Crosscheck Your Compliance - ACDIS Your Compliance_India… · Indiana Spring ACDIS Conference...

Indiana Spring ACDIS Conference 2019Lisa Farhar, RN, CCDS, MSN, MBAApril 13, 2019

Crosscheck Your Compliance

Copyright © 2019 Deloitte Development LLC. All rights reserved. 2Indiana Spring ACDIS Conference 2019

Introduction

Indiana Spring ACDIS Conference 2019Copyright © 2019 Deloitte Development LLC. All rights reserved. 3

Nursing

Dietary

Respiratory therapy

Physical therapy

Wound care nurses

Infection control

Clinical nursing educators

Case management

Social services

Cardiac cath lab

OR/PACU nursing

Critical care nursing

ER nurses

Pharmacy

Departments involved in CDIClinical Documentation Integrity (CDI)


Assets and liabilitiesElectronic Health Records

AssetsTimeliness Allows multiple Providers to have

access Real time Digitize

Outcomes Reduction of medical errors Improved quality of care Collaboration

Privacy and Security Decreased security breaches

LiabilitiesTechnology Technology challenges Multiple layers Training and support

Timing Increased time documenting Less face-to-face interaction Copy/paste

EHR


Health Care InteroperabilityThe Office of the National Coordinator for Health IT (ONC)

Secure exchange

Complete access, exchange, and use

Collaboration

CMS Interoperability FY 2019

Eligible hospitals, Critical Care Access Hospitals, Dual-access Hospitals

Medicare Promoting Interoperability Programs 2019

2015 Edition of the Certified Electronic Health Record Technology (CEHRT)

Benefits of InteroperabilityPatients

Sharing of information in real time

Improve outcomes

Increased security and privacy

Providers

Real-time

Informed decisions regarding care

Increased time spent with patients

Interoperability Electronic Health Records


CDI leading practice elementsIn order to create a successful CDI program, there are several elements that should be present:

COMPLIANCE

Validates that processes comply with various facility policies, monitors changes in regulations and their impact to processes

CLINICALDOCUMENTATION

Extensive and deep clinical experience and physician contact; focus on interpreting and translating the clinical language within the medical record

CODING

Deep experience in rules and regulations; resources for CDS and physicians;assist with timely andcompliant billing

QUALITY/CASEMANAGEMENT

Focus on quality metrics, managing patient stay, continued stay, discharge planning and denials/RAC follow-up or management

ProvidersSource of clinical

documentation; involved throughout the process; support the program;and facilitate change

with peer


Industry leading practices for Clinical Documentation IntegrityWhat does the industry say?


Association of Clinical Documentation Improvement Specialist (ACDIS)

Professional organization that oversees Clinical Documentation efforts with training, certifications, journal articles, white papers, and annual conference. It also serves to advocate for the CDI Profession.

American Health Information Management Association (AHIMA)

Professional organization that oversees and serves to improve the quality of the medical record through education, training, updated information from governmental changes, and advocates for the profession.

Centers for Medicare and Medicaid Services (CMS)

Part of the Department of Health and Human Services

Office of the Inspector General (OIG)

Audits, Evaluates, Inspects against healthcare waist, abuse and fraud

Department of Health and Human Services (HHS)

Protects the health and well being of all Americans. Mission is to provide for effective health and human services by fostering advances in medicine, public health, and social services.

Leading practicesClinical Documentation Integrity

Guidance

Center of Excellence

Promotes collaboration and uses leading practices to drive

results

Training

Governance

Support

Monitoring


Leading practicesClinical Documentation Integrity

Query for conflicting, illegible, or incomplete information.

Although CMS has deferred the query process guidelines to health information management, it is noted that this is not based on scientifically-proven or evidence-based information.

These established guidelines are intended to provide industry-wide standardization and compliance and must also be individualized by facility.

Queries are not intended to, in any way, question the medical decision making of the provider.

There are various levels of health care providers. It must be determined through facility policies and procedures on who and when to query.

The attending provider is ultimately the responsible party for documentation integrity when all is said and done.

Query types should not be leading in any way or persuade the provider or introduce new information into a record.

Providers should be given all pertinent clinical information that already exists in the medical record.

Query types include open-ended, multiple choice and yes/no.

Multiple choice queries are often the most utilized type of query and should only contain reasonable choices.

