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2/18/2019 1 The Importance of CDI: Inpatient and Outpatient Michele Hand, Senior Clinical and HIM Consultant CDI • A collaborative process between coding, CDI professionals and providers to ensure that documentation accurately reflects the condition and acuity of the patient during the episode of care. • CDI reconciles inconsistent, incomplete, and conflicting documentation prior to the final coding 2

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Page 1: The Importance of CDI - Arkansas HFMA · The Importance of CDI: Inpatient and Outpatient Michele Hand, Senior Clinical and HIM Consultant CDI • A collaborative process between coding,

2/18/2019

1

The Importance of CDI:Inpatient and Outpatient

Michele Hand, Senior Clinical and HIM Consultant

CDI

• A collaborative process between coding, CDI professionals and

providers to ensure that documentation accurately reflects the condition

and acuity of the patient during the episode of care.

• CDI reconciles inconsistent, incomplete, and conflicting documentation

prior to the final coding

2

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Characteristics of Good, Quality Documentation

• Complete

– Complete clinical picture of the patient encounter

– Includes chief complaint; physician orders and reason for the

orders; diagnostic test results; procedure, therapy and nursing

notes; physician and consultant notes

• Reliable

– Content is trustworthy and safe and everyone reading the record

has the same understanding

• Precise

– Accurate and well defined

– Detail supports clinical picture from diagnostic and treatment

positions.

– Clinical details include vitals, test results and other clinical

indicators needed for the diagnostic process

Characteristics of Good, Quality Documentation

• Consistent

– No contradictory statements from providers

– If diagnosis changes, indicate reasons for further specificity or new

diagnosis.

• Legible

– Documentation must be able to be understood by everyone

reviewing it.

– Illegible documentation compromises the quality of documentation

• Clear

– Comprehensible and distinct

– Vague documentation can be ambiguous and unclear

• Timely

– Available when it is needed for patient care delivery.

– Cannot be corrected after the fact

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Complete Medical Record Entries

• Support the diagnosis/condition

• Justify the care, treatment, and services

• Document the course and results of care, treatment, and services; and

promote continuity of care among providers

Evolution of Clinical Documentation Improvement

• Initial endeavors started in the inpatient setting

– These are still important, but with time, providers need less

assistance

– Capture comorbid conditions and major comorbid conditions

• MS-DRG Assignment

– Assign APR-DRGs which use SOI (severity of illness) and ROM

(risk of mortality)

– Document Present on Admission

– Ensure patients meet medical necessity and are placed in the

correct level of care

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DRG and Comorbid Condition Example

Scope of Focus is Expanding

• Inpatient Setting

– Hospital Value Based Purchasing

• Quality

• PSIs

– Clinical Validation

– Hierarchical Condition Category (HCC)

– Denial Management

• Outpatient Setting

– Hierarchical Condition Category (HCC) and Risk Adjustment

Scores

– E/M Levels

– Medical Necessity

– Denial Management

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Inpatient CDI

Hospital Value Based Purchasing

• Designed to improve the quality, efficiency, and safety of care during

acute care inpatient stays and to improve experience of care during

hospital stays

– Reduce or eliminate adverse events

– Adopt evidence-based standards and protocols that improve patient

outcomes

– Improve the transparency of care quality

– Improve patient experience

– Recognize hospitals providing high quality of care at lower costs

based on achievement and improvement

• Performance period for 2019 was 2017

• 2019 performance will affect future reporting

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2019 Performance Based on Four Quality Domains

CMS: Understanding the Fiscal Year 2019 Hospital Value-Based Purchasing Program, July 2018

Four Quality Domains

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CMS PSI 90 Measures

Hospital Acquired Conditions Reduction Program

• Hospitals that are not above the 75th percentile of reporting hospitals will

receive a 1% reduction in payment of claims for FY 2019

• Retrospective, so documentation this year will be used for future

reporting

• These are publicly reported on Hospital Compare

• 2 Domains are reviewed

Page 8: The Importance of CDI - Arkansas HFMA · The Importance of CDI: Inpatient and Outpatient Michele Hand, Senior Clinical and HIM Consultant CDI • A collaborative process between coding,

