a surgical DRG/MSDRG. • There are procedures common for multiple diagnoses in many MDCs. – IVC or Greenfield filter placement – Excisional debridement • While these procedures are included in several surgical DRGs/MS-DRGS, the PDx will drive to the most specific choice. 50 Unrelated mix • For procedures “unrelated to the principal diagnosis” – these cases are not defined in one MDC, but listed as “DRGs Associated with all MDCs” – MS-DRG 981 – 989 and further categorized by • The type of OR procedure – Extensive – Non-extensive – Prostatic • Severity with or without MCC or CC – With MCC – With CC – Without CC/MCC 52 Driver pathway 1. The PDx drives the assignment of the medical DRG. 2. A surgical procedure will drive the final surgical DRG assignment (determine “surgical”). • • • • One too many: diagnosis to procedure Unrelated OR vs. bedside Multiple surgical procedures 3. Check the surgical hierarchy • Variables = PDx, surgical class, complications & comorbidities 4. Review for those significant secondary diagnoses that may affect the severity of the patient 53 Driving points • “Birds of a feather …” – DRGs are sometimes like close “flocks” • the medical PDx and the (valid OR) surgical procedure usually stick together in the same MDC flock when they can 54 55 The driver(s) • Who is the driver of the documentation and can it be coded? “Medical record documentation from any provider (a physician or any qualified healthcare practitioner who is legally accountable for establishing the patient’s diagnosis) involved in the patient’s care and treatment may be used to support the determination of whether a condition was present on admission or not; and the importance of consistent, complete documentation in the medical record cannot be overemphasized” Source: MLN Matters Number: MM5499 Related Change Request Number: 5499, 091107 update and Transmittal #289 071707 update 56 The passenger(s)? • Not the licensed “treating” physician for an inpatient case: • Radiologist interpreting an x-ray • Pathologist examining tissue • Roles for clarification: – Residents • Are all residents licensed in your organization? – Nurse Practitioner/Physician Assistants • Check the state and/or hospital bylaws 57 HAC: Yes or no, and why? Indicator Definition How a HAC will be treated with this indicator Yes; POA Will assign to higher weighted DRG No; Not POA Will NOT assign to higher weighted DRG U Unknown: insufficient documentation Will NOT assign to higher weighted DRG W Clinically Undetermined: Unable to determine based on clinical picture Will assign to higher weighted DRG Y N It’s a go! 59 Reconciliation process Tightening the reconciliation process • • • • Many variables Start to finish review Coding rules Procedure – – It is what it is • Setting the bar too high – % matching • Final outcome Reconciliation goals • Back to basics – Goal(s) of the program – Top priorities – Communication front to back and in-between – Stats reported • • • • Purpose Method Outcome Baseline and opportunities – Remembering the different “lens” Bottom line • Hospitals as well as each physician need the most accurate and specific documentation that translates into correct and compliant coding to reflect the true complexity of care and severity of illness of their patients. Evolvement of the MS-DRG Admitting DRG • Starting Point; does not count • As currently documented Working DRG Presumptive DRG • Pending query • After query resolved and final coded Final DRG 63 Reconciliation mismatches The majority of the original sample of mismatches involved the principal diagnosis from the CDS to final coding . Reason Medical # Surgical % # Total % # % PDx 27 54% 4 8% 31 62% MCC 3 6% 2 4% 5 10% CC 1 2% 0 0% 1 2% SDx 0 0% 0 0% 0 0% PP 6 12% 1 2% 7 14% SPx 0 0% 0 0% 0 0% Multiple 3 6% 3 6% 6 12% Total 40 80% 10 20% 50 100% Reconciliation mismatches The final coded MS-DRG averaged a higher relative weight compared to the initial (working) MS-DRG assigned by the CDS. • RW ↑ 36 • RW ↓ 13 • No Change 1 72% • Total Sample 50 26% 2% Reconciliation mismatches Auditor’s review of the MS-DRGs assigned: Total Sample 50 cases • Agreed with Coding 40 • Changes – RW ↑ 5 – RW ↓ 5 80% 10% 10% • The 10 cases that differ from the final MS-DRGs: – 8 cases agreed to the working CDS assignment – 2 cases with different MSDRGs, compared to the initial CDS and the final coded assignments Reconciliation mismatches • In many cases, the final MS-DRG assigned was the most accurate due to different reasons such as: – The Coders have the entire chart at the time of coding for review, instead of reviewing the chart