• Complete and accurate documentation benefits both the hospital as well as the physician

• Complete and accurate documentation reflects an accurate picture of the patient’s acuity levels (severity of illness and risk of mortality)

• Is a reflection of the care provided – if “it is not documented it never happened”

• Effects many areas of the hospital including utilization management, resource management, hospital profiling, case management, coding accuracy, and severity and mortality indicators


Industry resourcesWhere to find the latest compliance updates?


Updated industry query complianceWhat’s new?


Guidelines for achieving a compliant query practice (2019 update) Released February 6, 2019

All queries (including verbal discussions) should be memorialized to demonstrate compliance with query requirements:

• Be clear, concise and compliant with AHIMA practice guidance

• Contain clinical indicators from the medical record

• Present only the facts identifying why clarification is needed

• Never include impact on reimbursement, payment methodology or quality measures

Examples of noncompliant queries:

• Directing providers to document a diagnosis that is not clinically supported

• Directing providers to document diagnoses that are not clinically supported as an exclusion criteria for a Patient Safety Indicator (PSI)

• Adding a non-reportable diagnosis which does not meet Uniform Hospital Discharge Data Set (UHDDS) criteria

• Encouraging providers to neutralize documentation suggestive of a complication

Reference: AHIMA “Guidelines for Achieving a Compliant Query Practice (2019 Update): https://acdis.org/resources/guidelines-achieving-compliant-query-practice-2016-update

https://acdis.org/resources/guidelines-achieving-compliant-query-practice-2016-update


Reasons to query for documentation clarificationTo support documentation of conditions that are clinically evident, meet UHDDS requirements, but are not specifically documented as a

diagnosis

To resolve conflicting documentation between attending provider and other providers

To clarify the reason for Inpatient admission

To seek clarification when a documented diagnosis does not appear to be clinically supported

To establish cause-effect relationship between medical conditions

To determine the acuity or specificity of a documented diagnosis

To clarify whether conditions documented as “history of” or “PMH (Past Medical History)” are current, active diagnoses or resolved

To clarify Present On Admission (POA) status

To clarify if diagnosis was ruled in or ruled out

To clarify the objective, and/or extent of a procedure




Guidelines for achieving a compliant query practice (2019 update) Released February 6, 2019

All queries (including verbal discussions) should be memorialized to demonstrate compliance with query requirements:

• Be clear, concise and compliant with AHIMA practice guidance

• Contain clinical indicators from the medical record

• Present only the facts identifying why clarification is needed

• Never include impact on reimbursement, payment methodology or quality measures

Examples of noncompliant queries:

• Directing providers to document a diagnosis that is not clinically supported

• Directing providers to document diagnoses that are not clinically supported as an exclusion criteria for a Patient Safety Indicator

• Adding a non-reportable diagnosis which does not meet UHDDS criteria

• Encouraging providers to neutralize documentation suggestive of a complication




Key changes: “Guidelines for achieving a compliant query practice (2019 update)”Role of previous encounters: It is inappropriate to “mine” documentation from a previous encounter for the purpose of generating a query not related to the current encounter. However, information from prior encounters can be utilized to query, when relevant to the current encounter. Examples may include:

Diagnostic criteria to establish the presence of, or to further specify a currently documented diagnosis (e.g., Chronic Heart Failure

type or specificity, cardiac arrhythmia)

Clinical criteria, diagnoses or treatment relevant to the current encounter that may have been documented in a prior encounter

Determination of prior patient “baseline,” allowing for comparison to the current status/presentation

Establish a cause-effect relationship

Determine etiology/diagnosis when only signs, symptoms or treatment are documented

Verify POA status

Clarify prior “history of” a disease that is no longer present (e.g., neoplasm, CA)




Key changes: “Guidelines for achieving a compliant query practice (2019 update)”

I. Uncertain, unconfirmed diagnoses:


Avoid using terms which suggest an uncertain diagnosis as a query response choice (e.g., “ probable, likely, presumed, etc.”) unless the query is issued at the time of, or after patient discharge

Avoid the use of the term “possible” in the query question.



Key changes: “Guidelines for achieving a compliant query practice (2019 update)”Clinical indicators:The 2019 update defines “clinical indicators” as documentation that supports a diagnosis as reportable and/or establishes thepresence of a condition

Queries must be supported by clinical indicators that are relevant to the diagnosis/ condition being queried and will vary dependent

upon the patient and clinical scenario

Clinical indicators may include provider observations, physical exam, assessment, diagnostic findings, treatments/interventions, etc.