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Hospital Acquired Conditions Reduction Program

– Domain 1: 10 PSI 90 Measures

• Reporting period 10/1/15 – 6/30/17

• 15% of total score

– Domain 2: 5 Healthcare Associated Infections

• Reporting period 1/1/16 – 12/31/17

• 85% of total score

Hospital Readmission Reduction Program

• Readmission is defined as an admission within 30 days of a discharge

from the same or another IPPS acute care hospital.

• Looks at 3 years of discharge data

– 2019 looks at 7/1/14 – 6/30/17

• Do not know what future readmissions will be measured, so

documentation must be complete for all conditions treated.

• Must have 25 discharges for the condition that is being measured

• Compared with hospitals in same “Peer Group”

• Reported on Hospital Compare

• This is a penalty program

– Maximum penalties of 3% reduction in payment

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Hospital Readmission Reduction Program

• Looks at readmissions in 6 areas

– Acute Myocardial Infarction (AMI)

– Chronic Obstructive Pulmonary Disease (COPD)

– Heart Failure (HF)

– Pneumonia

– Coronary Artery Bypass Graft (CABG) Surgery

– Elective Primary Total Hip Arthroplasty and/or Total Knee

Arthroplasty (THA/TKA)

Clinical Validation

• Diagnoses documented in a patient's record must be substantiated by

clinical criteria generally accepted by the medical community

– Professional guidelines and consensus

– Evidence-based sources

• Should not have conflicting documentation between providers

• Focus of RAC and MIC Audits

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Clinical Validation

• Separate function from DRG Validation

• Separate function from routine coding process

• Facilities should have a process in place to validate clinical conditions

prior to completing the coding process

• Ensure not only accurate coding but to also reflect the accurate clinical

scenario

• Examples

– Pneumonia with a negative chest x-ray

– Acute respiratory failure with normal ABGs

– Severe malnutrition with a normal BMI

Clinical Validation Queries

• Is there conflicting documentation between providers?

• Would the provider come to the same conclusion based on the same

information?

• Is the diagnosis a reasonable conclusion based on the totality of the

health record?

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Clinical Validation for Difficult Diagnoses

• Create list of vulnerable diagnoses and agree on standard clinical

indicators for diagnosis

– Criteria should be provider driven

– Many diagnoses lack a standardized definition

– Evidence based

– Goal to promote consistency in diagnoses criteria

– Internal policy helps with RAC Audits

• Providers should always be ready to defend their diagnoses to auditors

• Collaborative CDI/coding/provider meetings

• Second-level reviews to validate an accurate and complete clinical

picture

Outpatient CDI

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Outpatient CDI

• Multiple Outpatient Settings

– Hospital

• Emergency departments

• Infusion departments

• Other outpatient services

– Physician offices

– Outpatient surgery centers

Outpatient CDI Focus

• Select a focus of high volume, high risk review areas

– Risk - Reimbursement and Quality Score Impact

– Volume -Top 10 diagnoses and procedures

– Review

• Claims data

• Frequency of claims edits

• Coding audit report

• Denial information

• Chargemaster

• E and M

• HCCs and Risk Adjustment Scores

– Look at specific payors

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Chargemaster Review

• Prevents

– Overpayment or overcharging

– Underpayment or undercharging

– Claims rejections

– Fines

– Penalties

• Looks at supplies, devices, medical services and procedures

• Implement changes

• Schedule regular reviews, at least annually

Chargemaster Review Process

• Assemble team

– CFO or finance department billing department representative

– Representative from each charging department

– Coding representatives

– information systems department representative

• Run reports of chargemaster for review

• Chargemaster should be Current, Comprehensive, Compliant

• Research chargemaster issues, including new codes

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Evaluate and Manage

• May 2014 Report from OIG

– Over 40% of claims for E&M services were incorrectly coded and/or

lacking documentation

– E&M Claims are 50% more likely to be paid in error than any other

Part B services

– Target for audit

– Providers who bill for high level E&M codes are heavily scrutinized

by OIG and CMS Contractors

– Large percentages of errors identified were downcoding

Level of E/M Service Performed

• Selection of code depends on

– Patient type

– Setting of service

– Level of E/M services performed

• Code sets organized into various categories and levels.

