tains only to Medicare and only to retrospective audits. Some
have misinterpreted the announcement to mean that they
have complete flexibility with all payers for ICD- 10 reporting
on the front end. Someone well-versed in CDI can ensure compliant coding that won’t subsequently jeopardize reimbursement once the Medicare flexibility has expired.
Due to fear of denials and audits, physicians frequently down-code their evaluation and management (E/M) levels (i.e., code
a lower-level, lesser paying E/M code). In some cases, a higher
level might be justified if the individual trained in CDI can identify opportunities where documentation is lacking—and then
query for clarification. In other cases, a CDI specialist can identify patterns of over-coding that could trigger an audit or raise
a payer’s red flag. An example is when a physician provides a
follow-up office visit or subsequent hospital visit and then bills
using a higher level E/M code as though a comprehensive new
patient office visit or an initial hospital visit had been provided.
Bundling and modifier usage
CDI specialists can help physicians identify when it’s appropriate to use a modifier and when a particular procedure or service
is inherent in a more extensive procedure or service performed
at the same time.
How to Get Started with Physician CDI
In this age of documentation scrutiny, physician practices
can’t afford to wait for an OIG or CMS audit to reveal noncompliance. Doing so could put a practice out of business. It’s also
in the practice’s best interest to improve documentation if it’s
part of an ACO, shared-savings initiative, or larger health system. Consider these three strategies:
Hire a certified coding professional. Several associa-
tions, including AHIMA, can point a practice to certified
coding professionals. By ensuring that documentation
meets regulatory requirements, a certified coding pro-
fessional is an invaluable asset for any physician prac-
tice. A certified coding professional can also use his or
her auditing skills to provide CDI feedback. Allow cod-
ing professionals to spend time in the clinical areas of
the practice so they become more familiar with clinical
diagnoses and procedures and can assist with documen-
Focus on collaboration. Collaboration among key staff
members in the provider practice will help providers
document better and more efficiently. Also, quality CDI
programs can help a practice streamline processes and
procedures that currently create extra work for office staff
and providers alike.
Seek assistance from hospital-based CDI specialists
and HIM directors. These individuals can share valuable
resources (i.e., policies, documentation tools/tips) that
can help practices launch their CDI efforts.
Documentation quality begins in the outpatient setting. Physicians who document well in their practices help establish a
baseline for patient severity and justify medical necessity for
inpatient services. Quality documentation enhances outcomes
and ensures accurate revenue. Now is the time to evaluate
needs, build partnerships, and begin the important task of improving physician practice documentation. ¢
Department of Health and Human Services’ Office of Inspector
General. “Fiscal Year 2016 Work Plan.” http://oig.hhs.gov/
Dari Bonner ( firstname.lastname@example.org) is chief training officer, and Dr.
Karen M. Fancher ( email@example.com) is educational trainer at the
Medical Management Institute (MMI).
Expanding CDI to
Quiz ID: Q1628705 | EXPIRATION DATE: MAY 1, 2017
HIM Domain Area: Management Development
Article—“Expanding CDI to Physician Practices”
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