The quality of clinical indicators (as they related to the queried condition) is more important than the quantity of indicators

Reference to prior encounters is acceptable if care provided in the current encounter necessitates the review of previous encounters to

identify or specify the undocumented condition that is relevant to the current circumstances

Multiple choices must reflect reasonable conclusions specific to the clinical scenario of the patient; the number of multiple choices is not

mandated




Key changes: “Guidelines for achieving a compliant query practice (2019 update)”Provider query responses Individuals who are queried should be educated about the reasons for the query, the query process and expectations for completion and documentation

Leading Practice: query responses should be consistently documented within the health record as part of the progress, notes,

discharge summary or as an addendum

When a compliant query has been properly answered and authenticated by the responsible provider in the medical record, absence of

further documentation in the progress notes, discharge summary or addendum should NOT prohibit code assignment

It is considered non-compliant to ask the same query to the same or to multiple providers until a desired response is received




Query policies and procedures should be developed and query practice should be managed and monitored for compliance

Organizational policy should address:

Query retention – specify if queries are part of the permanent health record and the location, or retained as part of the business record and retained for auditing, monitoring and compliance

Query escalation – develop a policy for unanswered queries and address medical staff concerns regarding queries; outline expectations of each individual involved in the process, including expected time frames in which resolution or further escalation is indicated

Monitor/auditing of CDI and Coding query metrics (query rate, provider response rate, agree rate, etc.) by CDS, Coder, specialtyand provider trends

2019 AHIMA/ACDIS update: Leading practices




Identify strengths and weaknessesWhat are your identified areas of risk?

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Review of concepts: Types of queries


Verbal queries

Verbal Delivery:Non-leading

Include appropriate clinical indicators for queried diagnosis

Include reasonable, plausible options

Required Documentation – same as written query:Timely notation of:

• Reason for query

• Date, time, signature

• Clinical indicators

• Response options provided during the verbal interaction

Provider documentation of response (i.e., diagnoses, procedures) as part of the permanent medical record

Not all verbal interactions with providers are verbal queries (e.g., Patient rounding, Provider education)

Verbal queries may be more effective in complex circumstances, such as when multiple queries are required regarding the same set of clinical indicators or for discussion of ambiguous documentation




Open-ended queriesThe provider responds to the query using free-text, which may or may not align with the documentation needed to support the code assignment

Open-ended queries:

Does not suggest possible response options or multiple choices

Must be a well-structured question to avoid ambiguity or confusion in the provider’s response

Should be written with precise language, identifying relevant clinical indicators from the medical record

Phrased in a manner that allows the provider to make a clinical interpretation of facts based on his/her professional judgment

Can be a challenge to get the intended response

The justification and inclusion of relevant clinical indicators for the query is more important than the format of the query




Multiple choice queries

Multiple choice options should not be biased toward conditions that have a more favorable impact on reimbursement:

Include clinically reasonable options that are supported by clinical indicators, recognizing that there may be only ONE reasonable option

Providing a new diagnosis option in the multiple choice list is acceptable as long as the diagnosis is supported in the medical record and referenced by clinical indicators

There is no mandatory or minimum number of multiple choices

Additional query response options should include:• Other diagnoses (specify)• Unable to determine• Disagree

“Providing a new diagnosis as an option in a multiple choice list – as supported and substantiated by referenced clinical indicators from the health record – is NOT introducing new information.”




Yes/No queries

Determining POA status

To further substantiate a diagnosis that has already been documented in the medical record (e.g., pathology, radiology, diagnostic reports) with interpretation by a physician

To establish or negate a “cause-effect” relationship between documented conditions

To resolve conflicting documentation from multiple providers

New diagnoses CANNOT be derived by a “yes / no” query. Include options for “other diagnosis/condition” and “unable to determine”

Yes/No queries may not be used in circumstances where only clinical indicators of a condition are present and the condition/diagnosis has not yet been documented in the medical record.

Circumstances where “Yes / No” queries can be used:




Query construction: Writing a compliant query


A three-legged stool

Identify all relevant criteria to support the query response using the three-legged stool approach:Clinical indicators:

• Signs and symptoms

• Clinical findings

• Diagnostic tests

• Provider documentation in the record

Risk factors (where applicable) – examples include:

• Comorbid conditions, PMH, chronic illness

• Immunosuppression

• Age, activity level, diet/nutrition, etc.

• Tobacco, drug, alcohol, substance use or abuse

Treatments, interventions – examples include:• Medications

• Procedures

• Consultations

• Changes in level of care (e.g., transfer to ICU)

AHA Coding clinics often reference clinical indictors in their guidance, but are not intended to be an authoritative source for clinical indicators, nor for establishing a given diagnosis


Customize your query templatesQuery templates should be customized on an individual basis.