– More complex the visit, the higher the level of code

• Provider is responsible the select a code that reflects the services

furnished.

• 3 key components

– History

– Examination

– Medical Decision making

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Medical Necessity

• Health care services or procedures that are necessary for the purpose

of preventing, diagnosing or treating an illness, injury, disease or its

symptoms in a manner that is

– In accordance with generally accepted standards

– Clinically appropriate in terms of type, frequency, extent, site

– Not primarily for the economic benefit of the health plans, providers

or beneficiaries

• Understand NCDs and LCDs and benefits of specific plans

Hierarchical Condition Categories

• Chronic health conditions or diagnoses that require a higher level of

resources to treat

– Given a weight

• Used by payors, including Medicare and Medicaid, to predict future

healthcare costs for beneficiaries

• CMS has 83 HCC categories for 2019 and HHS has more, with close to

10,000 ICD-10 codes within the categories

• Must be documented and coded every year

• Used to predict the healthcare costs of beneficiaries

– RAF Score

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Hierarchical Condition Categories

• Review Quality Measure, MACRA and MIPS reports to see gaps

• Review 1-2 years of HCC Reports from MA payors

• HCC documentation affects Risk Adjustment Factor Scores

• Documentation criteria should follow MEAT standards

–Monitor

–Evaluate

–Assess

–Treat

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Risk Adjustment Factor

• Two parts

– Patient Demographics

• 20 -15% of the score

– Claims Data (ICD-10 HCC codes)

• 75 – 80% of the score

RAF Example

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Top Ten Risk Adjustment Coding Errors

• Health record does not have a legible signature with credentials.

• Electronic health record was not authenticated and electronically signed.

• Highest degree of specificity was not assigned to diagnosis.

• A discrepancy exists between billed diagnosis and actual description of the

condition noted in documentation.

• Documentation does not indicate a condition as being monitored,

evaluated, assessed, or treated.

• Cancer status is unclear and treatment is not documented.

• Chronic conditions such as hepatitis are not documented as chronic.

• Lack of specificity is an issue, such as unspecified arrhythmia versus a

specific type of arrhythmia.

• Chronic conditions and status codes are not documented on an annual

basis.

• Required linking language, causal relationship, or manifestation codes are

missing.

Outpatient Chart Review and Queries

• Prospective

– Pre-visit assessment of the patient’s problem list prior to encounter

– Use this information to monitor documentation after the encounter

to ensure the problem list was updated

– Develop a reminder to providers to review and update the problem

list

– Query would not be warranted prior to an encounter

• Concurrent

– Can be difficult to achieve in a busy physician practice

• Retrospective

– To ensure that all areas of focus have been addressed

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Chart Review

• Minimize claim edits from Scrubbers

– Hold up claim submission

– Can decrease reimbursement

– Require manual review

• Look at denial trends and reports for areas of focus

– Denial categories

– Denial volumes

• Coding audit reports (by coder)

– Internal and external

– Can show documentation gaps

• Increase specificity

• Support medical necessity

• CPT/HCPCS code assignment, including E/M level

Denials and Appeals

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Denial Management

• Denials are expensive

– No payment received

– Response to and defense of denials is time consuming

• Overturning the decisions made by RAC auditors is difficult

• Biggest area of denials

– Clinical Validation

– Medical Necessity

– Missing Documentation

– Inaccurate Code Assignment

Types of CMS Audits

• Audits can be done pre-payment or post-payment

• Types of Audits

– Automated: Electronic information used to detect improper claims

• Medical Code Editor (MCE)

