Guest Post: Keep mindful of compliance in your everyday CDI duties

by Robert S. Gold, MD

Some people go into an endeavor full bore, knowing that they’re always right.  Some people go into an endeavor learning as they go, knowing that they don’t know everything, eager to learn and always open to learning.

I found at the 2010 ACDIS conference in Chicago that most of the attendees were eager to learn and were sopping up knowledge like a sponge. Some–a very few–thought that the attention turned by a few of the presenters toward the compliance and regulatory agencies was too heavy-handed. However, the fact is that organizations are out there challenging what is done in CDI circles. It’s unhealthy and potentially dangerous to ignore the warning signs.

Back in the mid-1990s, hospitals were told that it’s right to change the code for documented “pneumonia” to the code for “gram negative pneumonia” when a patient was identified as residing in a nursing home and being diabetic with COPD or CHF.  The reasoning was that “Coding Clinic tells us that this is so,” referring to an enducational citation on patients at risk of gram negative pneumonias (Coding Clinic 3Q 1988, p. 11).

Hospitals were told that these are the rules. Hospitals believed the consultants.  Hospitals got fined billions of dollars when it was identified that the patients really didn’t have sufficient evidence in the medical record that the physician thought it was really gram negative pneumonia and really treated the patient with shotgun therapy for “CAP.”

I am not saying that it’s wrong to have confidence in what you’re doing as a CDI specialist. I’m saying that not asking questions, validating what you’re told, checking the resources of folks who have been bitten by the OIG and the RACs and the QIOs, and learning from the mistakes made in history, will lead you to repeat the mistakes done by others.

Ostriches are pretty birds. They can be easy prey when they stick their heads in the sand. The message isn’t doom and gloom—it’s check your resources and mind the warnings.

Editor's note: Dr. Robert S. Gold founded DCBA, Inc., in Atlanta, a consulting firm that provides physician-to-physician programs in CDI. The goals are data accuracy, profile management, and compliance in the inpatient and outpatient arenas.