Query Response Choices

Responses should NOT include diagnoses that do not pertain to the patient.

It is acceptable to use only one option when that option is the only choice.

Responses should include all possible diagnoses or etiologies based on documentation in the record

Acute blood loss anemia Acute post hemorrhagic

anemia Iron deficiency anemia Aplastic anemia Anemia of chronic disease Sickle cell anemia Anemia due to

chemotherapy Other anemia Unable to clinically

determine

Documentation in the medical records indicates anemia and GI bleed. HGB was 7.1 onadmission and the patient received 2 units PRBC. Please clarify the etiology of theanemia as:

Acute blood loss anemia Acute post hemorrhagic

anemia Precipitous drop in

hemoglobin Other please specify

Unable to clinicallydetermine


Query exercisesThe following are actual queries noted during a record review. Identify in the following examples how the query might be improved

Case scenario # 1- 82 year-old male was transferred in from an outside hospital where he presented to the ED with severe chest pain. He ruled in for STEMI. Cardiac cath was performed and showed 80% stenosis in the LAD and right coronary artery. The patient was taken to surgery for revascularization. While in surgery, the patient developed hypotension with SBPs in the 70s, became diaphoretic, and was poorly responsive to pressors. An IABP was placed for severe hypotension.

Query as written-Dr _________________. Can you read below and tell me if this patient was in cardiogenic shock and that is why the balloon was needed?

Operative note:We noted during the bypass run that the patient was hypotensive on pump and poorly responsive to Neo-Synepherine. We remove the cross clamp reperfused and de-aired. The patient was vasoplegic. He remained unresponsive to high dose of Levophed. He finally began to improve with vasopressin. Given the situation, I thought it would be helpful to have an intra-op balloon pump.

How could this query be improved?


Sample query templateDear Dr.: _________________________________ Date / Time: ____________________

Please exercise your independent, professional judgment in responding to the clarification form.

Please document in the progress notes and discharge summary the corresponding diagnosis for these clinical indicators[ ] Cardiogenic shock[ ] Other shock (please specify)_________[ ] Intraoperative hypotension[ ] Other (please specify)__________________[ ] Clinically unable to determine

Clinical Indicators:• 1/6 intraoperative vital signs- BP 76/52; 75/52; 81/70; 77/ 82 for 37 minutes; • Hypotension refractory to Levophed and Neo-Synephrine• RR 23; HR 125; diaphoresis- documented in anesthesia note

Risk Factors: AMI, CKD

Treatments; Levophed, Neo-Synepherine, and Vasopressin; IABP insertion- operative note 1/6


Query exercises.

Case scenario #2A 75 year-old female is admitted with sepsis due to UTI. On admission, the patient is noted to be dehydrated with a creatinine of 1.6. The patient was treated 200cc IV fluid bolus in the ED. Her creatinine improved to 1.3 and she was continued on IV fluids. Her creatinine improved to baseline of 1.0 two days after admission. The patient had no history of CKD. ED physician admitting diagnoses:Sepsis, UTI, prerenal azotemia.

Query as written in Meditech:“Please document the corresponding diagnosis for altered renal status with no known renal disease/history, for example AKI or other specified diagnosis.Was this condition POA?”




Please exercise your independent, professional judgment in responding to the clarification form. Clinical indicators are provided on the bottom of this form for your review

Please check all appropriate box(es) and document your response in the progress notes and/or discharge summary[ ] Acute Renal Failure (ARF) [ ] Acute Kidney Injury (AKI)[ ] Azotemia[ ] Other (please specify)_________________[ ] Clinically unable to determine

Present Clinical Indicators/Signs Symptoms/Labs Results ad location in Medical Record

[ ] Decreased urine output; Documentation of prerenal azotemia

UO 29ml/hr ED flowsheetED physician 1/29- prerenal azotemia

[ ] Elevated creatinine 1/29 1.6; 1/30 1.3; 1/29 1.0

Present Risk Factors Results ad location in Medical Record

[ ] Dehydration, sepsis Documented by ED physician, H&P, progress notes 1/29-1/31

Present Treatments Results ad location in Medical Record

[ ] IV fluid challenge 200cc fluid bolus 1/29


Query exercises

Case scenario #3A 82 year-old female with residual dysphagia from CVA, history of lung neoplasm, and hypertension, presented with dyspnea. Chest CT showed status post thoracotomy, RUL infiltrate, pericardial effusion and chronic pleural disease. Admitted for pleuraleffusion and likely aspiration pneumonia and started on IV meds. ED nursing documentation noted hx of CHF. Patient on po water pill at home.