– Non-medical record review: Identify improper coding that can

lead to improper payments

• National Correct Coding Initiatives Edits (NCCI)

– Medical record (Complex) review: Manual record review

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Types of CMS Audit Contractors

• CERT: Monitor the accuracy of MAC payments

– Findings are the road map for future audits by all types of Medicare

auditors, including MACs and recovery auditors

– Publicly reported

– Error Categories

• No Documentation

• Insufficient Documentation

• Medical Necessity

• Incorrect Coding

• Other

Types of CMS Audit Contractors

• MAC: Regional contractors with ability to compare Part A and Part B

claims for the same services to look for discrepancies to make sure the

hospital doesn't have a high payment error rate,

– Prepayment review can affect cash flow, which potentially can have

a much greater impact on a hospital than a RAC.

• RAC: Coding validations, medical necessity reviews, and clinical

validation reviews in both the inpatient and outpatient setting

• MIC: Ensure that paid claims were for services provided, properly

documented, billed properly, using correct and appropriate procedure

codes;

– 5 jurisdictions

– Audit, Review and Educate

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Types of CMS Audit Contractors

• SMRC: Focus on decreasing improper payments and increasing the

proficiencies of the medical review process for Medicare Part A and B

and durable medical equipment (DME) providers.

– May include liabilities identified by CMS’s CERT program, internal

databases, professional organization, and federal oversight

agencies

• ZPIC/UPIC: Goal is to recognize cases of suspected fraud and to then

perform an investigation to recoup inappropriate Medicare payments

using

– Investigations and Interviews

– Medical reviews

– Data analysis

– Administrative actions (e.g., payment suspension, auto-denial edits)

– Refer cases to law enforcement and licensing boards

Overview of Audit Scope

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DRG Validation Reviews

• Medicare Severity-DRG (MS-DRG) system indicates the severity of

illness that is used to represent the appropriate acuity level and the

resources utilized

• Determine if the appropriate DRG has been assigned based upon the

supplied clinical documentation and ICD-10-CM/PCS

• Ensure the diagnostic, procedural, and discharge information has been

assigned appropriately

• Evaluate all procedures that affect the DRG assignment and validate

they were reasonable and medically necessary

Medical Necessity Review

• Called “Patient Status Reviews”

• Performed by licensed medical professional

• Look at

– Admission criteria

– Invasive procedure criteria

– Inpatient-only procedures

– Coverage guidelines

– Published CMS criteria

– DRG validation guidelines

– Coding guidelines

– Other criteria such as practice guidelines

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Medical Necessity Review

• Looks at 2 Midnight Rule to make sure claims are suitable to pay under

Medicare Part A

• Documentation should support the provider’s judgment (patient history

and comorbidities, the severity of signs and symptoms of a diagnosis,

the current medical needs of the patient, and the risk of an adverse

event)

• Diagnosis sequencing can impact the likelihood of claim selection for

validation

– Principal Diagnosis definition is “the condition, after study, which

occasioned the admission”

– Comorbidities can increase the severity of illness of the patient

• Also review of diagnostic testing ordered to ensure they were necessary

to determine diagnosis

Clinical Validation Review

• Goal is to ensure accurate data was reported which represents the

patient’s condition and services provided to prevent fraudulent practices

(intentional or unintentional)

• Can identify underpayments as well as overpayments

• Requires a comprehensive record review performed by clinicians

• Clinical indicators and the patient’s overall condition are reviewed to

confirm diagnosis criteria were met

• Looks at the medical record (including physician queries), medical

literature, evidence‐based medicine

Page 25: The Importance of CDI - Arkansas HFMA · The Importance of CDI: Inpatient and Outpatient Michele Hand, Senior Clinical and HIM Consultant CDI • A collaborative process between coding,