as a snapshot point during the hospitalization. – The Coders are trained in coding, take the coding guidelines into consideration and since each case is different, multiple coding rules may apply. – The CDS however may not be as well versed in the guidelines. – The discharge summary in some of the sample cases “pulled” the information together, supporting the final coded MS-DRG. Reconciliation mismatches • The majority of the mismatched MS-DRGs assigned were due to principal diagnosis selection: – Multiple diagnoses that meet the definition for the principal diagnosis – PDx as a complication diagnosis/code – Adverse effects versus poisoning – Contradictory terms • There were also several cases with a “multiple” reason for the change. – These include a combination of topics including the principal diagnosis, and/or the secondary diagnosis at a higher weighted code - CC/MCC, and/or the procedure. Multiple PDxs? Which one is it? 69 Reconciliation mismatches • There were several cases where a mismatched MS-DRG was due to the procedure(s). – The majority of these changes involved incorrect MS-DRGs assigned by the CDS due to actual coding of the procedure itself and/or reviewing the case prior to the procedure date. – As a note, with these cases, the documentation was present in the chart where the Coders were able to accurately code the chart. Reconciliation mismatches • Factors – Knowledge and skill level of staff – The complexity of the cases • The focus of this review was complex cases that involved high level understanding of coding guidelines. – Process of concurrent reviews • Root cause(s) • In most cases, the inability to follow-up on cases and the application of coding guidelines for the principal diagnosis led to the MS-DRG mismatch. RAC – one more reason to work together… RAC: Top errors • Medically Unnecessary Service or Setting – 62% • All Other Inpatient Overpayments – 11% • Incorrect Discharge Status – 1% • DRG Change Due to Wrong Diagnosis Code or Principal Assignment – 14% • DRG Change Due to Wrong Procedure Code(s) – 12% Source: Appendix F Audit Areas and Top Errors by Provider Type Figure F1. Audit Areas and Top Errors by Provider Type, Net of Appeals: Cumulative Through 3/27/08, Claim RACs Only (Percent of Overpayment Amount) http://www.cms.hhs.gov/RAC/Downloads/RAC_Demonstration_Evaluation_Report.pdf RAC: Debridement Table P1. Excisional Debridements (Complex Review, Incorrect Coding) • Claim Facts – – – The hospital coder assigned a procedure code of 86.22. In the medical record, the physician writes “debridement was performed.” Coding Clinic 1991Q3 states “Unless the attending physician documents in the medical record that an excisional debridement was performed (definite cutting away of tissue, not the minor scissors removal of loose fragments), debridement of the skin should be coded to 86.26, non excisional debridement of skin… Any debridement of the skin that does not meet the criteria noted above or is described in the medical record as debridement and no other information is available should be coded as 82.26.” • The RAC determined that the claim was INCORRECTLY CODED and issued a repayment request letter for the difference between the payment amount for the incorrectly correctly coded procedure and the payment amount for the correctly coded procedure. • Corrective Actions – Hospitals can be more careful when submitting claims for excisional debridement. Medicare claims processing contractors can remind hospitals about the importance of following the coding clinic guidelines when submitting claims for excisional debridement. Source: http://www.cms.hhs.gov/RAC/Downloads/RAC_Demonstration_Evaluation_Report.pdf Summing it all up Set it up • Set your key goals involving: – Complete clinical documentation – Coding Quality – Medical Necessity – RAC or denial vulnerabilities • Set your table – Who is involved – Who is the “key” point person – Determine the level of involvement – Responsibility and authority – Map the process – Agree on the road map Reconciliation internally incorporating KEY members and “interdepartmental” involvement: CM, quality, core measures, departments • Developing and maintaining the full circle program • Bringing it all together Audits and RAC • Starting the program and Documentation Working together – Team and Relationship Building – Development of “partnerships” within and outside the facility – Dancing to the “same” tune Driving the distance • Develop a current state process and map to your common goal – destination • Keep going no matter what the barriers may be Audience questions ?