Query as written in Meditech:CDS Documentation-Dear Doctor: Specifying the acuity and type of heart failure reflects the severity of illness and affects code assignment. Clinical Indicators:H&P mentions persistent pleural effusion. Documentation mentions DOE; CT- Pericardial effusion. Evidence of bilateral pleural disease and previous right thoracotomy

MedicationsGeneric NameTrade Name

Dose Route Freq PRN Reason

StartStop

Last AdminDose Admin

FurosemideLasix po

40mg 12/25/2018 15:05 12/27/18 10:1340mg

CDI Query-Query: Please document below and in the PROGRESS NOTES/DISCHARGE SUMMARY both the acuity and type of CHF




Please exercise your independent, professional judgment in responding to the clarification form. Clinical indicators are provided on the bottom of this form for your review

Please check all appropriate box(es) and document your response in the progress notes and/or discharge summary[ ] Chronic Diastolic CHF[ ] Chronic Combined CHF[ ] Pleural effusion. Patient does not have CHF[ ] Other (please specify)__________________[ ] Clinically unable to determine

Present Clinical Indicators/Signs Symptoms/Labs Results and location in Medical Record

[ ] Ejection fraction = 45% 11/29 echocardiogram

[ ] Dyspnea Documentation of dyspnea in ED and H&P

[ ] Pleural effusion H&P and Chest CT 12/25

Present Risk Factors Results and location in Medical Record

[ ] Hypertension Documented by ED physician, H&P, progress notes 1/29-1/31

Present Treatments Results and location in Medical Record

[ ] 40mg Lasix PO Home medication list and 40mg PO given 12/25- 12/27


Query exercises case #4

Coder Documentation-

Dear Doctor: Review for final coding for this chart revealed the need for additional specificity to ensure coding compliance, accuracy, and severity of illness. In response to this query, please exercise your professional judgment. The fact that a question is asked does not imply that a particular answer is desired, or expected

Coder Query-Query: Hi Dr. ________________. Can you please clarify if this patient had chronic renal failure?



Documented conditions without clinical indicators and clinical validation queries


Section I.A.19ICD-10-CM Coding Conventions: Code Assignment and Clinical Criteria The assignment of a diagnosis code is based on the provider’s diagnostic statement that the condition exists.

The provider’s statement that the patient has a particular condition is sufficient.

Code assignment is not based on clinical criteria used by the provider to establish the diagnosis.

When a diagnosis is written by a provider that does not seem clinically valid (e.g., with signs, symptoms, abnormal findings, risk factors, treatments or interventions

• Coders/CDSs cannot “ignore” or not code the diagnosis because it did not appear to be clinically valid

• Query is acceptable to verify the diagnosis and request additional supportive documentation of clinical findings/indicators

No response to query? Provider does not document the clinical criteria?

BOTTOM LINE: Provider’s documentation that the condition exists is sufficient to code that condition, per Official Coding Guidelines

2019 Official guidelines for coding and reporting

Reference: https://www.cdc.gov/nchs/icd/data/10cmguidelines-FY2019-final.pdf

https://www.cdc.gov/nchs/icd/data/10cmguidelines-FY2019-final.pdf


Beyond traditional CDI queries

Traditional CDI Clinical validation CDI

Diagnoses suggested by clinical indicators but are not documented in a codable Format, are missing specificity, or are missing acuity

Diagnoses which are documented in a codable format, but do not appear to be supported by the clinical evidence


POA queries


The following are the main rationale for determining the POA status on each diagnosis for an inpatientencounter:

Present on admission: Rationale for determining POA status

To help clarify whether a diagnoses was present on admission in order to determine if the diagnosis:

• Qualifies as a hospital acquired condition that is subject to CMS reimbursement/quality implications (HAC, HACRP, HRRP, PSI)

• Can be sequenced as a principal or secondary diagnosis based on codingguidelines

Rationale


Present on Admission: Timeline for determination of POA status

TimeframePOA

The following is a summary of guidelines around timeframes for determining whether a diagnosis is POA or hospital acquired:

There is no required timeframe as to when a provider must identify or document a condition to be present onadmission.

In some clinical situations, it may not be possible for a provider to make a definitive diagnosis (or a condition may not be recognized or reported by the patient) for a period of time after admission.