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Clinical Validation Review

• Common findings by auditors

– Acute code when the clinical information indicates a chronic

condition

– Diagnosis that is only supported by one lab test

– Diagnosis for a condition that is inherent in another condition

– Conflicting documentation between providers

– Improper queries

Queries

• Acceptable Query types

• Queries should not lead provider

• Create neutral queries

– Clinical presentation

• Signs and symptoms

• HPI/progress notes/consults

– Diagnostic workup/lab values

– Multiple‐choice options

• Either/or

• Yes/no

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Denial Management Prevention

• Prevention is best practice

– Standard, physician approved diagnosis criteria to define difficult

diagnoses

– CDI reviews to ensure complete, consistent, accurate medical

records

• Present on Admission

• Correct DRG

• Clinical Validation

– Coders cannot omit a diagnosis that isn’t supported by

clinical indicators

• Specificity (Goal is < 20% of unspecified or NOS)

– Compliant query processes

– Tip Sheet development

– Education, education, education

Education

• Ongoing

• Pertinent

• Process improvement

• Formal and informal

• Educate

– Providers

– CDI professionals

– Coders

– Billers

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Standardized Evidence Based Criteria for Diagnoses

• For problematic diagnoses

• Providers must agree to use these guidelines or be prepared to defend

why they are not using this if audited

• Can assist in appeal process

• Gather diagnostic criteria that should be met from payors

– Some payors use Sepsis 2 and some use Sepsis 3

• Medicare definition is a hybrid of the two

Perform Audits Prior to Claim Submission

• Internal or external audits

• Documentation audits

– Specificity

– Clinical Validation

– Medical Necessity

– E/M level

• Coding quality audits

– Principal and secondary diagnoses and procedures

– Secondary diagnoses impacting SOI/ROM

– MS-DRG or APR-DRG assignment

– Present on admission (POA)

– Discharge disposition

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Management Strategies

• Document and track denials

– Reason for Denial (Coding error, Billing error, Documentation, etc)

– Changes and monetary differences (eg DRG change)

– Timelines

– Physician, CDI specialist and coder who were involved

– Whether it was appealed and appeal stage

– Action plan

– Final resolution

• Create Denial Management Team

– Defined responsibility for each member

• Physician should document clinical rationale for diagnoses and be

prepared to defend their diagnosis in an audit

Appeal Process

• Evaluate whether an appeal is warranted

• Understand different payors appeals process

• ADR (Additional Development Request)

– Reason your claim was selected

– What actions you need to take

– When you need to reply

– Consequences of not replying

– Instructions for replying

– Contractor contact information

• Create template library

– Subject matter experts (SMEs) information

– Case outlines

– Appeal letters (Must be customized for each appeal)

– Standardized clinical indicators for diagnosis

– Prior similar favorable decisions

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Appeal Letter Content

• Date of the denial letter in the heading

• Patient identifiers and Insurance information

• Restatement of the reason for denial

• A concise and factual statement explaining why the organization

believes the payer decision is inaccurate

• Physician Statement

• Supporting documentation, including where to find it

– Synopsis of the history of presenting illness

– Diagnostic results

– Clinical findings, including vital signs at time of admit decision

– Medications and their routes of administration, noting differences

from home medication regimens

– Nursing and additional clinical team member documentation

– Physician orders (admission level of care)

Appeal Letter Content

• Admission level of care review and level of care criteria screening tool

• Documentation of unexpected recovery

• Other documentation that supports the appeal (eg reference material)

• Corrective information taken

• Compliance or regulatory guidance

• Reference the CMS Conditions of Participation, AHA Coding Clinic®,

Official Guidelines for Coding and Reporting, local coverage rules,

hospital policies, etc.

• Requested outcome

• Organize information clearly

– Table of Content

– Exhibits

– Regulations

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Medicare Appeal Process

• Level 1: Redetermination of claim by MAC

– 120 days to file

– Second look at claim by someone not associated with denial

• Level 2: Reconsideration by a Qualified Independent Contractor

(QIC)

– 180 days to file

– May be panel of physicians or healthcare personnel

• Level 3: Hearing by an Administrative Law Judge (ALJ)

– 90 days to file

– ALJs operate under HHS Office of Medicare Hearings and Appeals,

is independent of CMS

– Appeals can be done

• By video teleconference, telephone, in person

• Face-to-face may be waived and answer sent by mail with an

appeal letter

Medicare Appeal Process

• Level 4: (Peer-to-peer) Review by the Medicare Appeals Council

– 90 days to file

– Facility disagrees with the ALJ decision or wants to escalate your

appeal

– Can overturn a previous denial in whole or in part

• Level 5: Judicial Review in Federal District Court

– 60 days to file

– Facility feels the Appeals Council decision is not favorable

– US District Court

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Denial Examples

• Pdx of sepsis, secondary to pneumonia (WBC 10.2, RR 32, HR

– 110, B/P 88/50), Patient is currently being treated with

chemotherapy for colorectal cancer and treated with dopamine, IV

fluids, and vancomycin.

– Denied due to not having enough clinical evidence to support the

diagnosis of sepsis.

• Pdx of aspiration pneumonia. Documentation indicates a stroke patient

with a failed swallow study

– Denied due to not having documentation to support the Pdx

• A 65 yo female, admitted to observation with dx of TIA. On day 2 she

developed hemiparesis and slurred speech and changed to an inpatient,

but no dx change made

– Denied for payment as an inpatient because TIA did not meet

medical necessity for IP care

Denial Examples

• Patient with breast cancer is admitted with anemia secondary to breast

cancer and dehydration. Treatment is directed toward anemia and

dehydration. The principal diagnosis is coded to breast cancer

– Denied due to incorrect coding, but payer agreed to pay for a

principal diagnosis of dehydration.

• Diagnosis of acute respiratory failure, with respiratory rate of 24, pulse

ox is 89% on RA, 1L of oxygen via nasal canula. Pulse ox is 97% on 1L

of oxygen. Lungs are clear and non‐labored breathing is documented.

– Denied due to not having enough clinical evidence to support the

diagnosis of acute respiratory failure

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Denial Analysis

Remember

• Document all conditions being treated for all episodes of care

• Determine facility wide standardized criteria for highly audited

diagnoses

• All Queries should be neutral and compliant with guidelines

• Perform clinical validation reviews

• Providers should be prepared to defend their diagnoses if audited

• Continue to educate

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Questions?

References

• Fernandez, Valerie. "Ins and Outs of HCCs" Journal of AHIMA 88, no.6 (June 2017): 54-56

• CMS Hospital-Acquired Condition Reduction Program Fiscal Year 2019 Fact

Sheet, July 2018

• CMS FY 2019 HACRP Matrix of Key Dates, July 2018

• Understanding the Hospital Readmissions Reduction Program, Lake Superior Quality Innovation Network, July 2018

• CMS Quality Payment Program Website (https://qpp.cms.gov/)

• CMS Hospital-Acquired Condition Reduction Program (HACRP) Website

(https://www.cms.gov/medicare/medicare-fee-for-service-payment/acuteinpatientpps/hac-reduction-program.html)

• CMS Hospital Readmissions Reduction Program (HRRP) Website

(https://www.cms.gov/medicare/medicare-fee-for-service-payment/acuteinpatientpps/readmissions-reduction-program.html)