In some cases it may be several days before the provider arrives at a definitive diagnosis

Diagnoses subsequently confirmed after admission are considered present on admission if at the time of admission they are documented as suspected, possible, rule out, differential diagnosis, or constitute an underlying cause of a symptom that is present at the time of admission


Often, query templates will include a POA question on each query. If POA is clearly established by the provider at the time of admission, a leading practice is to customize the query form by removing the POA question from the query. This should alleviateinconsistencies in responses by providers who may be confused as to the intent of the question when the condition was clearly POA

For conditions that clearly occur after admission and/or a medical procedure or surgery, query the physician to determine whether the condition was a complication of the procedure or due to another etiology.

Query tips for POA


Querying for severity


Severity of Illness (SOI)

Subclass SeveritySeverity Weight

1 Minor 0.52962 Moderate 0.71473 Major 1.22504 Extreme 2.8127

Risk of Mortality (ROM)

Subclass MortalityExpected Risk of

Mortality

1 Minor 0.26%2 Moderate 1.45%3 Major 5.58%4 Extreme 28.50%

The 3M APR DRG system assigns a Severity of Illness and Expected Risk of Mortality subclass for all cases

Below is an illustration of how the APR-DRG system works for a Sepsis case:

1APR DRG = All Patient Refined Diagnostic Related Grouping SOI & ROM based on APR DRG 720

Documentation of secondary diagnoses can drive the APR weight up or down when combined with the principal diagnosis and procedures

The 3M APR DRG1 classification system


What is hospital/physician profiling?• Analysis of practice patterns, based on discharge data, to assess performance

• Analysis of the resources utilized on patients compared to the severity of illness, risk of mortality, cost, and length of stay

Who is profiling?• Federal/State regulatory agencies

• The Joint Commission (JC)

• CMS

• Peer review organizations

• Managed care and third-party payers

• Profiling agencies

• Hospitals

• Physician groups

• Employers

• Public

What is profiling?


Specific and complete documentation = Accurate provider profiles

Compares “actual” versus “expected” mortality

Compares average LOS, charges, and costs to determine performance:

• Against state / national benchmarks

• Between organizations

• Same organization over time

• Physicians to their peers

Monitors hospital and physician practice and encourage efficiency and quality

Often perceived as a measurement of quality, cost efficiency and timeliness of care delivery

Physician and hospitals can be excluded from networks based on aggregate data

Diagnosis and procedure codes that truly reflect patient severity of illness and risk of mortality are driven by documentation!

How is profiling used?


APR-DRG documentation strategies

1• Follow CMS coding guidelines to sequence the principal diagnosis, and applicable secondary diagnoses and/or

principal procedure to obtain the most accurate APR-DRG and SOI/ROM

2• Multiple secondary diagnoses can influence the APR-DRG and SOI/ROM compared to MS-DRG which requires only

one principal diagnosis and or one secondary diagnosis/principal procedure to influence the DRG

3• Some non CC/MCC diagnoses can impact APR-DRG & SOI/ROM, therefore query the provider for specificity when

clinical indicators and treatments are present without the documentation of the associated treatments are present without the documentation of the associated diagnosis

4• Coding multiple CC/MCCs on the record can increase the SOI and ROM and mitigate RAC denials. Clarify all

applicable diagnoses and procedures to reflect the true APR-DRG & SOI/ROM especially if only one CC or MCC is initially found in the record


References• Centers for Medicare and Medicaid Services ICD-10-CM Official Guidelines for Coding and Reporting.

(https://www.cms.gov/Medicare/Coding/ICD10/Downloads/2019-ICD10-Coding-Guidelines-.pdf)

• Centers for Medicare and Medicaid Services ICD-10-PCS Official Guidelines for Coding and Reporting. (https://www.cms.gov/Medicare/Coding/ICD10/2019-ICD-10-PCS.html)

• AHIMA. “Guidelines for Achieving a Compliant Query Practice (2019 Update)” Journal of AHIMA, (Feb 2019 Reference: AHIMA “Guidelines for Achieving a Compliant Query Practice (2019 Update) (https://acdis.org/resources/guidelines-achieving-compliant-query-practice-2016-update)

• AHIMA. “Clinical Documentation Improvement Toolkit (2016 version)” (https://my.ahima.org/store/product?id=63693)



Round TableQuestions and Information Sharing

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Copyright © 2019 Deloitte Development LLC. All rights reserved.

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Crosscheck Your Compliance - ACDIS Your Compliance_India… · Indiana Spring ACDIS Conference...

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