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References

• CMS MLS Booklet Hospital Value-Based Purchasing, September 2017

• CMS Understanding the Fiscal Year 2019 Hospital Value-Based Purchasing

Program, July 2018

• Optimizing Revenue through Comprehensive CDI and Coding Practices, Joy

King Ewing, CCS AHIMA, September 2018

• Data Analytics for Outpatient CDI Programs, Pamela C. Hess, MA, RHIA, CDIP,

CPC; Vanessa Griggley-Owens, MGA, RHIA, CHC, AHIMA, 2018

• AHIMA 2016 Clinical Documentation Improvement Toolkit, 2016

• AHIMA Inpatient Query Toolkit, 2018

• AHIMA Clinical Validation Practice Brief, Melanie Endicott, MBA/HCM, RHIA, CHDA, CDIP, CCS, CCS-P, FAHIMA; Tammy Combs, RN, MSN, CDIP, CCS, CCDS

• AHIMA Clinical Validation: The Next Level of CDI, Journal of AHIMA 87, no.7 (July 2016): extended web version. Denton, Debra Beisel; Endicott, Melanie; Ericson, Cheryl E; Love, Tammy R.; McDonald, Lori; Willis, Daphne

References

• ACDIS Q&A: Querying for clinical validation of a diagnosis, CDI Strategies, August 29, 2013; Cheryl Erickson, MS, RN, CCDS, CDIP

• AHIMA CDI and Coding Collaboration in Denials Management TOOLKIT,

2018

• A Primer on Audits by RACs MACs, ZPICs and CERTs, Michael Taylor, M.D., May 24, 2011

• Medicaid Integrity Program: Medicaid Integrity Contractors

(https://www.cms.gov/Medicare-Medicaid-Coordination/Fraud-

Prevention/Provider-Audits/Downloads/MIP-Contractors-Presentation.pdf)

• Denials and CDI: A Recovery Auditor’s Perspective, Tim Garrett, MD;

Barb Brant, RN, CCDS, CDIP, CCS, 2017 ACDIS Conference

• Denials Management/Appeals, Alicia Kutzer, Esq., 2017 ACDIS

Conference

• CDI in Denials Management, Blog, Tammy Combs, RN, MSN, CDIP,

CCS, CCDS, Oct 30, 2017

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References

• ACDIS How to Mitigate and Manage Denials, Patricia Buttner,

MBA/HCM, RHIA, CDIP, CHDA, CPHI, CCS, Tammy Combs, RN, MSN,

CDIP, CCS, CCDS, ACDIS Conference 2018

• AHIMA Ten Steps to Successful Chargemaster Reviews, Maureen

Drach, Althea Davis, Carmen Sagrati, Journal of AHIMA 72 2001

• AHIMA Care and Maintenance of Chargemasters, Journal of AHIMA

March 2010

• HHS, OIG Improper Payments for Evaluation and Management

Services Cost Medicare Billions in 2010, Daniel R. Levinson Inspector

General May 2014

• AHIMA Auditing Across the Continuum: One Size Doesn’t Fit All,

Kathryn DeVault, MSL, RHIA, CCS, CCS-P, FAHIMA, Natalie Sartori,

MEd, RHIA

• AHIMA You Got Proof? Payers, Auditors Increase Clinical Validation

Checks, Mary Butler Journal of AHIMA 89, no. 7, July-August 2018

References

• AHIMA Guidelines for Achieving a Compliant Query Practice (2016

Update), AHIMA Practice Brief, January 2016

• ACDIS Ultimate Test for Queries, Cesar M. Limjoco, MD, Kelli A. Estes,

RN, CCDS, 2017

• Excellent Documentation is Necessary to Meet Medical Necessity, Erica

Remer, MD, FACEP, CCDS, ICD-10 Monitor

• AHIMA Medical Necessity for Outpatient Services, Rose T Dunn, RHIA,

CPA, CHPS, FACE, Shelley S. Safian, MAOM/HSM, CCS-P, CPC-H,

CHA, Audio Seminar Series, 2008

• A Refresher on Medical Necessity, Peter R. Jensen, MD, CPC,Family

Practice Management July/August 2006

• AHIMA Outpatient Clinical Documentation Improvement (CDI)

TOOLKIT, 2018